Khumani Iron Ore Mine Infrastructure Expansion Project ...€¦ · DRAFT REPORT FOR SUBMISSION...

63 Wessel Road Rivonia 2128 PO Box 2597 Rivonia 2128 South Africa Telephone: +27 (0)11 803 5726 Facsimile: +27 (0)11 803 5745 Web: www.gcs-sa.biz

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

Offices: Durban Johannesburg Lusaka Ostrava Pretoria Windhoek

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

Non-Executive Director: B Wilson-Jones

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Khumani Iron Ore Mine

Infrastructure Expansion Project

Environmental Impact Assessment (EIA) and

Environmental Management Programme (EMP)

Report

In terms of Mineral and Petroleum Resources Development Act, 2002

(Act No. 28 of 2002) and National Environmental Management Act, 1998

(Act No. 107 of 1998) * Regulation 543, 544, 545, 546 (2010) applicable

DRAFT REPORT SUBMISSION TO STAKEHOLDERS

September 2015

Version – 1

Assmang Proprietary Limited

DMR Reference: NC30/5/1/2/3/2/1/070

NCDENC Reference: NC/EIA/17/JTG/GAM/KAT2/2014

GCS Project Number: 13-843

Assmang (Pty) Ltd: Khumani Iron Ore Mine EIA/EMP Khumani Proposed Infrastructure Expansion

13-843 September 2015 Page ii

Khumani Iron Ore Mine Infrastructure Expansion Project

Environmental Impact Assessment (EIA) and Environmental Management Programme (EMP) Report

In terms of Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002) and National Environmental Management Act, 1998 (Act No. 107 of 1998)

DRAFT REPORT FOR SUBMISSION

August 2015

Version – Draft

DMR Reference: NC30/5/1/2/3/2/1/070 NCDENC Reference: NC/EIA/17/JTG/GAM/KAT2/2014

GCS Project Number: 13 - 843

DOCUMENT ISSUE STATUS

Report Issue Draft for Authority and I&AP review

GCS Reference Number GCS Ref – 13-843

Client Reference Khumani Proposed Infrastructure Expansion

Title EIA/EMP Report

Name Signature Date

Author (GCS) Riana Panaino August 2015

Document Reviewer (GCS) Renee Janse van Rensburg August 2015

Document Reviewer (Envirogistics)

Tanja Bekker August 2015

Director GCS Seabelo Pilane August 2015

Applicant (Khumani Iron Ore Mine)

Dirk Coetzee August 2015

Applicant (Asmang (Pty) Ltd)

Quentin Hall August 2015

LEGAL NOTICE

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


13-843 September 2015 Page iii

DISCLAIMER

Information contained in this report is based on data/information supplied to GCS Water and

Environment (Pty) Ltd (GCS) by the client and other external sources (including previous site

investigation data and external specialist studies). It has been assumed that the information

provided to GCS is correct and as such the accuracy of the conclusions made are reliant on

the accuracy and completeness of the data supplied. No responsibility is accepted by GCS

for incomplete or inaccurate data supplied by the client and/or other external sources.

Opinions expressed in this report apply to the site conditions and features that existed at the

time of the start of the relevant investigations and the production of this report.


13-843 September 2015 Page iv

EXECUTIVE SUMMARY

Background

Assmang (Pty) Ltd’s Khumani Iron Ore Mine (Khumani) is situated 15km south of Kathu,

adjacent to the Kumba Iron Ore Mine. Khumani compromises of four (4) farms, namely Parson

564 (Portions 0, 2, and 6), King (Portions 0, 1, 2, and 3), Bruce 544 (Portions 3, 4, 5 and the

Remainder of Bruce No. 544) and Mokaning 560 (Portions 0, 1, 2, 3, 4, and 5).

The mine falls within two Local and District Municipalities. The farm Mokaning is situated

within the Tsantsabane Local Municipality (NC085), which forms part of the ZF Mgcawu

District Municipality (formally known as the Siyanda District Municipality). The farms Parson,

Bruce and King are situated within the Gamagara Local Municipality (NC01B1), which forms

part of the John Taolo Gaetsewe Districts Municipality (formally known as the Kgalagadi

District Municipality). Neighbouring towns and villages include, Olifantshoek, Beeshoek,

Postmasburg, and Dingleton. The main industries in the area include mining (mainly for

manganese ore, iron ore and tiger’s eye), agriculture (mainly for cattle, sheep, goat and

game farming) and tourism.

The right to mine was granted to Assmang Proprietary Limited (Assmang) in terms of the

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

January 2007. Construction of the mine was initiated after approval was received from the

Northern Cape Department of Environment and Nature Conservation (NCDENC) in June 2006

on the farm Parson and the first train was loaded with iron ore at Khumani in May 2008. The

overall mining area over which Khumani operates is approximately 9000ha. Today, the mine

is a fully operational opencast mining operation, with an approved capacity of producing 16

million tons of iron ore per annum.

The iron ore is mined from a series of open pits on the farms Bruce and King by conventional

drill and blasting methods. Haul trucks transport the Run of Mine (RoM) to the primary

crushers, from where the material is transferred by conveyor to the RoM stockpiles, ahead of

the Beneficiation Plant (Parsons Plant), located on the farm Parson. Thereafter, the product

is transported via conveyor to the rapid load out and local railway siding for transport to

either Saldanha for export and to Port Elizabeth for the local market. The following

infrastructure has been approved through various application processes under National Water

Act, 1998 (Act No. 36 of 1998) (NWA), National Environmental Management: Waste Act, 2008

(Act 59 of 2008) (NEM:WA), National Environmental Management Act, 1998 (Act No. 107 of

1998) (NEMA) and Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of

2002) (MPRDA):


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Opencast Mining Operations;

Conveyors and service roads;

Powerlines and service roads;

Access roads and haul roads;

Crushers;

Washing and screening plant;

Stockpiles (topsoil, RoM, product) and overburden;

Paste Disposal Facility;

Local and export railway siding;

Two (2) approved river diversions;

Clean and dirty water infrastructure;

Sewage treatment plants;

Offices, workshops and ancillary buildings;

Potable and process water storage tanks;

Water supply from Sedibeng Pipeline;

Domestic Landfill Site and Temporary Storage area for Hazardous Waste;

Diesel storage; and

Borrow pits.

Through Khumani’s ongoing commitment to optimise its existing mineral resources, the

design and operational team has identified the need for two (2) additional process facilities

to optimise beneficiation with the aim of producing the required grade for its Markets and

strive to meet its approved production allocation. These facilities include the Off-Grade 2

Plant (approved in terms of the NEMA during October 2013) and the proposed WHIMS 2 Plant

(part of this application). The new infrastructure will result in the need for ancillary

infrastructure associated with the activities. The construction of the Off-Grade 2 Plant has

been placed on hold due to the current decline in the iron ore market. When the market

stabilizes the feasibility of the Off-Grade 2 Plant will be reinvestigated. The Off-Grade 2

Environmental License is valid for a period of three (3) years from allocation (i.e. up until

the last quarter of 2016). The applicant will remain in consultation with the department to

ensure that the validity of this permit does not expire. Saying this, the current project has

a different philospy and aim, in that the purpose of this project is to reuse existing material

from exsiting stockpiles, as described in the section hereafter.

Project Description

It is the intention of Assmang to upgrade infrastructure on the Farms Bruce, Parsons and King

within their existing mining boundary area. The proposed upgrades on the farm Bruce include:

The extension of the existing approved Bruce Low Grade ROM Stockpile and

Overburden Dump with 75ha.


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The proposed upgrades on the farm Parsons include:

The extension of the existing approved Low Grade Stockpile (previously known as the

Parson Discard Dump);

Tertiary By-pass Stockpile area at the existing Low Grade Stockpile s;

A new Low-Grade Reclaim Facility adjacent to existing Low Grade Stockpile;

The new WHIMS 2 Plant; and

Three (3) additional conveyors.

The proposed upgrades on the farm King include;

Extension of the existing King/Mokaning Overburden Low-Grade ROM Stockpile; and

A new Low Grade Stockpile for reclaiming purposes within the King Plant area.

Other activities required will include:

Upgrading and expansion of storm water facilities (separating clean and dirty water);

High Pressure Grinding Roll (HPGR) Crushing Facility;

Haul roads; and 22kV power lines to accommodate the WHIMS 2 Plant and the

reclamation activities.

These additional activities on the farms King, Bruce and Parson will require approval under

NEMA, the NWA and an Amendment to the Environmental Management Programme (EMP) in

terms of the MPRDA. The activities will not influence the production output or Mining Works

Programme of the mine.

Environmental Process Objectives

GCS Water and Environment (Pty) Ltd (GCS) have been appointed as the independent

Environmental Assessment Practitioners (EAP) to undertake the environmental processes

required to obtain approval for the proposed listed activities, as requested by the relevant

competent authorities. The project requires authorisations in respect of the following Acts:

MPRDA;

NEMA; and

NWA.

In order to mitigate potentially negative impacts and to identify any potential fatal flaws

which may render the project environmentally unacceptable, GCS has adopted an integrated,

step-by-step process to identify issues of concern and to thoroughly investigate these issues.

To ensure that the negative impacts are identified and mitigated in the early stages of the


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project, and that the positive impacts are maximised, it will be necessary for the

environmental study to meet the following aims:

Follow the guideline process as outlined by the NEMA and the MPRDA;

Provide input in the feasibility phases to ensure that the most technically feasible,

and environmentally sound options are selected;

Ensure that impacts are identified early through investigations to minimize

environmental damage and maximise benefits;

Conduct thorough special investigations that will allow the project team to develop

an adequate understanding of the issues to be dealt with;

Compile an EIA that will identify, evaluate and address the potential impacts;

Provide ongoing environmental input into the project planning and development;

Compile an EMP that will limit the significance of the negative impacts and maximise

the positive aspects;

Ensure that all relevant Interested and Affected Parties (I&APs) are consulted and

involved throughout the environmental process; and

Ensure that an open and transparent communication structure is in place during the

life of the mine.

Strong emphasis has been placed placed on the MPRDA, NEMA and NWA processes to ensure

that the processes will be able to run concurrently, and will easily be comparable with no

confusion between the different processes.

Public Participation Process (PPP)

The following process was followed with respect to consultation of I&APs and the Government

Authorities.

List of Authorities Consulted

The following Authorities have been identified and invited to become involved in the process

to date:

National Government Authorities:

Department of Water and Sanitation (DWS); and

Department of Mineral Resources (DMR).

Provincial Government Authorities:

NCDENC;

Department of Transport, Roads and Public Works; and

Provincial Administration Northern Cape.

Catchment Agency:

Tshiping Water Users Association


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District Municipalities:

John Taolo Gaetsewe District Municipality.

ZF Mgcawu District Municipality

Local Municipalities:

Tsantsabane Local Municipality; and

Gamagara Local Municipality.

Other Authorities:

Transnet;

South African National Parks;

The Wildlife and Environment Society of South Africa (WESSA); and

The South African Heritage Resource Agency (SAHRA).

Identification of I&APs

A Comprehensive List of I&APs, which had been previously contacted for previous Khumani

applications has been updated by GCS through a process of networking, press advertisements

and site notices.

Notification of Stakeholders

Site Notice

Site Notices were placed at the mine and at the proposed sites to inform the public of the

proposed infrastructure and upgrades at Khumani.

BID

A Background Information Document (BID) was sent to all I&APs on the existing database by

means of email, fax and or post. The BID was compiled in English and it included details of

the proposed project, the EIA process and the requirements of the NEMA, MPRDA and NWA.

The BID also included relevant contact details and a comment/registration sheet for I&APs

to complete. I&APs were invited to register and send responses, by fax, telephone or email

to GCS.

Advertisements

An advertisement regarding the proposed project and associated environmental applications

was placed in the regional newspaper, Diamond Fields Advertiser (DFA), on the 17 September

2014.

An advertisements was placed on the DFA newspaper notifying the I&APs on the availability

of the draft Environmental Scoping Report (ESR) on Friday, 31 October 2014)


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An additional advertisement was placed in the Volksblad and Kathu Gazette on the 15th of

May 2015, as notification of the inclusion of the Dump expansion on the Farm Bruce.

Availability of Report

The draft ESR was made available for Public review and comments for a 40 day period from

23 October 2014 until 28 November 2014. The report was made available on the GCS

Website www.gcs-sa.biz. I&APs were notified of the availability of the draft report via emails,

faxes and letters. No comments from any stakeholders were received.

An addendum to the ESR which served to include the expansion of the Dump on the farm

Bruce was submitted on the 15th of May 2015 for consideration by the department before

continueing with the EIA.

The PPP is on-going and will follow the environmental process up until the decision by the

Competent Authorities has been reached.

Environmental Baseline Description

Geology

The farm Parsons is situated in the northern part of the Maramane Dome. Carbonate rocks of

the Campbellrand Subgroup and iron formations of the Asbesheuwels Subgroup of the

Transvaal sequence define the dome. The eastern part of Maramane Dome is exposed. The

red beds of the Gamagara Formation of the Olifantshoek Group overlie the Transvaal

sequence along an angular unconformity to the west.

Topography

The general topography is characterised by fairly flat terrain, with no steep inclines, except

for the two (2) mountain ranges to the west (Langberg range) and a smaller range to the east

(Kuruman Heuwels). Altitudes range from approximately 1360 metres above mean sea level

(mamsl) in the south to 1200mamsl in the north. Various landform elevations occur on the

four (4) farms, with the highest elevations on the southern portion of Mokaning farm

(1365mamsl) and on the border between Mokaning and King farms (1347mamsl).

Climate

The proposed infrastructure upgrades are located in an area that is characterised by a low

rainfall. Most of the rainfall in this semi-arid region occurs in summer and autumn months

between December and April. The mean annual rainfall recorded at the Postmasburg

Weather Station between 1918 and 1999 equates to 325mm. The mean monthly rainfall is

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27mm. The summers in the Northern Cape are hot with maximum temperatures usually

between 30 and 35 Degrees Celsius. High summer temperatures are the cause of atmospheric

instability and turbulence, which leads to the development of thunderstorms. Winter

temperatures are cold, with temperatures below 10 Degrees Celsius not uncommon. The

area is characterised by a north-westerly wind. The average wind speed is between 1.6 and

3.5m/s.

Soils

Soil distribution is strongly linked to the topography of the area. In turn, the topography is

closely linked to the underlying surface geology. Hard rock outcrops characterise the

topographic highs of the area. The outcrops generally comprise quartzites and the iron ore

bearing ironstones. These outcrops form prominent hills or ridges with moderate to steep

slopes. In these areas, soils are very shallow to non-existent, occurring as erratic pockets of

orange sands within the outcrops. The pockets can be as deep as 1m. These soils are classified

as Mispah Form soils, with minor occurrences of Hutton Form soils.

Land Use

Kumba Iron Ore Mine (Kumba), a large opencast mining operation of the Anglo American

Group, is situated directly north of the farm Parson, west of the farm Bruce, and north west

of the farm King. Besides the mining operations, other activities in the region include

livestock farming, and small residential communities and business trade. The land use on site

is currently mining and mining related operations.

The main land uses in the study area are:

Livestock grazing;

Game farming; and

Mining.

In terms of the municipal Strategic Development Framework the area is zoned for mining

activities.

Land Capability

The site is located within the mining area and surrounded by infrastructure associated with

the mining industry and as a result, has no specific land capabilities other than that of mining

and mining related activities. There are no substantial areas of arable land or wetland areas

within the site, some pans (depressions) does exists in the proposed Low Grade Stockpile area

on the southern Khumani extent.


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Heritage and Sites of Cultural Significance

No archaeological artifacts have been identified in the footprint areas where infrastructure

is planned. The sites of heritage and cultural significance as identified during the original EIA

studies, is not in close proximity of the proposed activities and will be maintained as per the

management conditions.

Biodiversity

A total of 70 plant species were recorded during the field investigations on the farm Parsons

564 (April 2014). During the April 2014 survey a well-developed herbaceous stratum was

found, represented by 28 forbs (40%) and 18 grass species (25.7%). A physiognomically

dominant shrub and tree layer is represented by 12 shrub species (17.1%) and 5 tree species

(7.1%). This floristic diversity is represented by 32 families dominated by Poaceae (20 species,

29.1%), Fabaceae (8 species, 11.4%) and Asteraceae (7 species, 10.0%). The physiognomy and

diversity exhibited by natural habitat with the study areas is regarded representative of the

regional vegetation types. Degradation and transformation is noted on a local and regional

scale. It is therefore concluded that the vegetation is in a sub climax status.

Animals known to be present in the Q-grids 2723CC, 2722BA, 2722BB and 2722BD were

considered potential inhabitants of the study area (all species known from the Northern Cape

Province were included in the assessment to limit the known effects of sampling bias, except

for birds, which have been sampled extensively and the data for the Q-grids is accepted as

accurate).

Wetlands

The recently published Atlas of Freshwater Ecosystem Priority Areas in South Africa (Nel et

al, 2011a) (The Atlas) which represents the culmination of the National Freshwater Ecosystem

Priority Areas project (NFEPA), a partnership between SANBI, CSIR, WRC, DEA, DWA, WWF,

SAIAB and SANParks, provides a series of maps detailing strategic spatial priorities for

conserving South Africa’s freshwater ecosystems and supporting sustainable use of water

resources. Freshwater Ecosystem Priority Areas (FEPA’s) were identified through a systematic

biodiversity planning approach that incorporated a range of biodiversity aspects such as

ecoregion, current condition of habitat, presence of threatened vegetation, fish, frogs and

birds, and importance in terms of maintaining downstream habitat. The Atlas incorporates

the National Wetland Inventory (SANBI, 2011) to provide information on the distribution and

extent of wetland areas.

According to the NFEPA database, no pans are present on the Parsons or King footprint areas.

This was confirmed during the 2014 site visit. There are numerous pans present in the


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adjacent areas of the Parsons expansion, but none within the footprint area. A wetland was

identified to be present on the proposed Bruce Expansion site. The wetland was characterized

as an Eastern Kalahari Bushveld Depression.

The following important observations can be made:

Flagship river: Ga-Magara river traverses the farm Bruce to the south and the farm

Parson to the North. The river is however not in close proximity to the proposed

activities; and

There is one wetland present within the proposed Bruce expansion area.

Hydrology

The area of the proposed upgrades falls within the Lower Vaal Water Management Area. The

area is situated in the catchment of the Gamagara River, the quaternary catchment being

D41J. The site is located on gently sloping to hilly terrain with rivers flowing in a north-

westerly direction. The major river traversing the site is the Gamagara River, which flows

from the east to west north of the Parsons Plant area. The river then flows north to

confluence with the Kuruman River.

Iron ore, diamonds and manganese are mined in the water management area. Farming

activity ranges from extensive livestock production and rain fed cultivation to intensive

irrigation enterprises at Vaalharts. Kimberley, which straddles the divide between the Lower

Vaal and Upper Orange water management areas, is the largest urban centre in the area.

More than 50% of the yield from natural water resources in the tributary catchments within

the water management area is supplied from groundwater.

None of the proposed activities are located within floodlines of river systems in the area.

The mine further has a well established monitoring programme in place, which has not

indicated any significant pollution sources from the mine.

Geohydrology

The hydraulic properties of the area are characterised by shallow dolomitic aquifers with

high transmissivities. The lithologies below the dolomites are characterised by a host

interbedded chert, ironstones, chert breccias, quartzites, conglomerates and shales which

would be indicative of primary and secondary aquifers. Groundwater flow will mainly be in

the form of fracture flow. Porosities vary greatly throughout the lithologies from 1% to 30%.

The dykes in the area that have not been permeated by faulting, form compartments where

water is dammed up and greatly disrupt groundwater flow; this phenomenon is known as

compartmentalisation. The shallow aquifers are of younger age than the dyke structures and


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are therefore not intruded by these structures. The implication of this is that the shallow,

unconsolidated sandy aquifers were previously not affected by the dyke structures and water

could flow freely across the top of the dyke structures and the water levels would be more

constant throughout the area. As the water table has now been lowered, the effect of

compartmentalisation has now become relevant.

No dewatering activiites are undertaken by the mine, due to ongoing dewatering activities

taking place in the surrounding area.

Air Quality

Sources that may contribute to air pollution include, blasting activities associated with the

mining operations, windblown dust from the various mine stockpiles in the area, vehicle

emissions (the N14 runs between the farms Bruce and King), household fuel combustion,

biomass burning (from veld fires and agriculture) and various miscellaneous fugitive dust

sources (agriculture activities, wind erosion of open areas and vehicle entrainment of dust

along unpaved and paved roads).

Sensitive receptor areas in the vicinity of the mine are road users on the N14, the towns of

Dingleton, Olifantshoek and Kathu. In addition, there are various farms and homesteads

surrounding the proposed area.

Visual

The semi-arid open nature of the landscape renders it particularly sensitive to visual

intrusion, especially from mining activities or any other surface infrastructure such as the

proposed various infrastructure at Khumani. However, the landscape character and sense of

place is also determined, to a large extent, by the existing mining activities in the region.

The expectation of visitors to the area and those persons travelling along the N14 will

therefore be of a mining area and not a pristine landscape devoid of human intervention. The

proposed upgrades at Khumani will be vital for the mine and add to the visual aspect of the

mining activities in the area.

Noise

The area in which the proposed the proposed infrastructure upgrades are to be established,

is characterised by the following environments:

A rural farming community where the farmsteads are located at large distances

apart;

The existing large opencast operation at Kumba;

The existing opencast operation at Khumani; and


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The N14 and the railway lines that cross the area.

Areas in the proximity of existing mining activities will already be subjected to the noise

emissions from diesel-powered equipment and other mining processes. The proposed

activities, should not contribute to the current noise sources in this area.

Social

The Northern Cape Province is the largest province in South Africa with a land area the size

of 361 830km2. The province has a population density of two (2) persons per every km2.

Prominent languages include Afrikaans, English, Nama, SeTswana and Xhosa

(www.northerncape.org.za). The Province is divided into 5 DMs. These are again subdivided

into 4 LMs. Major Towns include Calvinia, Colesberg, Kuruman, Springbok and Upington.

Population and Household

The population size (persons) for the Gamagara District Municipality increased by 25.47% over

the 1995 to 2011 time period, whereas the John Taolo Gaetsewe District Municipality only

grew by 12.49% over the same period. Households have also grown over the 1995 to 2011 time

period, with the Gamagara Local Municipality showing a 30.36% increase and the John Taolo

Gaetsewe District Municipality by 27.23%.

Population Group

The Gamagara Local Municipality population are composed of mostly Black African persons

(49.96%) followed by 34.58% Coloured persons. The John Taolo Gaetsewe District

Municipality, however, shows an 87.36% Black African population with a much smaller

percentage of Coloured persons (8.76%). According to the 2011 Statistics SA census, Kathu

(Ward 4) has mainly a Coloured population (58.53%).

The sex ratio is 120,1 males per 100 females, (Statistics South Africa, census 2011)

The main languages that are spoken in the area are: Afrikaans, Setswana and English.

Age

It is important to assess the age distribution of persons in order to determine both the current

and future needs of an area. Age is an important indicator as it relates to education, skills

and dependency. A young population may require an improved educational system, whereas

an older society may need an accented focus on healthcare. The largest percentage of people

in the Gamagara Local Municipality, 71.9% fall within the working age category (16-64 years

of age). 25.5% of the population are between the age of 0 and 14. And the elderly population


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forms 2.5% of the municipality’s population. (Statistics South Africa, census 2011) Persons

younger than 15 years of age do not form part of the Economically Active Population (EAP)

of the area.

Education

The largest percentage (89,5%) of the Gamagara Local Municipality population has obtained

some form of primary schooling. 24.9% of the population has attained matric and a further

3.6% with higher education.

Employment and Labour

The largest sector of employment in the Local Municipality is the mining sector, supplying

just over a third of the jobs in the area. Followed by wholesale and retail trade jobs, which

make up around 12% of the total employment. The main reason for this distribution are mines,

like Sishen and Khumani in the area that are the largest employers in the municipality.

The main average income of households in the Gamagara Local Municipality is between

R9,601 and R307,600 as derived from the census 2011 data. It should however be noted that

around 10% of the population in the municipality do not earn an income.

Services and Infrastructure

Social service delivery centres on the provision of health, education and community

development facilities and services. The concept of service delivery also comprises various

elements such as affordability, quality, efficiency and access.

This indicator therefore examines the level of service provision in the study area. Services

assessed include sanitation, water, housing and electrification. There are three priority

services (water, sanitation and electricity) for the promotion of health, convenience and

quality of life.

Housing

According to the 2011 census, almost 75% of the households in the Gamagara municipality

live in formal dwellings. The second largest dwelling group in the municipality is workers’

hostels, which can be associated with mining activities. Kumba is converting its hostels into

bachelor flats (www.northerncapebusiness.co.za). The third largest dwelling type in

Gamagara is informal dwellings that are not in someone’s backyard. These settlements are

an indication that people are coming to the area from other areas to seek employment. Quite

often these work seekers are not successful because most of the jobs have already been filled


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and they lack the funds to return home, or they do not earn enough to afford to rent a house

or a room in the area.

Energy Use

The use of electricity for lighting, cooking and heating was by far the highest across all

regions. Some gas, paraffin and wood is also used, but these energy sources are being used

less and less, mainly due to the fact that the majority of people live in formal dwellings.

Water and Sanitation

The households in the municipality have access to piped water inside their residence. 3% of

the households rely on boreholes for water supply.

As for sanitation, 87,6% of the households have flush toilets with a small percentage of

households making use of pit latrines. (Statistics South Africa, census 2011)

Activities Resulting in Impacts and Requiring Mitigation

The following activities may result in impact on the bio-physical and socio-cultural

environment:

Site clearance:

o Stripping of vegetation for infrastructure development;

o Stripping of topsoil and subsoil as the construction activities start on site;

Construction activities:

o Construction of the WHIMS2 Plant on Parsons;

o Enlargement of the Low Grade Stockpile on Parsons;

o Construction of Low Grade Reclamation Facility on Parsons;

o Constuction of Tertiary By-pass Stockpile on Parsons;

o Construction of Low Grade Stockpile on King

o Expansion of the the King/Mokaning Low Grade RoM Stockpile;

o Expansion of the Bruce Low Grade RoM Stockpile;

o Construction and expansion of converyer belts on Parsons; and

o Upgrade of the existing stormwater management structures.

Decommissioning and Closure activites:

o Stockpile shaping and stabilising for closure;

o Removal of plant and associated infrastructure; and

o Landscaping of footprint area.

The following impacts may arise due to the above mentioned activities:

Loss of vegetation, which may include senstitive strata, such as the Kameeldoring

tree;.


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Loss of topsoil

Minimal impact on the water system albeit with an increase in runoff and associated

siltation potential;

Loss of sensitive aquatic systems, such as the pans present on Parsons and impact on

the pan wetland on the farm Bruce;

Possible compaction of soils by the establishment of topsoil stockpiles and berms;

and

Dust dispersion from infrastructure construction activities.

An impact assessment (Section 7) has been undertaken for the life of the project as the

activities specified may trigger impacts requiring mitigation and management measures to

be implemented. It should however be noted, that the management measures included are

based on the management measures recommended and approved as part of prior EMPs and

conditions stipulated in approved Environmental Permits and Licenses.

Needs and Desirability of the Project

The project should be seen as a continuation of Khumani’s commitment made in the Mining

Right Application and subsequent EMPs, to reclaim all low grade material as far as practically

possible. The motivation can therefore be stated as the following:


operational team has identified the need for additional process facilities required to optimise

beneficiation and still meet its approved production allocation. The approved Khumani Mining

Right Application, submitted by the mine, stipulated the mine’s intention to reuse low grade

material by reclaiming same in the future. The proposed project ensures that the mine fulfils

this commitment.

No-Go Option

Not reclaiming the low-grade material, will result in the presence of extensive infrastructure

requiring shaping and stabilising as part of the closure conditions stipulated in the approved

EMPs. Reusing material throughout the life of mine, can be regarded as ongoing

rehabilitation, whist also resulting in an economic benefit to both the mine and iron ore

markets. This in return will lower the mines financial environmental liability in terms of

rehabilitation. The overall project as presented in this report is therefore presented with

the view of reducing long term rehabilitation requirements.

Identified Direct Impacts

Direct Impacts during Construction


13-843 September 2015 Page xviii

It shoud be noted that impacts associated with the proposed projects will be significantly

lower than those in greenfields area, as activities are located within the mine’s dirty water

management area and mostly within already disturbed environments.

Topography

Direct impact: topographical changes as a result of land and footprint clearance,

topsoil stripping, stockpiling, and infrastructure establishment.

Soils, Land Use and Land Capability

Direct impact: loss of topsoil (soil stripping) in preparation for the construction

phase;

Direct impact: stripping of topsoil and sub-surface layers will alter the soil landscape

during the construction phase;

Direct impact: soil compaction due to construction activities and vehicular movement

on site;

Direct impact: soil erosion due to exposed surfaces; and

Direct impact: soil contamination due to construction vehicles and potential

hydrocarbon spillages and/or leaks.

Hydrology

Direct impact: hydrocarbon spillages from equipment utilised in construction

activities.

Geohydrology

Direct impact: allthough no significant impacts are foreseen by the proposed

activities on the geohydrological resources, the increase in stockpile areas, may

reduce the potential recharge to aquifers.

Biodiversity

Direct impact: loss of floral and faunal species of conservation importance due to

topsoil removal and vegetation disturbance;

Direct impact: displacement of faunal species and human/animal conflict during site

preparation activities; and.

Air Quality

Direct impact: incease in dust fallout from topsoil removal and vegetation removal.

Visual


13-843 September 2015 Page xix

Direct impact: loss of soil due to soil due to stripping and footprint clearance will

impact the perceptions of people travelling past site and staying/working near site.

Noise

Direct impact: increased noise due to increased vehicular movement on site.

Wetlands

Direct Impact: Destruction of non perennial pan systems

Direct Impacts during the Operational Phase

Topography

Direct impact: topographical changes resulting from the changes in the stockpiles

sizes and heights due to disposal and reclamation activities;


Direct impact: soil erosion due to exposed surfaces; and.

Direct impact: soil contamination due to operation vehicles and equipment and

potential hydrocarbon spillages and/or leaks.

Geohydrology

Direct impact: the increase in stockpile areas, may reduce the potential recharge to

aquifers.

Biodiversity

No further impacts foreseen.

Air Quality

Direct impact: increase in dust fallout from the stockpiles due to the disposal of

material onto stockpile areas and the relamation activities.

Visual

Direct impact: visual changes resulting from the changes in the stockpiles sizes and

heights due to disposal and reclamation activities.

Direct impact: increase in dust fallout from the disposal of material onto stockpile

areas and the relamation activities.

Noise


13-843 September 2015 Page xx

Direct impact: increased noise due to increased vehicular movement on site; and

Direct impact: operation of the plant.

Wetlands

Direct impact: Destruction of non-perennial pan system.

Direct Impacts during Decommissioning and Closure

Topography

Direct impact: reshaping of the area following mining activities in order to achieve

the proposed end of mine land use.


Direct impact: soil compaction due to vehicles and equipment utilised in the

rehabilitationactivities contributing to vehicular movement on site;

Direct impact: soil erosion due to exposed surfaces and rehabilitation;

Direct impact: soil contamination due to the operation of vehicles and equipment

during rehabilitation and potential hydrocarbon spillages and/or leaks;

Direct impact: Re-establishment of end land use objectives; and

Hydrology

• Direct impact: surface water contamination as a result of hydrocarbon spills from

vehicles used during decommissioning; and

• Direct impact: Siltation during to water running off site once the berms and

stormwater structure are decommissioned.

Geohydrology

• Direct impact: groundwater quality impacts due to potential spillages and

contamination.

Biodiversity

• Direct impact: disruption to faunal and floral communities that have established on

site during the operational phase; and.

• Direct impact: re-establishment of faunal and floral communities during the

rehabilitation process.

Air Quality

• Direct impact: fugitive dust emissions; and


13-843 September 2015 Page xxi

• Direct impact: dust entrainment from vehicles on site as a result of driving on

exposed surfaces.

Visual

• Direct impact: landscaping of the entire site and berm removals; and

• Direct impact: removal of infrastructure from site and re-establishment of vegetated

areas.

Noise

• Direct impact: increased noise due to rehabilitation activities; and

• Direct impact: reduction in noise levels due to mining cessation.

Social

• Direct impact: out-migration of job seekers as the mining operations cease;

• Direct impact: job losses;

• Direct impact: loss of the social and economic investment by the mine as part of the

mine’s Social and Labour Plan into the municipal Integrated Development Plan (IDP);

and

• Direct impact: a reduction in economic activities due to job losses and mine closure.

Direct Cumulative Impacts

Biodiversity

• Direct impact: loss of ecological connectivitiy and ecosystem functioning, resulting

in the overall movement of animals within this region, which could impact

surrounding game reserves and tourism activities.

Air Quality

• Direct impact: increase in dust fallout throughout the life of mine and impact on

surrounding residence, especially considering the combined impact with including

surrounding mining activities in the area.

Social and economical

• Direct impact: in-migration of job seekers;;

• Direct impact: employment opportunites during all phases of the operation, which

will contribute to the multiplier effect;

• Direct impact: improvement of service delivery in the immediate project area; and


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• Direct impact: increase in crime, which may extent the boundaries of the mining

area;

Wetlands

• Direct impact: increased sedimentation in the wetland on site and downstream

wetlands and water course.

Impact Statement

From the assessment of impacts throughout all the phases it is clear that though the impacts

may occur directly as a result of the proposed infrastructure upgrades, the impacts are mostly

of medium significance before mitigation. According to the assessment carried out by the

EAP the majority of the impacts can be reduced to a low significance with the appropriate

mitigation measures in places. The motivation of the project in terms of long term economic

benefits and also the indirect rehabilitation which will take place as part of the reworking

activities must be considered in the conclusion of the assessment. The EAPs and

environmental consultants responsible for the compilation of this document, and the

associated PPP are of the opinion based on the presented specialist assessments and impact

assessment that the Khumani Ifrastructure upgrades should be authorised. The following

mitigation measures are crucial and should form part of the environmental authorisation to

ensure that the applicant manages impacts adeaquatly:

• Adhere to the updated Stormwater Management Plan;

• Adhere to the Existing Environmental Management Plan;

• Ensure that all design drawings include effective erosion control measures;

• Comply with the conditions of the WUL;

• Adhere to the Emergency Procedures Report and implement spill clean-up

procedures;

• Apply for relevant permits with authorities for the removal of indigenous tree and

plant species; and

• Major Spill should be reported within 24hr to the Department of Water and Sanitation

and the NCDENC.


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ABBREVIATIONS AND ACRONYMS

ABBREVIATION/ACRONYM DESCRIPTION

% Percent

± Plus/Minus

°C Degrees Celsius

< Less than

> Greater than

ABA Acid Based Accounting

AEL Air Emmission License

AM Ante Meridiem (Before midday)

ADMS 5 Atmospheric Dispersion Modelling System

BA Basic Assessment

BFS Bankable Feasibility Study

BID Background Information Document

Ca Calcium

Ca-HCO3 Calcium bicarbonate

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

CD Compact Disc

CERC Cambridge Environmental Research Consultants

cm Centimeter

CR Critically Rare

CSI Corporate Social Investment

CSR Corporate Social Responsibility

DTPW Department of Transport and Public Works

DA Department of Agriculture

dB decibel

dBA Decibels (Weighted)

DDD Insufficient Information

DDT Taxonomically Problematic

DEA Department of Environmental Affairs

DM District Municipality

DMR Department of Mineral Resources

DMS Dense Medium Separation

DWS Department of Water and Sanitation

E East

EAP Environmental Assessment Practitioner

EERP Environmental Emergency Response Plan

EC Electrical Conductivity

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

EIA Environmental Impact Assessment

EIS Ecological Importance and Sensitivity analysis


13-843 September 2015 Page xxiv


EMP Environmental Management Plan/Programme

EN Endangered

ESR Enviromental Scoping Report

FEL Front End Loader

Fe2O3 Ironoxide

Fax Facsimile

FEPA Freshwater Ecosystem Priority Areas

GCS GCS Water and Environment (Pty) Ltd

GPS Global Positioning System

Ha/lsu Hectare/Livestock Unit

HDPE High-Density Polyethylene

HGM Hydro-geomorphic

HIA Heritage Impact Assessment

HL Habitat linkage

HR Habitat requirements

HS Habitat status

Hz Hertz

I&APs Interested and Affected Parties

IDP Integrated Development Plan

IHAS Invertebrate Habitat Assessment System

IHI Index of Habitat Integrity

IRR Issues and Response Register

IUCN International Union for Conservation of Nature

IWUL Integrated Water Use License

IWULA Integrated Water Use License Application

IWWMP Integrated Water and Waste Management Plan

K Potassium

Kg Kilogram

Kl/d Kilolitres per Day

km Kilometres

l Litres

l/d Litres per Day

l/s Litres per Second

LED Local Economic Development

LM Local Municipality

LOM Life of Mine

LOS Level Of Service

Mg Magnesium

m Metres

m2 Square Meters

m3 Cubic Metres


13-843 September 2015 Page xxv


m3/Hr Cubic Metres per Hour

MAE Mean Annual Evaporation

MAP Mean Annual Precipitation

MAR Mean Annual Runoff

masl Metres Above Sea Level

mbgl Metres Below Ground Level

mg/Kg Milligrams per Kilogram

mm Millimetres

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

Na Sodium

Na-Cl Sodium chloride

N/A Not Applicable

NEAS National Environmental Authorisation System

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

NFEPA National Freshwater Ecosystem Priority Areas

NGA National Groundwater Archive

NEM:BA National Environmental Management: Biodiversity Act (Act No. 10 of

2004)

NEM:WA National Environmental Management: Waste Act

NT Near Threatened

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

P phosphorus

PCD Pollution Control Dam

PES Present Ecological State

PFD Process Flow Diagram

pH Potential of Hydrogen

PM Post meridiem (After midday)

PoC Probability of Occurrence

PPP Public Participation Process

ROM Run of Mine

S South

S&EIR Scoping and Environmental Impact Report

SAHRA South African Heritage Resource Agency

SANBI South African National Biodiversity Institute

SANRAL South African National Roads Agency Limited

SANS 10103 South African National Standard 10103

SAR Sodium Absorption Ratio

SASS5 South African Scoring System

SAWS South African Weather Service

SDF Strategic Development Framework

SEA Strategic Environmental Assessment

SIA Social Impact Assessment


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SLP Social and Labour Plan

SMMEs Small, Micro and Medium Enterprises

sms Short Message Services

SWMP Stormwater Management Plan

t Ton

t/hr Tons per Hour

t/day Tons per Day

t/w Tons per Week

t/m3 Tons per Cubic Metre

TFR Transnet Freight Rail

tpm Tons per Month

TSP Total Suspended Particulates

vph Vehicles Per Hour

VU Vulnerable

WHIMS Wet High Intensity Magnetic Seperator

WMA Water Management Area

WUL Water Use License


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CONTENTS PAGE

1 INTRODUCTION AND BACKGROUND .......................................................................................... 1

1.1 BACKGROUND ............................................................................................................................... 1 1.2 BRIEF PROJECT DESCRIPTION ........................................................................................................... 3 1.3 DESCRIPTION OF LAND .................................................................................................................... 4 1.5 LEGISLATIVE BACKGROUND .............................................................................................................. 6

1.5.1 The Constitution ................................................................................................................ 7 1.5.2 Environmental Principles .................................................................................................. 8 1.5.3 Polluter Pays Principle..................................................................................................... 10 1.5.4 Precautionary Principle ................................................................................................... 10 1.5.5 Preventive Principle ........................................................................................................ 10 1.5.6 Cradle-to-Grave .............................................................................................................. 11 1.5.7 Mineral and Petroleum Resources Development Act (Act No. 28 of 2002) (MPRDA) Process 11 1.5.8 National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA) Process 13 1.5.9 National Environmental Management, Waste Act, 2008 (Act No. 59 of 2008) (NEM:WA) Process 15 1.5.10 National Water Act, 1998 (Act No. 36 of 1998) (NWA) Process ..................................... 17

1.6 ENVIRONMENTAL PROCESSES ......................................................................................................... 19 1.6.1 Environmental Process Objectives .................................................................................. 19 1.6.2 The MPRDA Amendment ................................................................................................ 19 1.6.3 The NEMA ....................................................................................................................... 20 1.6.4 The NEM:WA................................................................................................................... 26 1.6.5 The NWA ......................................................................................................................... 28

1.7 ROLES AND RESPONSIBILITIES IN TERMS OF THE NEMA AND MPRDA ................................................... 29 1.7.1 The Applicant .................................................................................................................. 29 1.7.2 The Environmental Assessment Practitioner .................................................................. 30 1.7.3 Interested and Affected Parties ...................................................................................... 32

1.8 ENVIRONMENTAL REPORTING ........................................................................................................ 32 1.8.1 Environmental Impact Assessment ................................................................................. 32 1.8.2 Environmental Management Programme ...................................................................... 34 1.8.3 Reporting Structure (EIA/EMP) ....................................................................................... 34

2 DETAILED PROJECT DESCRIPTION ............................................................................................. 38

2.1 EXISTING INFRASTRUCTURE ............................................................................................................ 38 2.2 PROPOSED INFRASTRUCTURE AND UPGRADES ................................................................................... 55

2.2.1 WHIMS 2 Plant (C) .......................................................................................................... 55 2.2.2 Parsons Low Grade Stockpile Expansion (A) ................................................................... 56 2.2.3 Low Grade Reclaim Facility (B) ....................................................................................... 56 2.2.4 Tertiary By-pass Stockpile (E) .......................................................................................... 57

2.3 ADDITIONAL LOW GRADE STOCKPILES ............................................................................................. 57 2.3.1 King ROM Stockpile (J) .................................................................................................... 57 2.3.2 King/Mokaning Low Grade ROM Stockpile Expansion (H) .............................................. 58 2.3.3 Bruce Low Grade ROM Stockpile and Overburden Dump Expansion (K) ........................ 58

2.4 ANCILLARY INFRASTRUCTURE ......................................................................................................... 59 2.5 BULK SUPPORTING SERVICES .......................................................................................................... 59 2.6 MINING ACTIVITIES ...................................................................................................................... 60 2.7 PROPOSED PROJECT PLANNING AND ASSOCIATED ACTIVITIES ............................................................... 60

2.7.1 Pre-Construction Phase ................................................................................................... 61 2.7.2 Construction Phase ......................................................................................................... 61 2.7.3 Operational Phase .......................................................................................................... 62


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2.7.4 Decommissioning and Closure Phase.............................................................................. 63

3 PROJECT ALTERNATIVES ........................................................................................................... 64

3.1 ACTIVITY ALTERNATIVES ................................................................................................................ 64 3.2 NEEDS AND DESIREABILITY OF THE PROJECT ...................................................................................... 65 3.3 NO-GO PRINCIPLE ....................................................................................................................... 65

4 DETAILED ENVIRONMENTAL DESCRIPTION ............................................................................... 66

4.1 GEOLOGY ................................................................................................................................... 66 4.2 TOPOGRAPHY ............................................................................................................................. 67 4.3 CLIMATE .................................................................................................................................... 68

4.3.1 Precipitation.................................................................................................................... 68 4.3.2 Temperature ................................................................................................................... 69 4.3.3 Wind................................................................................................................................ 70

4.4 SOILS, LAND USE AND LAND CAPABILITY ........................................................................................... 72 4.4.1 Soil .................................................................................................................................. 72 4.4.2 Land Capability ............................................................................................................... 74 4.4.3 Land Use ......................................................................................................................... 75

4.5 HERITAGE AND SITES OF CULTURAL SIGNIFICANCE .............................................................................. 75 4.6 BIODIVERSITY .............................................................................................................................. 76

4.6.1 Regional Ecology ............................................................................................................. 76 4.6.2 Freshwater Ecosystems ................................................................................................... 77 4.6.3 Flora ................................................................................................................................ 79

4.6.3.1 Botanical diversity ..................................................................................................................... 79 4.6.3.2 Flora species of conservation importance ................................................................................. 80 4.6.3.3 Protected tree species (National Forest Act) ............................................................................ 82 4.6.3.4 Vegetation development drivers ............................................................................................... 82 4.6.3.5 Macro habitat types and variations observed ........................................................................... 82 4.6.3.6 Botanical sensitivity of the study area ...................................................................................... 84

4.6.4 Fauna .............................................................................................................................. 86 4.6.7.1 Degraded faunal habitat ........................................................................................................... 89

4.7 HYDROLOGY ............................................................................................................................... 90 4.7.1 MAP and MAE ................................................................................................................. 92 4.7.2 Peak Rainfall ................................................................................................................... 93 4.7.3 Mean Annual Runoff (MAR) ............................................................................................ 93 4.7.4 Normal Dry Weather Flow (NDWF) ................................................................................ 95 4.7.5 Downstream water users ................................................................................................ 95

4.8 GEOHYDROLOGY .......................................................................................................................... 95 4.8.1 General aquifer description ............................................................................................ 96 4.8.2 Hydrocensus .................................................................................................................... 97

4.8.2.1 Boreholes Visited ...................................................................................................................... 99 4.8.2.2 Groundwater Levels .................................................................................................................. 99

4.8.3 Groundwater Quality .................................................................................................... 102 4.8.4 Conceptual model ......................................................................................................... 104

4.8.4.1 Conceptual Model Boundaries ................................................................................................ 104 4.8.4.2 Groundwater Consideration .................................................................................................... 104

4.9 AIR QUALITY ............................................................................................................................. 105 4.9.1 Single Dust Monitoring Units ........................................................................................ 106 4.9.2 Directional Dust Monitoring Units ................................................................................ 108

4.10 VISUAL .................................................................................................................................... 110 4.11 NOISE...................................................................................................................................... 110 4.12 SOCIAL CONDITIONS ................................................................................................................... 111

4.12.1 Introduction and approach ........................................................................................... 111 4.12.3 Local Context (Gamagara Local Municipality) .............................................................. 112

4.12.3.1 Demographic Profile ........................................................................................................... 113

5 PUBLIC PARTICIPATION PROCESS ........................................................................................... 121


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5.1 PURPOSE OF PUBLIC PARTICIPATION .............................................................................................. 121 5.2 LIST OF AUTHORITIES CONSULTED ................................................................................................. 122 5.3 SCOPING PHASE ........................................................................................................................ 122

5.3.1 Identification of I&APs .................................................................................................. 123 5.3.2 Notification of Stakeholders ......................................................................................... 123

5.3.2.1 Site Notice ............................................................................................................................... 123 5.3.2.2 BID ........................................................................................................................................... 123 5.3.2.3 Advertisements ....................................................................................................................... 123

5.3.3 Availability of Reports ................................................................................................... 123 5.4 EIA PHASE ............................................................................................................................... 124

5.4.1 Advertisements ............................................................................................................. 124 Availability of Reports ........................................................................................................... 124

6 ENVIRONMENTAL MANAGEMENT GOALS AND OBJECTIVES ................................................... 125

6.1 ACTIVITIES ................................................................................................................................ 125 6.1.1 Pre-Construction Phase ................................................................................................. 126 6.1.2 Construction Phase ....................................................................................................... 126 6.1.3 Operational Phase ........................................................................................................ 127 6.1.4 Closure and Decommissioning Phase............................................................................ 127 6.1.5 Post-Closure Phase........................................................................................................ 127

6.2 ENVIRONMENTAL MANAGEMENT OBJECTIVES ................................................................................. 128 6.2.1 Construction Phase ....................................................................................................... 128

6.2.1.1 Land Clearance, Soil Stripping and Stockpiling ........................................................................ 128 6.2.1.2 Establishment of Infrastructure and stockpiles ....................................................................... 129 6.2.1.3 Waste handling ....................................................................................................................... 129

6.2.2 Operational Phase ........................................................................................................ 130 6.2.2.1 Low Grade Stockpiles, ROM Stockpile and Overburden stockpiling ........................................ 130 6.2.2.2 Reworking Strategy ................................................................................................................. 130 6.2.2.3 Operation of Clean and Dirty Water Systems and Stormwater Management Systems .......... 130 6.2.2.4 Hydrocarbon Storage ............................................................................................................. 131

6.2.3 Closure and Decommissioning ...................................................................................... 131 6.2.3.1 Aftercare, Monitoring and Maintenance ................................................................................ 131

7 IDENTIFICATION OF IMPACTS AND CONCERNS WITH MANAGEMENT MEASURES AND ACTION PLANS ............................................................................................................................................ 132

7.1 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY ................................................................... 133 7.2 PRE-CONSTRUCTION PHASE ......................................................................................................... 136 7.3 CONSTRUCTION PHASE ............................................................................................................... 136

7.3.1 Geology ......................................................................................................................... 136 7.3.2 Climate .......................................................................................................................... 136 7.3.3 Topography ................................................................................................................... 136 7.3.4 Soils, Land Use and Land Capability .............................................................................. 136 7.3.5 Heritage and Sites of Cultural Significance ................................................................... 137 7.3.6 Hydrology ...................................................................................................................... 137 7.3.7 Geohydrology ................................................................................................................ 137 7.3.8 Biodiversity ................................................................................................................... 137 7.3.9 Air Quality ..................................................................................................................... 138 7.3.10 Visual ............................................................................................................................ 138 7.3.11 Noise ............................................................................................................................. 138 7.3.12 Social ............................................................................................................................. 139 7.3.13 Wetlands ....................................................................................................................... 139 7.3.14 Construction Phase Impact Assessment ....................................................................... 139

7.4 OPERATIONAL PHASE ................................................................................................................. 147 7.4.1 Geology ......................................................................................................................... 147 7.4.2 Topography ................................................................................................................... 147 7.4.3 Soils, Land Use and Land Capability .............................................................................. 147


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7.4.4 Heritage and Sites of Cultural Significance ................................................................... 147 7.4.5 Hydrology ...................................................................................................................... 147 7.4.6 Geohydrology ................................................................................................................ 148 7.4.7 Biodiversity ................................................................................................................... 148 7.4.8 Air Quality ..................................................................................................................... 148 7.4.9 Visual ............................................................................................................................ 148 7.4.10 Noise ............................................................................................................................. 149 7.4.11 Social ............................................................................................................................. 149 7.4.12 Wetlands ....................................................................................................................... 149 7.4.13 Operational Phase Impact Assessment ......................................................................... 149

7.5 DECOMMISSIONING AND CLOSURE PHASE ...................................................................................... 155 7.5.1 Geology ......................................................................................................................... 155 7.5.2 Topography ................................................................................................................... 155 7.5.3 Soils, Land Use and Land Capability .............................................................................. 156 7.5.4 Heritage and Sites of Cultural Significance ................................................................... 156 7.5.5 Hydrology ...................................................................................................................... 156 7.5.6 Geohydrology ................................................................................................................ 156 7.5.7 Biodiversity ................................................................................................................... 156 7.5.8 Air Quality ..................................................................................................................... 157 7.5.9 Visual ............................................................................................................................ 157 7.5.10 Noise ............................................................................................................................. 157 7.5.11 Social ............................................................................................................................. 158 7.5.12 Wetlands ....................................................................................................................... 158 7.5.13 Decomissioning and Closure Phase Impact Assessment ............................................... 158

7.6 POST CLOSURE AND RESIDUAL IMPACTS ......................................................................................... 166 7.7 CUMULATIVE IMPACTS ................................................................................................................ 169

7.7.1 Geology ......................................................................................................................... 169 7.7.2 Topography ................................................................................................................... 170 7.7.3 Soils, Land Use and Land Capability .............................................................................. 170 7.7.4 Heritage and Sites of Cultural Significance ................................................................... 170 7.7.5 Hydrology ...................................................................................................................... 170 7.7.6 Geohydrology ................................................................................................................ 170 7.7.7 Biodiversity ................................................................................................................... 170 7.7.8 Air Quality ..................................................................................................................... 171 7.7.9 Social ............................................................................................................................. 171

8 MONITORING AND AUDIT MANAGEMENT PROGRAMME ...................................................... 175

8.1 WATER MONITORING................................................................................................................. 176 8.1.1 Surface Water Monitoring ............................................................................................ 176

8.1.1.1 Locality of Surface Water Sampling Points: ............................................................................. 177 8.1.1.2 Variables .................................................................................................................................. 177 8.1.1.3 Frequency ................................................................................................................................ 178 8.1.1.4 Operational, Inspection and Maintenance Requirements ...................................................... 178

8.1.2 Groundwater Monitoring Programme .......................................................................... 180 8.2 DUST MONITORING ................................................................................................................... 184 8.3 NOISE MONITORING ................................................................................................................... 188 8.4 SOIL AND VEGETATION MONITORING ............................................................................................ 189 8.5 PERIODIC MINE ENVIRONMENTAL AUDIT ....................................................................................... 189

9.2.1 Defining an Environmental Emergency Response Plan ................................................. 191 9.4.1 Communication Sectors ................................................................................................ 195 9.4.2 Management Sector ..................................................................................................... 195 9.4.3 Administrative Sector .................................................................................................... 195 9.4.4 Contractors ................................................................................................................... 204 9.5.1 Induction ....................................................................................................................... 204 9.5.2 Environmental Symposiums .......................................................................................... 204


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9.5.3 In-house Training .......................................................................................................... 205 9.5.4 On the Job Training ....................................................................................................... 205 9.5.5 General Training and Skills Development ..................................................................... 205 9.5.6 Environmental Open Days ............................................................................................ 205 9.5.7 Publications................................................................................................................... 205 9.6.1 Internal Communication ............................................................................................... 206 9.6.2 External Communication Strategies ............................................................................. 206

10 FINANCIAL PROVISION ........................................................................................................... 209

10.1 OVERVIEW OF LEGAL REQUIREMENTS ............................................................................................ 209

11 ENVIRONMENTAL REHABILITATION PROGRAMME ................................................................ 211

11.1 BACKGROUND INFORMATION ....................................................................................................... 211 11.1.1 Nature of the Mining Operation ................................................................................... 211 11.1.2 Impacts of the Mining Operation .................................................................................. 211 11.1.3 Land Use of the Surrounding Area ................................................................................ 212

11.2 AIM OF REHABILITATION PLAN ..................................................................................................... 212 11.3 REHABILITATION OBJECTIVES ....................................................................................................... 213 11.4 MANAGEMENT CRITERIA FOR THE REHABILITATION OF LAND .............................................................. 213

11.4.1 Removal of Infrastructure ............................................................................................. 214 11.4.2 Active Rehabilitation - Landscaping .............................................................................. 214 11.4.3 Disposal of material ...................................................................................................... 214 11.4.4 Water Pollution Control Structures ............................................................................... 215 11.4.5 Maintenance ................................................................................................................. 215

12 INFORMATION GAPS AND FURTHER ASSESSMENTS REQUIRED .............................................. 218

13 MOTIVATION FOR THE PROJECT ............................................................................................. 219

14 LIST OF SPECIALIST STUDIES UNDERTAKEN ............................................................................. 220

15 ENVIRONMENTAL IMPACT STATEMENT ................................................................................. 223

16 CONCLUSION .......................................................................................................................... 228

LIST OF FIGURES

Figure 1.1: Locality Map................................................................................... 1 Figure 1.2: Khumani Mining Right Boundary Area .................................................... 4 Figure 2.1: Proposed new infrastructure on the farm Parsons .................................... 56 Figure 2.2: Proposed new stockpiles on the farm King ............................................. 58 Figure 2.3: Proposed stockpile expansion on the farm Bruce ..................................... 59 Figure 4.1: Geological Map of the Khumani Mine area. ............................................ 67 Figure 4.2: Topographical map of the Khumani mine area. ....................................... 68 Figure 4.3 Average Monthly Temperature measured at Parsons Weather Station (2012-2014) 69 Figure 4.4 Average Monthly Temperature measured at Parsons Weather Station (2012-2014) 70 Figure 4.5: Period Wind roses recorded at Parsons Weather Station for period (2012-2014) 71 Figure 4.6: Period Wind roses recorded at Parsons Weather Station for period (2012-2014) 72 Figure 4.7: Soil Types. .................................................................................... 73 Figure 4.8: Current Land Use within the Khumani mine area. .................................... 75 Figure 4.9: NFEPA’s of the study area ................................................................. 78 Figure 4.10: Surface water management areas of the greater mining right area. ............ 92 Figure 4.11: Runoff in Regional Rivers ................................................................. 94 Figure 4.12: Runoff into Local Rivers .................................................................. 94 Figure 4.13: Hydrocensus points ........................................................................ 98 Figure 4.14 Single dust monitoring units (annual average results per site 2007-2014) . 107


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Figure 4.15 Directional DustWatch dust monitoring units (annual average results per site 2007-2014) 109 Figure 4.16: Population and household size (1995 – 2011) ....................................... 114 Figure 4.17 Age and Sex distribution (2011) ................................................... 115 Figure 4.18 Education Level (2011) .............................................................. 116 Figure 4.19 Economic Status (2011) ............................................................. 117 Figure 4.20 Average household Income (2011) ................................................ 118 Figure 4.21 Type of Energy (2011) ............................................................... 119 Figure 4.22 Access to Water (2011) ............................................................. 120 Figure 4.23 Access to Sanitation (2011) ........................................................ 120 Figure 6.1: Proposed Activity Flowchart ............................................................ 126 Figure 7.1: Process for impact assessment. ........................................................ 134 Figure 8.1: Surface water and Groundwater Monitoring Points ................................. 179

LIST OF TABLES

Table 1.1: Land Ownership ............................................................................... 5 Table 1.2: Description of the S&EIR process in terms of GN R543 in GG 33306 of 18 June 2010 of NEMA. .................................................................................................... 21 Table 1.3: Listed activities in terms of NEMA 2010 Regulations. ................................. 23 Table 1.4: Name and address of Applicant representative. ...................................... 30 Table 1.5: Name and Address of Environmental Assessment Practitioner. ..................... 31 Table 1.6: Environmental Project Resources. ....................................................... 31 Table 2.1 Existing infrastructure at Khumani Iron Ore Mine ...................................... 39 Table 4.1: Land Capability Classes ..................................................................... 74 Table 4.2: Growth form recorded on Parson during the April 2014 survey ..................... 80 Table 4.3: Plant families recorded on Parson during the April 2014 survey .................... 80 Table 4.4: Botanical conservation data for the Northern Cape ................................... 81 Table 4.5: Plant species conservation status in the Northern Cape .............................. 81 Table 4.6: Conservation important plant species recorded during the April 2014 survey .... 81 Table 4.7: Protected tree species of the region ..................................................... 82 Table 4.8: Floristic sensitivity estimations of the study area ..................................... 86 Table 4.9: Protected species of the Northern Cape Province ..................................... 89 Table 4.10: Faunal habitat sensitivity of the study area ........................................... 90 Table 4.11: Mean annual rainfall and evaporation in mm/month ................................ 92 Table 4.12:24-hour design rainfall values ............................................................. 93 Table 4.13: Groundwater Statistics (2013) ........................................................... 99 Table 4.14: Summary of hydrocensus (Please refer to Appendix C for the high resolution Table). ..................................................................................................... 100 Table 4.15: Hydrochemistry results for the hydrocensus points. .............................. 103 Table 4.16: Gamagara Local Municipality ........................................................... 112 Table 7.1: Ranking Scales used in Impact Assessment. ........................................... 135 Table 7.2: Impact Significance Ratings .............................................................. 135 Table 7.3: Impacts and Management Measures for Construction Phase Activities. .......... 140 Table 7.4: Impacts and Management Measures for Operational Phase Activities. ........... 150 Table 7.5: Impacts and Management Measures for Closure and Decommissioning Phase Activities. ................................................................................................. 159 Table 7.6: Impacts and Management Measures for Post Closure Impacts. .................... 167 Table 7.7: Impacts and Management Measures for Cumulative Activities. ................... 172 Table 8.1: Groundwater monitoring points and schedules ....................................... 180 Table 8.2 Groundwater Quality Parameters .................................................... 182 Table 8.3 Khumani Dust Management Plan ..................................................... 185 Table 8.4: Environmental Emergency Procedures and Responses .............................. 193 Table 8.5: Environmental Awareness Plan for the Construction Phase at Khumani. ....... 197 Table 8.6: Environmental Awareness Plan for the Operational Phase at Khumani. ........ 200


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Table 8.7: Environmental Awareness Plan for the Decommissioning Phase at Khumani. .. 203 Table 11.1: Responsibilities and Responsible Parties for Rehabilitation Activities. ......... 217 Table 14.1: Previous Specialist Studies .............................................................. 221

LIST OF APPENDICES

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

FIGURE 1.1: LOCALITY MAP. ...............................................................................

FIGURE 1.2: KHUMANI MINING RIGHT BOUNDARY AREA ............................................

FIGURE 2.1: PROPOSED NEW INFRASTRUCTURE ON THE FARM PARSONS .......................

FIGURE 2.2: PROPOSED NEW STOCKPILES ON THE FARM KING ....................................

FIGURE 2.3: PROPOSED STOCKPILE EXPANSION ON THE FARM BRUCE ...........................

FIGURE 4.1: GEOLOGICAL MAP OF THE KHUMANI MINE AREA. ....................................

FIGURE 4.2: TOPOGRAPHICAL MAP OF THE KHUMANI MINE AREA. ...............................

FIGURE 4.7: SOIL TYPES. ................................................................................

FIGURE 4.8: CURRENT LAND USE WITHIN THE KHUMANI MINE AREA. ............................

FIGURE 4.9: NFEPA’S OF THE STUDY AREA ...........................................................

FIGURE 4.10: SURFACE WATER MANAGEMENT AREAS OF THE GREATER MINING RIGHT AREA.

FIGURE 4.13: HYDROCENSUS POINTS ...................................................................

FIGURE 8.1: SURFACE WATER AND GROUNDWATER MONITORING POINTS ......................

APPENDIX B: PROOF OF PPP ................................................................................

APPENDIX C: SPECIALIST ASSESSMENTS ...................................................................

C1: GROUNDWATER STUDIES ...............................................................................

C2: HYDROLOGY ..............................................................................................

C3: ECOLOGY ..................................................................................................


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1 INTRODUCTION AND BACKGROUND

1.1 Background

Khumani Iron Ore Mine (Khumani) is situated 15km south of Kathu, adjacent to the Kumba

Iron Ore Mine. Khumani compromises of four (4) farms, namely Parson 564 (Portions 0, 2, and

6), King (Portions 0, 1, 2, and 3), Bruce 544 (Portions 3, 4, 5 and the Remainder of Bruce No.

544) and Mokaning 560 (Portions 0, 1, 2, 3, 4, and 5).

The mine falls within two Local and District Municipalities (Figure 1.1). The farm Mokaning

is situated within the Tsantsabane Local Municipality (NC085), which forms part of the ZF

Mgcawu District Municipality (formally known as the Siyanda District Municipality). The farms

Parson, Bruce and King are situated within the Gamagara Local Municipality (NC01B1), which

forms part of the John Taolo Gaetsewe Districts Municipality (formally known as the Kgalagadi

District Municipality). Neighbouring towns and villages include, Olifantshoek, Beeshoek,

Postmasburg, and Dingleton. The main industries in the area include mining (mainly for

manganese ore, iron ore and tiger’s eye), agriculture (mainly cattle, sheep, goat and game

farming) and tourism.

(Please refer to Appendix A for the A3 figure.)

Figure 1.1: Locality Map.


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The right to mine was granted to Assmang Proprietary Limited (Assmang) in terms of the

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

January 2007. Construction of the mine was initiated after approval was received from the

Northern Cape Department of Environment and Nature Conservation (NCDENC) in June 2006

on the farm Parson and the first train was loaded with iron ore at Khumani in May 2008. The

overall mining area over which Khumani operates is approximately 9000ha. Today, the mine

is a fully operational opencast mining operation, with an approved capacity of producing 16

million tons of iron ore per annum.

The iron ore is mined from a series of open pits on the farms Bruce and King by conventional

drill and blasting methods. Haul trucks transport the Run of Mine (RoM) to the primary

crushers, from where the material is transferred by conveyor to the RoM stockpiles, ahead of

the Beneficiation Plant (Parsons Plant), located on the farm Parson. Thereafter, the product

is transported via conveyor to the rapid load out and local railway siding for transport to

either Saldanha for export and to Port Elizabeth for the local market. The following

infrastructure has been approved through various application processes under NWA, NEMA

and MPRDA:





Crushers;



Paste Disposal Facility;









Diesel storage; and

Borrow pits.


design and operational team has identified the need for two (2) additional process facilities


13-843 June 2015 Page 3

to optimise beneficiation with the aim of producing the required grade for its markets and

strive to meet its approved production allocation. These facilities include the Off-Grade 2

Plant (approved in terms of the NEMA during October 2013) and the proposed WHIMS 2 Plant

(part of this application). The new infrastructure will result in the need for ancillary

infrastructure associated with the activities. The construction of the Off-Grade 2 Plant has

been placed on hold due to the current decline in the iron ore market. When the market

stabilizes the feasibility of the Off-Grade 2 Plant will be reinvestigated. The Off-Grade 2

Environmental License is valid for a period of three (3) years from allocation (i.e. up until

the last quarter of 2016). The applicant will remain in consultation with the department to

ensure that the validity of this permit does not expire. Saying this, the current project has

a different philospy and aim, in that the purpose of this project is to reuse existing material

from exsiting stockpiles, as described in the section hereafter.

1.2 Brief Project Description


within their existing mining boundary area (Figure 1.2). The proposed upgrades on the farm

Bruce include:



















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These additional activities on the farms Bruce, King and Parson will require approval under

NEMA, the National Water Act, 1998 (Act No. 36 of 1998) (NWA) and an Amendment to the

Environmental Management Programme (EMP) in terms of the Mineral and Petroleum

Resources Development Act, 2002 (Act No. 28 of 2002) (MPRDA). The activities will not

influence the production output or Mining Works Programme of the mine.


Figure 1.2: Khumani Mining Right Boundary Area

1.3 Description of Land

This section of the report relates to Section 31(2) of the GNR543 published in the Government

Gazette No.33306 of 18 June 2010, under Section 24(5) of the National Environmental

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

Regulation 31(2)

2 c) A description of the property on which the activity is to be undertaken and the location of the activity on the property and if it is:

i. A linear activity, a description of the route of activity;

ii. An ocean based activity ,the co-ordinates where the activity is to be undertaken


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The mine falls within two Local and District Municipalities. The farm Mokaning is situated

within the Tsantsabane Local Municipality (NC085), which forms part of the ZF Macgawu

District Municipality. The farms Parson, Bruce and King are situated within the Gamagara

Local Municipality (NC01B1), which forms part of the John Taolo Gaetsewe Districts

Municipality (formally known as the Kgalagadi District Municipality). Neighbouring towns and

villages include, Olifantshoek, Beeshoek, Postmasburg, and Dingleton.

The farms and portions that will be affected by the proposed Khumani infrastructure upgrades

are detailed in Table 1.1.

Table 1.1: Land Ownership

FARM NAME PORTION REGISTRATION

DIVISION SIZE

SURFACE OWNER AND

TITLE DEED

Parson 564 RE Kuruman RD 1878.83 Ha Owner: Assmang (Pty) Ltd

Title Deed: T193/2006

King 561 RE Kuruman RD 2320.31 Ha Owner: Assmang (Pty) Ltd


Mokaning 560 1 and 3 Kuruman RD 558.8023 Ha

Owner: Assmang (PTY)

Ltd


Bruce 544 RE Kuruman RD 2346.86Ha Owner: Assmang (PTY) Ltd Title Deed: T349/1954

1.4 Offset Area Investigation

Assmang has been in the process of investigating opportunities for the establishment of an

Offset Area since 2006. The offset area has been under investigation from 2006, various

areas have been part of lengthy discussions with NCDENC. Some of the areas already discussed

included:

The Witsand Nature Reserve and surrounding farms;

The Kathu Forest and surrounding farms;

A number of identified farms in the Olifantshoek area;

The Assmang Outside Story Game Farm;

Undisturbed parts of the Khumani Iron Ore Mine site; and

Portion 1 and Portion 2 of the farm Beaumont 569 west of Khumani.


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NCDENC also listed preferences in terms of offset opportunities:

The first priority for the NCDENC is to expand existing areas;

The second priority for the NCDENC is to look at a conservation plan and funding

where specific areas (as part of the SANBI strategy) have been identified by the

government;

The third priority for the NCDENC is to look at a fund which will be managed by the

NCDENC.

Various constraints have delayed this process (i.e. land claims, departmental philosophy

change and guidance). During the meeting in November 2013, preliminary agreement was

obtained from the Department that the existing 2006 Environmental Conservation Act, 1989

(ECA) permit (Permit 43/2006) be amended, not to exclude the offset area, but to re-issue

the condition in terms of a working strategy between the mine and NCDENC. This amendment

request was submitted to the department on 24 February 2014.

A meeting was held with NCDENC on the 15th of April 2014 regarding the status of the process

and to discuss the agreed way forward of the Khumani Iron Ore Mine Offset Area process.

Subsequent to the submission of the amendment application to the department, the

Department has requested that Assmang present the department with a commitment in

writing of the proposed process that will be followed to work towards a Biodiversity Offset

Agreement and that this letter will be attached to the existing permit (2006) with the

department’s agreement on the way forward.

The way forward agreed to for the proposed Biodiversity Offset Area will be the undertaking

of a Biodiversity Offset Agreement which must be undertaken by a suitable and qualified

Biodiversity Specialist, as suggested by the Department.

To date the following has been implemented by Khumani to give effect to the Biodiversity

Offset Agreement:

Mr. Mark Botha from Conservation Strategy Tactics & Insight was appointed on the

6th of August 2014 as recommended by NCDENC to compile the Biodiversity Offset

Agreement. Consultation meetings are currently still ongoing.

Feedback of this process will be given to all stakeholders as part of this application process.

1.5 Legislative Background


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For most of its history, the mining industry in South Africa has not been subjected to

comprehensive environmental regulation. However, in recent years, this has changed

significantly and the industry is now required to comply with a multifaceted network of

mining and environmental legislation. There are no shortages of policy and legal frameworks

to ensure “responsible” mining in South Africa. The Minerals and Mining Policy for South

Africa, 1998 affirmed that the State, as custodian of the nation’s natural resources will

support mining development while maintaining and enhancing environmental awareness of

the mining industry in accordance with national environmental policy, norms and standards.

To this end, 10 principles on sustainable mining were adopted. These include the adoption

of the precautionary approach as well as the polluter pays principle; assertion that a

consistent standard of environmental impact management would be adopted, irrespective of

the scale of mining concerned; encouraging the mining industry to reduce problems of

pollution by promoting a culture of waste minimisation through re-cycling, and re-use of

waste products; and ensuring the effective implementation of environmental management

measures and monitoring of occurrences of pollution, amongst others.

1.5.1 The Constitution

The Constitution reigns supreme and the advancement of human rights is one of the

foundations of South Africa’s democracy. Furthermore, the Bill of Rights plays a central role

in the democratic regime because it embodies a set of fundamental values which should be

promoted at all times. One of the fundamental values is contained in Section 24 and is,

arguably, the cornerstone for environmental governance in South Africa which includes the

mining industry. Section 24(a) proclaims the right of everyone “to an environment that is

not harmful to their health or well-being”. Mining companies are thus duty-bound to

constitutional, legislative, and other measures to prevent pollution and ecological

degradation, promote conservation and to develop in a sustainable manner.

Two particular judgments deserve consideration in that they contain a comprehensive

analysis of the nature and content of the environmental right within the sustainability

context. Firstly, the court in BP Southern Africa (Pty) Ltd v MEC for Agriculture, Conservation

and Land Affairs 2004 5 SA 124 (WLD) confirmed that environmental interests should be

balanced with justifiable economic and social development well beyond the interests of the

present living generation. The court justified the latter with Section 24(b), since this Section

requires the environment to be protected for the benefit of present and future generations.

The court confirmed the importance of sustainable development and predicted that it will

“…play a major role in determining important environmental disputes in the future”.

Furthermore, the court emphasised the importance of progressively realising the protected


13-843 June 2015 Page 8

environmental right by stating that “Pure economic principles will no longer determine, in

an unbridled fashion, whether a development is acceptable. Development, which may be

regarded as economically and financially sound, will, in future, be balanced by its

environmental impact, taking coherent cognisance of the principle of intergenerational

equity and sustainable use of resources in order to arrive at an integrated management of

the environment, sustainable development and socio-economic concerns. By elevating the

environment to a fundamental justifiable human right, South Africa has irreversibly

embarked on a road, which will lead to the goal of attaining a protected environment by an

integrated approach, which takes into consideration, inter alia, socio-economic concerns and

principles.”

Within this context, the mining industry (and the accompanied social and economic

development it should bring with it) is constitutionally bound to uphold the environmental

right. The court in Fuel Retailers Association of Southern Africa v Director General:

Environmental Management, Department of Agriculture, Conservation and Environment,

Mpumalanga Province 2007 6 SA 4 (CC) attempted to balance these social, environmental and

economic concerns by recognising the importance of economic and social development for

the well-being of human beings. However, the court emphasised that development and the

environment are inexorably linked and development cannot exist upon a weakening

environmental base. Consequently, the promotion of development requires the protection

of the environment.

The constitutional environmental right elevates the importance of environmental protection

and conservation, and emphasises the significance that South Africans attach to a sound and

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

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

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

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

sectoral legislation which relate to mining.

1.5.2 Environmental Principles

Section 2(1)(c) of the NEMA provides that “The principles set out in this section apply

throughout the Republic to the actions of all organs of state that may significantly affect

the environment and serve as guidelines by reference to which any organ of state must

exercise any function when taking any decision in terms of this Act or any statutory provision

concerning the protection of the environment…”


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Any decision taken in respect of the proposed application for environmental authorization

should take into account the principles as set out in Section 2 of NEMA. GCS Water &

Environment (Pty) Ltd (GCS) acknowledge that these principles serve as guiding principles

because they are binding, enforceable and justifiable. By adhering to these principles, GCS

promotes a cautious approach when advising on the activities, processes and daily operations

of the mine and Infrastructure and also advocates compliance with environmental regulatory

measures.

The principles contained in Section 2 of NEMA are the corner stone of environmental

governance and liability in South Africa and is based on the foundation of sustainable

development. These principles all apply directly to mines by virtue of Section 37(1) of the

MPRDA which provides that regard must be had to the NEMA principles by stipulating that the

principles set out in Section 2 of NEMA:

“a) Apply to all prospecting and mining operations, as the case may be, and any matter or

activity relating to such operation; and

b) Serve as a guideline for the interpretation, administration and implementation of the

environmental requirements of this Act.”

Section 37(2) of the MPRDA further provides that “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.”

(own emphasis)

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

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

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

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

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

life cycles. When a competent authority takes a decision in terms of NEMA or any other law

concerned with environmental protection, the principles must serve as guidelines. More

specifically, the principles should guide the interpretation and implementation of the liability

regime of NEMA and any other law concerned with environmental protection including mining

related legislation. The following principles are particularly important and are discussed in

the following sections.


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1.5.3 Polluter Pays Principle

The polluter pays principle is reflected in the provision 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

must be paid for by those responsible for harming the environment. Therefore rehabilitation

guarantees are put in place.

In essence, the polluter pays principle means that “polluters and users of natural resources

(should) bear the full environmental and social costs of their activities”. The polluter pays

principle can also be described as an economic principle that requires the polluter (the mining

industry in this instance) to be held liable to compensate or pay for pollution prevention,

minimisation and remediation. Therefore, the crux of the principle is to impose economic

obligations when environmental damage is caused by a polluter and this is achieved by setting

minimum rules on liability for environmental damage.

1.5.4 Precautionary Principle

The precautionary principle provides guidance during development or when anything occurs

which might harm the environment and where there is scientific uncertainty. NEMA stipulates

and requires “a risk averse and cautious approach” to be applied and that decision-makers

should take “into account the limits of current knowledge about the consequences of

decisions and actions”. This approach is also acknowledged in the White Paper on a Minerals

and Mining Policy for South Africa in that:

“…during decision-making a risk averse and cautious approach that recognises the limits of

current environmental management expertise will be adopted and where there is

uncertainty, action is required to limit the risk”.

The precautionary principle requires the mining industry to take adequate precautionary

measures to safeguard against contamination, pollution or degradation of the environment

and where there is uncertainty, the action taken should be to limit the risk to the

environment.

1.5.5 Preventive Principle

The preventive principle is reflected in the concept that the disturbance of ecosystems and

loss of biological diversity are to be “…avoided, or minimised and remedied.” Furthermore,

the principle prescribes that the disturbance of the landscape and the nation’s cultural

heritage is to be avoided, and where it cannot be altogether avoided, must be minimised and


13-843 June 2015 Page 11

remedied. Any negative impacts on the environment and on people’s environmental rights

should also be anticipated and prevented, and where they cannot be altogether prevented

they should minimised and remedied.

The principle aims to minimise environmental damage by requiring that action be taken at

an early stage of the process, and if possible, before such damage actually occurs. Broadly

stated, it prohibits any activity which causes or may cause damage to the environment in

violation of the duty of care established under environmental law. The preventive principle

bestows on the mining industry an obligation to take steps to avoid causing certain types of

damage to the environment, including the environment beyond their own territory or

property.

1.5.6 Cradle-to-Grave

A cradle-to-grave stewardship perspective indicates the adoption of a comprehensive

ecological view of the impacts of a process on the environment, commencing with research,

development and design through the extraction and use of raw materials, production and

processing, storage, distribution and use, to the final disposal of the product and the waste

generated as a by-product. The integrated consideration of all the environmental impacts

forms part of this cycle. The cradle-to-grave principle advocates liability as a result of, or

caused by, policies, programmes, projects, products, processes, services and activities.

Given the general purpose of NEMA, together with the other sustainability principles, this

legal liability may include to rectify, remedy or compensate for environmental damage or

degradation. The principle also recognises that environmental impacts, pollution or

degradation may be associated with the entire life cycle of a mine, that is, from the

identification, exploration phase through project planning, implementation, operations and

post-operational closure, decommissioning and rehabilitation. Thus, the mining industry will

remain liable for the damage or degradation caused by its activities throughout the life cycle

of the mining operations until decommissioning and rehabilitation.

1.5.7 Mineral and Petroleum Resources Development Act (Act No. 28 of 2002) (MPRDA) Process

Section 38 provides a key insight into the MPRDAs environmental liability approach. In terms

of this Section, mining companies are required to familiarize themselves of potential

environmental impacts; manage any environmental impacts; and rehabilitate the

environment in so far as is reasonably possible. Furthermore, Section 38(1)(e) states that

such holders, whose mining causes or results in ecological degradation, pollution, or

environmental damage that may be harmful to the health or well-being of anyone “…is


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responsible for any environmental damage, pollution or ecological degradation as a result

of his or her operations and which may occur inside and outside the boundaries of the area

to which such right, permit or permission relates.”

These holders will “…remain responsible for any environmental liability, pollution or

ecological degradation and the management thereof until a closure certificate has been

issued”. Similar to NEMA, the MPRDA specifically extends the widely-framed liability of mines

to the director of the mining company concerned in his or her personal capacity, by stating

in Section 38(2) the following:

“...the directors of a company or members of a close corporation are jointly and severally

liable; for any unacceptable negative impact on the environment, including damage,

degradation or pollution; advertently or inadvertently caused by the company or close

corporation which they represent or represented.”

In general, this provides for a comprehensive liability net which must also be considered in

light of NEMAs provisions. According to Section 39, a mine must indicate how it will contain

or remedy the cause of pollution or degradation and migration of pollutants and comply with

any prescribed waste standards or management practice. Granting of permission to mine or

prospect, among others, is conditional on an environmental management programme and

plan being submitted and accepted by the relevant government authority. Section 43 is one

of the most important provisions as it deals with the responsibility for any environmental

liability, pollution or ecological degradation until the issue of the closure certificate. It is

important to note that environmental liability will not necessarily cease or fall away by the

issuing of a closure certificate. In addition to the broader liability provisions above, Section

45 provides that the relevant authority may direct a mine to undertake remedial measures

where:

“...any prospecting, mining, reconnaissance or production operations cause or results in

ecological degradation, pollution or environmental damage which may be harmful to the

health or well-being of anyone and requires urgent remedial measures.”

Where the mine fails to take these measures, the relevant authority will act on its behalf and

then recover costs incurred from the mine. If the mine fails to compensate the authority,

the latter is empowered to seize and sell the mine’s property to recover the costs. The mine

will thus remain financially liable for the rehabilitation, even if it chooses to ignore the

government directive.


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It is noted that there have been substantial amendments to the MPRDA. However, due to

uncertainty and lack of guidance from the Department of Mineral Resources on how the new

amendments should be implemented, it is assumed that the old MPRDA (before the

amendments were promulgated) still functions as guiding mining legislation. Kindly note

that Section 39 (pertaining to environmental management plans/programmes) has been

repealed by the new amendments to the MPRDA. However, to ensure compliance with

Section 24 of the Constitution (i.e. the constitutionally protected environmental right) and

the environmental management principles contained in Section 2 of NEMA as well as to

ensure compliance with best practice guidelines, Section 38 and 39 should be utilised as a

guideline to indicate how compliance will be met.

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

As stated above, NEMA provides for a comprehensive array of principles which cumulatively

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

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

from these principles, NEMA also contains mechanisms, procedures and structures to

facilitate pollution prevention, minimisation and remediation.

Chapter 7 of NEMA contains essential provisions dealing with liability for environmental

damage in South Africa and two key elements form part thereof; namely: pollution prevention

and remediation. A duty of care is contained in Section 28, which encompasses the main

liability provision which applies retrospectively and therefore also to historical pollution.

Section 28(1) applies to all forms of pollution, including mining pollution, and is formulated

generally by providing a duty of care to avoid, minimise and/or remedy pollution or

environmental degradation. In terms of this subsection, the duty imposes liability on an

almost non-exhaustive category of persons, because it refers to “every person”. Section

28(2) goes even further and imposes the duty on a range of people including owners or people

in control of land or premises and people who have the right to use the land or premises on

which, or in which, an activity or process is, or was, performed or undertaken, or any other

situation exists which causes, or is likely to cause, significant pollution or degradation to the

environment.

The duty of care imposes strict liability since Section 28(1) requires reasonable persons to

take reasonable measures. Subsection (3) provides an indicative range of measures that can

be considered as “reasonable measures” and these may include measures to investigate,

assess and evaluate the impact on the environment; inform and educate employees about


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the environmental risks of their work and the manner in which their tasks must be performed

in order to avoid causing significant pollution or degradation, contain or prevent the

movement of pollutants or the causing of degradation, eliminate any source of the pollution

or degradation and remedy the effects of the pollution or degradation. One can identify from

the wording an obligation to prevent and minimise pollution or degradation and the list

indicates that remediation is clearly part of South African law. Where a mine fails to take

reasonable measures to prevent or minimise pollution, it can be directed to do so by the

relevant authority and if it does not comply with the directive, measures will be taken by

government on its behalf, but at the mine’s expense.

Under Section 34(7), liability is specifically extended to the director of the mining company

concerned in his or her personal capacity, in other words, the director is personally liable.

Furthermore, Section 43 provides that if directors failed to take all reasonable steps to

prevent the offence being committed, and monetary advantage was gained, they may be

personally liable for damages or compensation, have to pay a fine, or have to comply with

remedial measures determined by the Court, and may even have to pay the State’s

investigative costs. The latter was confirmed in Minister of Water Affairs and Forestry v

Stilfontein Coal Mining Co Ltd and Others 2006 5 SA 333 (W) where the court held, in a telling

statement that “To permit mining companies and their directors to flout environmental

obligations is contrary to the Constitution, the Mineral Petroleum Development Act and to

the National Environmental Management Act. Unless courts are prepared to assist the State

by providing suitable mechanisms for the enforcement of statutory obligations an impression

will be created that mining companies [and their directors] are free to exploit the mineral

resources of the country for profit over the lifetime of the mine, thereafter they may simply

walk away from their environmental obligations. This simply cannot be permitted in a

constitutional democracy which recognises the right of all of its citizens to be protected

from the effects of pollution and degradation.”

Under the “One Environmental System”, the Minister of Mineral Resources will issue

environmental authorisations and waste management licences in terms of the NEMA and

NEM:WA, respectively, for mining and related activities. The Minister of Environmental Affairs

will be the appeal authority for these authorisations. This is important, as the above

specifically gives rise to the question of the regulation of Mine Residue Stockpiles in terms of

the NEM:WA, which is categorised as a Schedule A waste in NEM:WA.

This is important, as the above specifically gives rise to the question of the regulation of

Residue Stockpiles in terms of the NEM:WA. The address the current view on this aspect as

part of this application, and to open up communication with the NCDENC as the regulatory


13-843 June 2015 Page 15

authority on this application, it is important to present the current views included as part of

this project and the proposed way forward.

In terms of the NEM:WA, waste is classified as “Any substance, material or object that is

unwanted, rejected, abandoned, discarded or disposed of by the holder of that substance,

material or object.”

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

The NEM:WA fundamentally reformed the law regulating waste management, and for the first

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

waste management hierarchy. The objects of the NEM:WA are to protect health, well-being

and the environment by providing reasonable measures for, inter alia, remediating land

where contamination presents, or may present, a significant risk of harm to health or the

environment. The objects of the NEM:WA are structured around the steps in the waste

management hierarchy, which is the overall approach that informs waste management in

South Africa. The waste management hierarchy consists of options for waste management

during the lifecycle of waste, arranged in descending order of priority; i.e. waste avoidance,

reduction, re-use, recycling, recovery, treatment, and safe disposal as a last resort.

NEMA, as previously mentioned, introduced a number of additional guiding principles into

South African environmental legislation, including the life-cycle approach to waste

management, producer responsibility, the precautionary principle and the polluter pays

principle (i.e. the sustainability principles as contained in Section 2 of NEMA). Section 5(2)

of the NEM:WA stipulates that the Act should be interpreted and guided in accordance with

these sustainability principles. The NEM:WA, furthermore, echoes the duty of care provision,

in terms of Section 28 of NEMA, by obliging holders of waste to take reasonable measures to

implement the waste management hierarchy. Section 16(1) of the NEM:WA provides that:

“A holder of waste must, within the holder’s power, take all reasonable measures to –

(a) avoid the generation of waste and where such generation cannot be avoided, to

minimise the toxicity and amounts of waste that are generated;

(b) reduce, re-use, recycle and recover waste;

(c) where waste must be disposed of, ensure that the waste is treated and disposed of

in an environmentally sound manner;

(d) manage the waste in such a manner that it does not endanger health or the

environment or cause a nuisance through noise, odour or visual impacts;

(e) prevent any employee or any person under his or her supervision from contravening

this Act; and


13-843 June 2015 Page 16

(f) prevent the waste from being used for an unauthorised purpose.”

When considering whether a “substance” is considered a “waste” or not, the definition of

the NEM:WA must be considered. The NEM:WA defines “waste” as:

“any substance, whether or not that substance can be reduced, re-used, recycled and

recovered;

(a) that is surplus, unwanted, rejected, discarded, abandoned or disposed of;

(b) which the generator has no further use of for the purposes of production;

(c) that must be treated or disposed of; or

(d) that is identified as a waste by the Minister by notice in the Gazette and includes

waste generated by the mining, medical or other sector.”

Furthermore, the following is not regarded as waste for the purposes of the NEM:WA:

A by-product as defined in the NEM:WA; and

Any portion of waste, once re-used, recycled and recovered, ceases to be waste.

While the NEM:WA creates a comprehensive legal framework for waste management, its

provisions will be meaningless without measures to monitor and, where necessary, enforce

compliance. Compliance monitoring is supported by a range of reporting provisions contained

in the NEM:WA. In addition to compliance reports for waste management licences and norms

and standards, the NEM:WA has provisions for annual performance reports on the

implementation of provincial and local Integrated Waste Management Plans. Industry Waste

Management Plans are subject to review at intervals to be determined by the authority that

mandated the plan. Furthermore, Environmental Management Inspectors and Waste

Management Officers can request a Waste Impact Report where they suspect a contravention

of the Act, licence conditions or exemption conditions.

Section 26(1) of the NEM:WA contains the main liability provision and states that:

“no person may-

a. dispose of waste, or knowingly or negligently cause or permit waste to be disposed

of, in or on any land, waterbody or at any facility unless the disposal of that waste

is authorised by law; or

b. dispose of waste in a manner that is likely to cause pollution of the environment or

harm to health and well-being”.

The penalty for non-compliance with Section 26(1) is a fine not exceeding R 1,000,000.00 or

to imprisonment for a period not exceeding 10 years, or to both such fine and such

imprisonment.


13-843 June 2015 Page 17

The NEM:WA provides for a licensing regime specific to waste management activities. It

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

Environment Conservation Act, 1989 (Act No. 73 of 1989) (hereinafter referred to as the

“ECA”). Transitional arrangements allow existing permits granted in terms of ECA to be

regarded as licences in terms of the NEM:WA until the Minister requires a licence application

as per the NEM:WA category of the waste management activity (i.e. category A or B). The

NEM:WA waste management categories determine the environmental assessment procedure

(which is the equivalent of the EIA regulations' requirements) required to obtain a licence.

Category A activities need a basic assessment as defined in the EIA regulations provided in

NEMA. A Basic Assessment (BA) is appropriate where the environmental impact of a particular

activity is well understood and limited in scope. Category B activities require a full

assessment report in terms of the EIA regulations. A full assessment is appropriate where

the potential scope and extent of environmental impacts are not well understood, or is likely

to be significant.

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

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

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

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

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

the framework of NEMA.

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

prevention and remediation of the effects of pollution. The NWA provides a wide duty of

care in that:

“(1) an owner of land, a person in control of land or a person who occupies or uses the land

on which-

a) Any activity or process is or was performed or undertaken; or

b) Any other situation exists, which causes, has caused or is likely to cause pollution of

a water resource must take all reasonable measures to prevent any such pollution

from occurring, continuing or recurring”.

The words “likely to cause pollution” broadens the scope of the duty, which enables an

activity, or situation that is land-based, to trigger the application of the duty. The

“reasonable measures” are not prescribed, but may include measures intended to “Cease,

modify or control any act or process causing the pollution; comply with any prescribed waste

standard or management practice; contain or prevent the movement of pollutants; eliminate


13-843 June 2015 Page 18

any source of pollution; remedy the effects of pollution; and remedy the effects of any

disturbance to the bed and banks of a watercourse”.

The NWA, furthermore, provides for water use authorisations which a mine will have to apply

for, before commencing with its primary activity of mining. Various conditions may be

attached to these licenses and a breach thereof will result in criminal and civil liability. The

conditions attached to water use authorisations will function alongside the additional

protective measures, duty of care and statutory liability provisions provided by the NWA and

other legislation to regulate a whole array of water issues.

The detrimental impact of mining on water resources is further regulated by the NWA in a

comprehensive set of regulations titled: “Regulations on the Use of Water for Mining and

Related Activities Aimed at the Protection of Water Resources”. In terms of these regulations

“No person in control of a mine or [mining] activity may place or dispose of any residue or

substance which causes or is likely to cause pollution of a water resource, in the workings

of any underground or opencast mine excavation, prospecting diggings, pit or any other

excavation”.

Regulations provide for a whole array of provisions which specifically aim to protect water

resources from mining. These provisions state that every person in control of a mine or

mining activity must take all reasonable measures to, inter alia: prevent water containing

waste or any substance which causes or is likely to cause pollution from entering any water

resource; design, modify, locate, construct and maintain all water systems including residue

deposits, to prevent the pollution of any water resource through the operation or use thereof;

cause effective measures to be taken to minimise the flow of any surface water or floodwater

into mine workings, opencast workings, other workings or subterranean caverns; prevent the

erosion or leaching of materials from any residue deposit or stockpile from any area; and

ensure that water used in any process at a mine or activity is recycled as far as practicable.

These provisions specifically relate to the protection of water resources and they clearly set

out further additional liabilities for mines as far as their water resource protection activities

are concerned.

According to NWA, water may not be used without prior authorisation from the leading

authority, in this case the Department of Water and Sanitation (DWS). Due to the

requirements of the NWA, an Integrated Water Use License Application (IWULA) and

Integrated Water and Waste Management Plan (IWWMP) needs to be compiled and submitted

to the DWS to ensure the legality of the water uses. GCS will be undertaking the development

of the required WULs as per the NWA.


13-843 June 2015 Page 19

1.6 Environmental Processes

1.6.1 Environmental Process Objectives

In order to mitigate potentially negative impacts and to identify any potential fatal flaws

which may render the project environmentally unacceptable, GCS has adopted an integrated,

step-by-step process to identify issues of concern and to thoroughly investigate these issues.

To ensure that the negative impacts are identified and mitigated in the early stages of the

project, and that the positive impacts are maximised, it will be necessary for the

environmental study to meet the following aims:

Follow the guideline process as outlined by the NEMA and the MPRDA;

Provide input in the feasibility phases to ensure that the most technically feasible,

and environmentally sound options are selected;

Ensure that impacts are identified early through investigations to minimize

environmental damage and maximise benefits;

Conduct thorough special investigations that will allow the project team to develop

an adequate understanding of the issues to be dealt with;

Compile an EIA that will identify, evaluate and address the potential impacts;

Provide ongoing environmental input into the project planning and development;

Compile an EMP that will limit the significance of the negative impacts and maximise

the positive aspects;

Ensure that all relevant Interested and Affected Parties (I&APs) are consulted and

involved throughout the project; and

Ensure that an open and transparent communication structure is in place during the

life of the mine.

Strong emphasis will be placed on the MPRDA, NEMA, and NWA processes to ensure that the

processes will be able to run concurrently, and will easily be comparable with no confusion

between the different processes.

The environmental process is being undertaken in accordance with the provisions of the

MPRDA, NEMA and NWA. The various environmental authorisation processes being followed

for this project are described in the sections which follow.

1.6.2 The MPRDA Amendment


13-843 June 2015 Page 20

The EMP Amendment process, required in terms of the Mineral and Petroleum Resources

Development Act, 2002 (Act No. 28 of 2002) (MPRDA), considers the project as a whole

including all activities related to the proposed Khumani Infrastructure Expansion Project. The

EIA/EMP developed in terms of the MPRDA will address all the environmental impacts and

proposed management measures associated with the proposed mining operation, as well as

provide background on the current environmental conditions on site. The activities will

however not influence the production output or Mining Works Programme (MWP) of the mine.

In terms of Section 39(1) of the MPRDA, every person who has applied for a mining right in

terms of Section 22 must conduct an EIA and submit an EMP within 180 days of the date on

which he or she is notified by the Regional Manager to do so. There also rests an obligation

on the applicant to notify and consult with interested and affected parties within 180 days

from the date of the notice. Khumani is required to conduct an environmental assessment

for all new activities in terms of the Khumani Infrastructure Expansion Project and submit a

Scoping Report and EIA/EMP to the DMR in the Northern Cape for authorisation.

1.6.3 The NEMA

Section 24(1) of NEMA requires that the potential consequences of or impacts on the

environment of listed activities must be considered, investigated, assessed and reported on

to the competent authority. Where EIAs have been identified as the instrument to be utilised

in achieving the aforementioned, an application for environmental authorisation needs to be

obtained. The identified activities are listed under Government Notice (GN) R544, R545,

R546 and R547 of the NEMA Regulations respectively.

The listed activities which are triggered by the proposed mine operation are contained in

Listing Notice 1 (GN R544) and Listing Notice 2 (GN R545). Activities contained in Listing

Notice 1 require a Basic Assessment (BA) process to be followed whilst activities in Listing

Notice 2 require a Scoping and Environmental Impact Report (S&EIR) process to be followed.

For the purposes of this application all items listed under Listing Notice 1 will be addressed

in the required EIA process applicable to Listing Notice 2 activities. The NCDENC is regarded

as the competent authority and as such a consolidated EIA report will be developed for

proposed application and submitted to the NCDENC for assessment and authorisation.

S&EIR processes entail a comprehensive EIA process which includes a scoping phase and an

EIA phase. In the scoping phase, issues and a plan of study for the EIA phase are identified

and an ESR is developed. The EIA phase assesses issues identified during the scoping phase

and includes an EMP. The EMP provides information on the proposed activity and the manner


13-843 June 2015 Page 21

in which potential impacts will be minimised or mitigated. This process is required for all

listed activities.

Table 1.2 provides a description of the S&EIR process followed in respect of the proposed

Khumani infrastructure updagrades. Please note the process was followed using NEMA

regulations as a guideline.

Table 1.2: Description of the S&EIR process in terms of GN R543 in GG 33306 of 18 June

2010 of NEMA.

REGULATION PROVISION PROGRESS DATE

Regulation 26 The Applicant or the Environmental

Assessment Practitioner (EAP) must

complete the application form for

environmental authorisation and

submit to the competent authority.

The EIA application form was

submitted to the NCDENC.

31 July 2014

Regulation

13(2)

The competent authority must

acknowledge receipt of the

application within 14 days of receipt

of the application.

The NCDENC acknowledged

receipt of the application and

granted permission to proceed

with the S&EIR.

31 July 2014

Regulation 27 After having submitted an

application, the EAP managing the

application must:

Conduct a public participation

process;

Give notice of the proposed

application to any organ of

state which has jurisdiction in

respect of any aspect of the

activity;

Open and maintain a register of

all interested and affected

parties;

Consider all comments and

representations received from

interested and affected parties

following the public

participation process;

Subject the application to

scoping;

Prepare a scoping report;

Give all registered interested

and affected parties an

opportunity to comment on the

scoping report; and

Submit at least five copies of

the scoping report to the

competent authority.

All I&APs and authorities on the

existing Khumani mine database

were contacted at the onset of

the NEMA process. During

consultation with I&APs, as well

as with the applicant, additional

parties were identified be

identified and were included

within the existing database.

Additional I&APs will be notified

by word of mouth by other parties

and will be included in the

database as necessary. Additional

parties who respond to the

advertisements and notifications

will also be included in the

database.

GCS has developed and will

maintain an electronic database

for the duration of the project

where stakeholder details are

captured and automatically

updated as and when information

is received from I&APs and/or

authorities.

Ongoing

Site notices were placed at the

following locations:

Entrance from N14 to

King Mine

King Mine Security Gate;

06 October

2014


13-843 June 2015 Page 22


Main Entrance to Load

Out Security Gate;and

Load Out Northern

Entrance Security Gate.

An advertisement regarding the

proposed project, including

background information, the

assessment process being

followed was placed in the DFA

newspaper.

17

September

2014

Background Information

Documents (BIDs) were sent to all

registered I&APs/stakeholders.

All I&APs were notified by way of

sms, fax, email or letter,

depending on their preferred

method of contact. The BID

included details of the proposed

project, the EIA process and the

requirements of the NEMA. The

BID also includes relevant contact

details and a

comment/registration sheet for

I&APs to complete. I&APs were

also invited to register and send

responses by fax, telephone or

email to GCS.

30

September

2014

The Draft ESR for Review was

made available on the GCS

website www.gcs-sa.biz for

review by authorities and I&APs

for a maximum 40 day period and

all registered I&APs were

informed of the report

availability. CD’s were provided

to I&APs on request. The Draft

ESR was also be submitted to

authorities for comment.

The Final ESR for Submission was

submitted via courier on 15

December 2014 and received by

the Department on 12 January

2015. This report was made

available via the GCS website to

all registered I&APs.

Amendment to the final ESR,

which included the expansion of

the Bruce Dump was submitted

and received by the department

on the 15th of May 2015. All

23 October

2014

15 December

2014

15 May 2015



13-843 June 2015 Page 23


Registered I&AP’s were notified

of the inclusion.

Regulation 29 The EAP managing an application

must submit 5 copies of the scoping

report to the competent authority.

Five copies of the Draft ESR were

made available to the NCDENC for

review and comment.

Five copies of the Final ESR were

made available to the NCDENC for

review and comment.

23 October

2014

15 December

2014

Regulation 30 The competent authority must,

within 30 days of receipt of a

scoping report, or receipt of the

required information, reports, or

comments or the amended scoping

report, consider it, and in writing:

Accept the report and advise

the EAP to proceed with the

tasks contemplated in the plan

of study for EIA;

Request the EAP to make such

amendments to the report as

the competent authority may

require; or

Reject the scoping report.

Received Feedback from the

NCDENC on the submitted ESR.

Received 4

February

2015

Regulation 31 If a competent authority accepts a

scoping report and advises the EAP

to proceed with the tasks

contemplated in the plan of study

for environmental impact

assessment, the EAP must proceed

with those tasks, including the

public participation process for EIA

and prepare an EIA report in respect

of the proposed activities.

Continue with EIA phase. Commenced

September

2015

Regulation

34(1)

The EAP managing an application

must submit the draft EIA report to

the competent authority.

Received Feedback from the

NCDENC on the submitted EIA.

October

2015

Regulation

34(2)

The competent authority must,

within 60 days of receipt of an EIA

report:

Accept the report; or

Reject the report.

Not applicable at this stage. N/A

Regulation

34(4)

An EIA report that is rejected in

terms of Regulation 34(2) may be

amended and resubmitted by the

EAP.

Not applicable at this stage. N/A

Table 1.3 indicates the potential listed activities which may be triggered by the Khumani

Infrastructure Upgrades.

Table 1.3: Listed activities in terms of NEMA 2010 Regulations.


13-843 June 2015 Page 24

ACTIVITY NO (S) (IN TERMS OF THE

RELEVANT OR NOTICE):AND DATE OF THE

RELEVANT NOTICE

LISTED ACTIVITY: DESCRIPTION OF PROJECT ACTIVITY

THAT TRIGGERS LISTED ACTIVITY

National Environmental Management Act, 1998 (Act No.107 of 1998) Environmental Impact Assessment Regulations 2010

GN R 544, 2 August 2010- Activity 11

The construction of: (i) Infrastructure or structures

covering 50 square metres or more, where such construction occurs within a watercourse or within 32 metres of a watercourse, measured from the edge of a watercourse, excluding where such construction will occur behind the development setback line.

Parsons: There are pans within the proposed footprint of the Low Grade Stockpile area (A) on the farm Parsons that will be affected. King: there is a non-perennial channel in the vicinity of the proposed new Low Grade Stockpile (H). Bruce There is a pan in the proposed Low Grade Stockpile expansion area.


The construction of a road, outside urban areas,

(i) with a reserve wider than 13,5 meters or,

(ii) where no reserve exists where the road is wider than 8 metres

New haul roads to be constructed on farms Parsons and King which will also include internal roads for construction and maintenance purposes.


The expansion of existing facilities for any process or activity where such expansion to will result in the need for a permit or license in terms of national or provincial legislation governing the release of emissions or pollution, excluding where the facility, process or activity is included in the list of waste management activities published in terms of section 19 of the National Environmental Management Waste Act 2008 (Act 59 of 2008).

The creation of the Low Grade Stockpile and infrastructure (A, B, E) on Parsons and the expansion of the King/Mokaning and Bruce Low Grade Overburden Stockpile (H) on King and Bruce respectively will require a License in terms of section 21(g) and 21 (c&i) of the NWA.


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

Parsons: Establishment of the Low Grade Stockpile with additional infrastructure (A, B, C, D, E, F, G) King: Establishment of the Overburden Dump (J).


13-843 June 2015 Page 25

ACTIVITY NO (S) (IN TERMS OF THE

RELEVANT OR NOTICE):AND DATE OF THE

RELEVANT NOTICE

LISTED ACTIVITY: DESCRIPTION OF PROJECT ACTIVITY

THAT TRIGGERS LISTED ACTIVITY

National Environmental Management Act, 1998 (Act No.107 of 1998) Environmental Impact Assessment Regulations 2010


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

(i) Linear development activities; or

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

The project will comprise the development of mining related surface infrastructure in areas on both farms Bruce, Parsons and King, where no previous mining activity took place.


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

(i) Linear development activities; or

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

The removal of indigenous trees on farms Bruce, Parsons and King, for the development of infrastructure and creation of stockpiles.

The main implication of the abovementioned amendments is that the thresholds of the

activities have been changed from being measured in terms of annual throughput capacity to

being measured in terms of daily throughput capacity. This in effect means an increase in

the thresholds. Only expansion of facilities on undeveloped land will require an

environmental authorisation.

Kindly note that GCS is mindful of the new legislative changes which came into force on

Monday, 8 December 2014. Accordingly, we direct the Department’s attention to the

transitional arrangements contained in Regulation 53(1) of the 2014 Environmental Impact

Assessment Regulations (GN R 982 in Government Gazette 38282 of 4 December 2014) which

states the following:


13-843 June 2015 Page 26

“(1) An application submitted in terms of the previous NEMA regulations which is

pending when these Regulations take effect, including pending applications for auxiliary

activities directly related to-

(a) Prospecting or exploration of a mineral or petroleum resource; or

(b) Extraction and primary processing of a mineral or petroleum resource,

Must despite these Regulations be dispensed with in terms of those previous NEMA

regulations as if those previous regulations were not repealed.

(2) If a situation arises where an activity or activities, identified under the previous

NEMA Notices, no longer requires environmental authorisation in terms of the current

activities and competent authorities identified in terms of Section 24(2) and 24D of the

National Environmental Management Act, 1998 (Act No. 107 of 1998) or in terms of the

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

a decision on an application under the previous NEMA regulations is still pending, the

competent authority will consider such application to be withdrawn.

(3) Where an application submitted in terms of the previous NEMA regulations, is

pending in relation to an activity of which a component of the same activity was not

identified under the previous NEMA notices, but is now identified in terms of Section

24(2) OF THE Act, the competent authority must dispense of such application in terms

of the previous NEMA regulations and may authorise the activity identified in terms of

Section 24(2) as if it was applied for, on condition that all impacts of the newly

identified activity and requirements of these Regulations have also been considered and

adequately addressed.”

In accordance with the abovementioned provision, the Environmental Authorisation Process

currently underway in terms of the NEMA will continue in terms of the previous NEMA

Regulations (2010).

1.6.4 The NEM:WA

In terms of the National Environmental Management Laws Amendment Act, 2014 (Act No. 25

of 2014) (NEMLA 3), Waste Management Licences (WMLs) were to be regulated by the Minister

of Mineral Resources for residue stockpiles and deposits relating to prospecting, mining,

exploration or production activities as from 3 September 2014 as part of the “One

Environmental System”. However NEMLA 3 and its associated regulations for the One

Environmental System will be implemented from 8 December 2014 in terms of a press

statement by the Department of Environmental Affairs in September 2014.


13-843 June 2015 Page 27

Under the “One Environmental System”, the Minister of Mineral Resources will issue

environmental authorisations and waste management licences in terms of the NEMA and

NEM:WA, respectively, for mining and related activities. The Minister of Environmental Affairs

will be the appeal authority for these authorisations. This is important, as the above

specifically gives rise to the question of the regulation of Mine Residue Stockpiles in terms of

the NEM:WA, which is categorised as a Schedule A waste in NEM:WA.

This is important, as the above specifically gives rise to the question of the regulation of

Residue Stockpiles in terms of the NEM:WA. The address the current view on this aspect as

part of this application, and to open up communication with the NCDENC as the regulatory

authority on this application, it is important to present the current views included as part of

this project and the proposed way forward.

In terms of the NEM:WA, waste is classified as “Any substance, material or object that is

unwanted, rejected, abandoned, discarded or disposed of by the holder of that substance,

material or object.”

In terms of Schedule 3, Waste Category A, a list of material considered to be hazardous is

presented. One of the activities listed in here, is that of Mine Residue Stockpiles. Residue

Stockpiles are defined in here as “any debris, discard, tailings, slimes, screening, slurry,

waste rock, foundry sand, mineral processing plant waste, ash or any other product derived

from or incidental to a mining operations which is stockpiled, stored or accumulated within

the mining area for potential re-use, or which is disposed of, by the holder of a mining right,

mining permit, or production right or an old order right, including historic mines and dumps

created before the implementation of this Act.” In addition to this, the definition of

Hazardous Waste is given as “any waste that contains organic, or inorganic elements or

compounds that may, owning to the inherent physical, chemical or toxicological

characteristic of that waste, have a detrimental impact on health and the environment and

includes hazardous substances, material or objects within business waste, residue deposits

and residue stockpiles as outlined below:…” (listed activity of residue waste then presented).

If residue stockpiles and deposits were not constructed with all of the required environmental

consents, including environmental authorisations or water use licences before 2 September

2014, a WML would be required. For a WML to be required, residue stockpiles and deposits

would need to constitute ’waste’. It would also be dependent on whether they fall within the

listed waste management activities that require WMLs, which is dependent on the nature and

size of the residue stockpiles and deposits - this is unless an entity ’lawfully conducted’ these

activities prior to 2 September 2014. Therefore, if residue stockpiles and deposits were not


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constructed with all of the required environmental consents, including environmental

authorisations or water use licenses before 2 September 2014, a WML would be required.

Based on the above:

1. The Parson Low Grade Stockpile, King/Mokaning ROM and Low Grade Stockpile were

approved in terms of NEMA, and also the NWA, making these lawful activities.

2. Khumani is not considering potential re-use, the material stockpiled, which forms

part of this application is now specifically earmarked for re-use, with the

infrastructure to undertake these activities included in this application.

3. Khumani is an iron ore operation; the beneficiation process is in the form of a wash

and screening operations. The process is considered as inert, with no potential of

hazardous impacts (as stipulated in this activity definition).

1.6.5 The NWA

The NWA stipulates that activities which have the potential to impact on a water resource

require that an Integrated Water Use License (IWUL) be issued by the DWS. In accordance

with the requirements of the NWA, an IWULA will be compiled for the proposed Upgrades and

update to the storm water management plan and submitted to the DWS to ensure the legality

of the identified water uses associated with the proposed operation.

It is anticipated that following water uses (in bold) in terms of Section 21 of the NWA will be

applied for at the Northern Cape Regional Office of the DWS:

a) Taking water from a water resource;

b) Storing water;

c) Impeding or diverting the flow of water in a watercourse;

d) Engaging in a stream flow reduction activity contemplated in section 36;

e) Engaging in a controlled activity identified as such in section 37(1) or declared under

section 38(1);

f) Discharging waste or water containing waste into a water resource through a pipe,

canal, sewer, sea outfall or other conduit;

g) Disposing of waste in a manner which may detrimentally impact on a water

resource;

h) Disposing in any manner of water which contains waste from, or which has been

heated in, any industrial or power generation process;

i) Altering the bed, banks, course or characteristics of a watercourse;

j) Removing, discharging or disposing of water found underground if it is necessary for

the efficient continuation of an activity or for the safety of people; and


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k) Using water for recreational purposes.

A pre-consultation meeting were held with the DWS on the 4th of February 2015 during which

time the relevant Section 21 water uses and way forward were discussed. The final Section

21 water uses that need to be applied for has been confirmed with the DWS prior to the

submission of the IWULA.

A Water Use License (WUL) may be issued for a maximum period of 40 years with a specified

review period. The WUL also prescribes a set of conditions to protect water resources, and

gauge the impact of the water use. These have to be strictly adhered to for as long as the

water use continues. This may extend beyond the life of mine and the applicant will be

responsible for impacts caused by the operation after decommissioning and closure.

Furthermore, Section 27 of the NWA specifies that the following factors, regarding water use

authorization, must be taken into consideration:

The efficient and beneficial use of water in the public interest;

The socio-economic impact of the decision whether or not to issue a license;

Alignment with the catchment management strategy;

The impact of the water use and possible resource directed measures; and

Investments made by the applicant in respect of the water use in question.

Section 27 considerations will be included in the IWULA. This will assist the applicant in

ensuring that the water uses applied for, are undertaken in a manner that does not negatively

impact on the public, water resources, or downstream water users or compromise any of the

country’s international obligations with regards to shared water resources.

1.7 Roles and Responsibilities in terms of the NEMA and MPRDA

This section sets out the roles and responsibilities of the Applicant, Environmental Assessment

Practitioner (EAP) and Interested and Affected Parties (I&APs).

1.7.1 The Applicant

An applicant is a person (including a juristic person) who has submitted an application for,

inter alia, environmental authorisation. For the purpose of this application, Assmang

Proprietary Limited’s Khumani Iron Ore Mine submitted an application for authorisation in


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terms of the NEMA on 31 July 2014, and in the same process also to conduct an amendment

of the approved EMP under MPRDA.

The contact details of the applicant are provided in Table 1.4.

Table 1.4: Name and address of Applicant representative.

ITEM COMPANY CONTACT DETAILS

Name of Applicant Assmang Proprietary Limited: Khumani Iron Ore Mine

Contact Person Mr Dirk Coetzee

Physical Address Khumani Iron Ore Mine, Kathu, Northern Cape Province

Postal Address Private Bag X503,Kathu, Northern Cape Province, 8446

Tel no. +27 (0) 53 723 8090

E-mail address [email protected]

The NEMA Regulations require the applicant to appoint an EAP who will comply with the

requisite statutory provisions and regulations on behalf of the Applicant. Further, the

Applicant must:

Provide the EAP with a detailed and precise statement of the purpose and need for

the proposed activities;

Take all necessary steps to verify whether the EAP complies with Sections 17(a) and

(b) of NEMA; and

Provide the EAP with access to all information regarding the application, whether or

not such information is favourable to the Applicant.

1.7.2 The Environmental Assessment Practitioner

In terms of Section 17 of the NEMA, the applicant has to appoint and EAP before applying for

an environmental authorisation of any activity listed in terms of GN 544 and 545. An EAP is

responsible for the planning, management and coordination of EIAs, Strategic Environmental

Assessments (SEAs), EMPs or any other appropriate environmental management instruments

introduced through regulations. The EAP must be independent, objective and have expertise

in conducting EIAs. Such expertise should include knowledge of all relevant legislation and

of any guidelines that have relevance to the proposed activity.

An EAP must perform the work relating to the application in an objective manner, even if it

results in views and findings that are not favourable to the applicant, and disclose to the

applicant and competent authority all material information in the possession of the EAP.

For this purpose the applicant has appointed GCS Water and Environment (Pty) Ltd (GCS) as

the EAP to undertake the necessary environmental assessments and to ensure that all


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legislative requirements are adhered to as part of the environmental authorisation processes.

GCS provides a professional, independent consulting service in the fields of water,

environmental, engineering and earth sciences. The GCS team consists of highly trained staff

that has extensive experience in the fields of geohydrology, hydrology, pedology, engineering

geology, engineering and environmental science.

GCS have considerable experience in Southern Africa and undertake investigations for

environmental assessments. The environmental scientists carry out all aspects of

environmental assessments and management programmes.

GCS was founded in 1987 and the broad GCS client base ranges from individuals, engineers,

municipalities and mines, to Independent States and Governments. GCS is an independent

practice wholly owned by the partners of the company.

GCS is a level 4 contributor to B-BBEE.

GCS is an independent environmental consulting firm and has undertaken the EIA/EMP Report

development. GCS is also responsible for undertaking the Public Participation Process (PPP)

pertaining to the proposed operation.

The contact details of the EAP are provided in Table 1.5.

Table 1.5: Name and Address of Environmental Assessment Practitioner.

ITEM COMPANY CONTACT DETAILS

Company Name GCS Water and Environment (Pty) Ltd

Company Representative Mrs Riana Panaino

Qualification B. Sc Honours Biodiversity and Conservation

Tel no. +27 (0)11 803 5726

Fax no: +27 (0)11 803 5745

E-mail address [email protected]

Postal address PO Box 2597, Rivonia, 2128

Table 1.6 provides a summary of the appointed EAPs working on the Khumani Infrastructure

expansion environmental authorisation process.

Table 1.6: Environmental Project Resources.

PROFESSIONAL STAFF TITLE COMPANY

Renee Janse van Rensburg Senior Project Manager GCS Water & Environment

Riana Panaino Environmental Consultant GCS Water & Environment

Tanja Bekker Project Advisor EnviroGistics


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1.7.3 Interested and Affected Parties

An Interested and Affected Party (I&AP) is defined as any person, group of persons or

organisation interested in or affected by an activity; and any organ of state that may have

jurisdiction over any aspect of the activity.

The NEMA Regulations distinguish between I&APs and registered I&APs. Registered I&APs

refer to an I&AP whose name is recorded in the register opened for the environmental

authorisation application. Accordingly, only registered I&APs will be notified of:

The availability of reports and other written submissions made (or to be made) to the

competent authority (I&APs are entitled to comment on these reports and

submissions); and

The outcome of the application, the reasons for the decision and that an appeal may

be lodged against a decision.

For the purpose of an application, the EAP must open and maintain a register which contains

the names, contact details and addresses of:

All persons who have submitted written comments or attended meetings with the

Applicant or EAP;

All persons who have requested the Applicant or EAP, in writing, to be entered on

the register; and

All organs of state which have jurisdiction in respect of the activity to which the

application relates.

1.8 Environmental Reporting

Based on the outcome of the Environmental Scoping Phase, an EIA and an EMP Report must

be submitted to the DMR and NCDENC for consideration and approval.

1.8.1 Environmental Impact Assessment

The EIA Report must determine the nature, extent, duration, probability and significance of

the environmental, social and cultural impacts of the project, the reasonable alternatives

and the required mitigation measures for each impact during the life of the mine. It is the

role of the relevant environmental authorities to make a decision on whether the project

should proceed or not, based on the information provided in the EIA. The EAP does, as is

required of them, make a recommendation on whether the project should proceed or not,


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based on the findings of specialist assessments, the needs and desireability of the project

and on the impact assessment findings.

Regulation 31(2) of Government Notice R543 of the NEMA Regulations stipulates that an EIA

Report must contain all necessary information to enable the competent authority to consider

the application and to reach a decision. The EIA Report must contain, inter alia, the

following:

A description and comparative assessment of all alternatives identified;

A description of all environmental issues identified as well as the significance of each

issue and an indication if the extent to which the issue could be addressed by the

adoption of mitigating measures;

An Environmental Impact Statement; and

An Environmental Management Programme.

Furthermore, the criteria which the competent authority will apply, when considering

applications in terms of the provisions of NEMA, is enunciated in Regulation 8 of Government

Notice R543 of the Regulations. The latter regulation states that consideration must be had

for Section 24O, Section 24(4), as well as the need and desirability of the activity. The

activities identified in the provisions of NEMA and the Regulations thereto pertain to activities

which may have a detrimental impact on the environment.

The criteria to be taken into account by the competent authority when considering

applications as set out in Section 24O and 24(4) of NEMA includes, inter alia, the following

relevant factors:

Any pollution, environmental impacts or environmental degradation likely to be

caused if the application is approved or refused;

Measures taken to protect the environment from harm as a result of the activity

which is the subject of the application;

Measures taken to prevent, control, abate or mitigate any pollution, substantially

detrimental environmental impacts or environmental degradation;

The ability of the applicant to implement mitigation measures and to comply with

any conditions subject to which the application may be granted;

Where appropriate, any feasible and reasonable alternatives to the activity which is

the subject of the application and any feasible and reasonable modifications or

changes to the activity that may minimise harm to the environment; and

Any comments received from organs of state that have jurisdiction over any aspect

of the activity which is the subject of the application.


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1.8.2 Environmental Management Programme

Each specialist was required to identify means of avoiding, mitigating and/or managing the

negative impacts in his/her particular aspect of the investigation. The recommended

management strategies are synthesised in this report by GCS to formulate the EMP for the

proposed listed activities and the operation as a whole. Management strategies are based on

the recommendations by specialists in their specific field of study and on best practise

guidelines where applicable. The management measures will be incorporated into the mine

systems to avoid, or appropriately manage impacts from the outset.

A draft EMP must include details of the person who prepared the EMP and the expertise of

that person to prepare an EMP. The draft EMP must, furthermore, include information on

any proposed management or mitigation measures that will be taken to address the

environmental impacts that have been identified, including environmental impacts or

objectives in respect of –

Planning and design:

o Pre-construction and construction activities;

o Operation or undertaking of the activity;

o Rehabilitation of the environment; and

o Closure, where relevant.

A detailed description of the aspects of the activity that are covered by the draft

EMP;

An identification of the persons who will be responsible for the implementation of

the mitigating measures;

Where appropriate, time periods within which the measures contemplated in the

draft EMP must be implemented; and

Proposed mechanisms for monitoring compliance with the environmental

management plan and reporting thereon.

The EIA ensures that the needs of the environment (biophysical and socio-economic) are

identified. The EMP in turn provides a tool for meeting the objective to reduce or avoid

negative environmental impacts associated with a project within a certain environment by

providing detailed mitigation measures and management commitments. All of these sections

will become legally binding on the approval of this report.

1.8.3 Reporting Structure (EIA/EMP)


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The EIA/EMP Report has been compiled to identify the impacts associated with the mining

activities and to determine the management measures that need to be implemented.

Chapter 1: Introduction and Background

This chapter provides a description of the location and the land ownership of the mine, as

well as the purpose, approach and methodology followed for the completion of this project.

It also includes a review of applicable legislation reviewed during the compilation of this

report.

Chapter 2: Detailed Project Description

This chapter provides a description of the proposed mining operation, mining method,

required services, access routes, transport routes and surface infrastructure. It also includes

a detailed section on the proposed mine development.

Chapter 3: Project Alternatives

This chapter provides a description of the project alternatives considered and a motivation

for why the preferred alternative was selected.

Chapter 4: Detailed Environmental Description

This chapter provides a description of the baseline biophysical and socio-economic conditions

of the project area prior to commencement of the proposed project. The information in this

chapter has been obtained from the specialist studies undertaken as well as various desktop

sources.

Chapter 5: Public Participation Process

This chapter details the process undertaken for stakeholder engagement and provides a

discussion on the issues raised and how these have been addressed.

Chapter 6: Environmental Management Goals and Objectives

This chapter outlines the environmental management goals and objectives for the proposed

operation.

Chapter 7: Identification of Impacts and Concerns with Management Measures and Action

Plans

This chapter assesses and rates the potential impacts on the environment, prior to the

consideration of mitigation measures, as well as the potential impacts after the

implementation of the proposed mitigation measures. It furthermore provides management

measures per impact identified and details specifica actions plans that are required.


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Chapter 8: Monitoring and Audit Management Programme

This chapter outlines the monitoring and auditing programmes which have been

recommended by the relevant specialists. It includes objectives of each proposed monitoring

programme, the location of monitoring points, the procedures to be followed when

undertaking monitoring; the frequency of monitoring required; criteria to assess

environmental performance, as well as the recommendations for internal and external

(independent) auditing to be undertaken.

Chapter 9: Environmental Awareness Plan and Environmental Emergency Response Plan

This chapter sets out procedures to be followed during and after various types of incidents

and accidents. It also sets out the procedure for inducting employees and informing all mine

employees and contractors of the various risks which may results from the various activities

on site and all required management and mitigation measures.

Chapter 10: Financial Provision

The chapter provides the financial provision required for the project.

Chapter 11: Environmental Rehabilitation Programme

This chapter outlines the environmental rehabilitation to be undertaken following

environmental disturbances caused by the proposed activities associated with the proposed

mine.

Chapter 12: Information Gaps and Further Assessments Required

This chapter outlines the assumptions made during the specialist studies and environmental

impact assessment, the adequacy of underlying assumptions, the uncertainties in the

information provided, as well as recommendations to improve the accuracy of the

information used to compile this report and the relevant appendices. It also outlines further

assessments that may be required.

Chapter 13: List of Specialist Studies Undertaken

List of specialist reports which are appended to this document.

Chapter 14: Motivation for the Project

This chapter provides motivation for the commencement of the proposed project.

Chapter 15: Environmental Impact Statement


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The chapter details whether the project should or should not be granted approval by the

competent authority in the opinion of the EAP.

Chapter 16: Conclusion

The conclusion provides a brief discussion on the findings in the report.

Chapter 17: Undertaking

This chapter provides an undertaken to be signed by the applicant.

Chapter 18: References

The conclusion a list of references to studies used in this report.


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2 DETAILED PROJECT DESCRIPTION

This section of the report relates to Section 31 (2) of the GNR543 published in Government

Gazette No.33306 of 18 June 2010, under Section 24(5) of the NEMA.

REGULATION 31 (2)

2 b) Detailed description of the proposed activity

2 f) A description of the need and the desirability of the proposed activity

2.1 Existing Infrastructure

The following infrastructure has been approved through various application processes under

NWA, NEMA and MPRDA:





Crushers;



Paste Disposal Pacility;









Diesel storage; and

Borrow pits.

A detailed description of the existing infrastructure is provided in Table 2.1.


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Table 2.1 Existing infrastructure at Khumani Iron Ore Mine

INFRASTRUCTURE DESCRIPTION

Roads

The N14 National Road

Existing N14 National Road:

The N14 national road traverses the Khumani property between the farm Bruce and King in a North / South direction.

The Secondary road (R325)

Existing Secondary Road (R325):

A Secondary road (R325) to the town Dingleton runs through to the farm Parson in a north-south direction.

Access Roads Approved Access Roads:

Access to the plant and main administrative buildings is from the existing R325 Dingleton road. Roads to the administrative buildings are surfaced.

Access to the King/Mokaning operations is directly from the N14 road.

Access to the Bruce operations is from an existing road turning off from the N14.

Treated roads serve the plant area.

Treated access roads have been established for access to the Bruce and King opencast operations.

Haul Roads Approved Haul Roads:

Haul roads serve as links between the various mine pits, the two ore crushing facilities (at Bruce and King respectively), as well as the topsoil storage areas and discard dumps.

Overburden is transported via trucks on treated roads to the crushers, which are situated in close proximity to the opencast operations.

ROM is transported to the crushers via haul roads from where it is loaded onto conveyors.

Various haul roads have been / will be constructed to provide access from one opencast working area to the other.

Two categories of haul roads:

Category 1 has a width of 38.0m, and serves as main arterials between pits and crushing facilities.

Category 2 haul roads have a width of 31.0m without a central berm, and function as links from pits to Category 1 haul roads.

Other Roads Approved Other Roads:

Service roads have been constructed connecting the plant area to the Bruce and King / Mokaning opencast operations.

The service road from the plant to the Bruce opencast operations runs parallel to the conveyors in a north-easterly direction.

The service road from the plant area to the King / Mokaning operations utilizes the same road as the Bruce opencast operations for the first 1.5km, after which it crosses the N14 national road under a bridge in an easterly direction parallel to the conveyors connecting the King / Mokaning opencast operations with the plant.


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A surface road has been constructed between the Bruce and King / Mokaning opencast operation, to serve as access between the two mining operations. This road is known as the A1 highway. The road runs on the eastern boundary of the King farm in an approximate northerly direction. The road crosses the N14 national road under a bridge. Table ‘blocks to be on 1 page – don’t split as per this block

Conveyors

Bruce Conveyor Approved Conveyor at Bruce:

This single length conveyor PS 15/CV60 is 6,5km long. From the stockpile at Bruce, where the conveyor is loaded, it passes under a Transnet railway line (OREX line) and public road (N14) to surface on the south side of these.

The conveyor further crosses a bridge (400m wide) across the Gamagara, travelling outside of the 1:100 floodline. The fourth crossing is under the Transnet Hotazel/PE line. Before arriving at the load off point at Parson, the conveyor travels over two small flood plains where it is suspended on culverts, and under the Khumani export siding.

King Conveyors Approved Conveyor at King:

This conveyor route is made up of two conveyors. The first leg, PS25/CV60, which is 1km long, travels west from the stockpile where it is loaded. After 400m, the conveyor passes over the Mine Access road and Hotazel/PE Transnet railway line.

The conveyor further passes under the N14 highway to arrive at a transfer tower. The ore is then transferred to the second conveyor PS25/CV70 which is ~1,5km long. The conveyor passes under the export siding at the same point as the Bruce conveyor.

Railway Lines and Associated Infrastructure

The OREX Railway Line

Existing OREX Railway Line:

The OREX Railway Line is an existing railway line between Kumba Iron Ore Mine and the Saldanha Port (export market) which runs parallel to the R325.

The Port Elizabeth / Hotazel Railway line

Existing Port Elizabeth / Hotazel Railway Line:

The Port Elizabeth / Hotazel Railway line (local markets) traverses the farms Mokaning and King where after it runs west of the farm Bruce.

Rapid Load-Out Facilities

Approved Rapid Load-Out Facility:

The layout of the siding is of a balloon shape with double track arrangement comprising two (2) balloons. The siding is electrified at 50kV in common with the Transnet Main Line (OREX Line), and the take-off from the Transnet line is fully signalled and controlled from Saldanha.

The siding line initiates from the OREX line and splits to form two balloons (loop structures) in order to load the required product on the train wagons for export. The railway siding has been established to accommodate 342 wagons plus 6 locomotives. Wagons capable of transporting 100 tonnes of product are used.

The layout basically allows for a 342 wagon train to enter the siding, one at a time, and proceed on to the balloon layout in an anti-clockwise direction. The train will proceed to one of the load-out stations. Uncoupling will take place and the rear part of the train with two (2) locomotives now leading will proceed to the load-out station. Loading will commence after the train has entered the load-out and the first


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wagon in each rake has been aligned and declared ready for loading. Three (3) rakes of 114 wagons each are loaded separately, connected and dispatched to the OREX line. Movement of rakes on the balloons is currently undertaken by diesel locomotives.

The following design criteria has been adopted: (track standards as per Transnet, i.e. 30 ton axle loads, 60kg/m rails)

30t axle loads

50kV ac overhead electrification

Multi aspect colour light signalling

Maximum train length 342 wagons excluding locomotives.

Port Elizabeth / Hotazel Railway Line

Diversion

Approved Port Elizabeth / Hotazel Railway Line Diversion:

The railway line linking Hotazel to Port Elizabeth passes through an area that has been earmarked for open cast pits on King. In order to mine these open cast pits, the railway line was diverted to the west.

Local Railway Line Siding

Approved Local Railway Line Siding:

There are requirements for iron ore on the local market and financial feasibility studies carried out by Assmang indicated that it would be advantageous to sell material on the local market. A siding linked to the Hotazel – Port Elizabeth line has been constructed.

The local siding will be a single track railway tying into with the Hotazel-Port Elizabeth railway line south-east of the point at which the Hotazel-Port Elizabeth line crosses the Sishen-Saldanha Line. The local siding then crosses the following existing infrastructure:

1. A Rail-over-Road bridge over the Dingleton Provincial road.

2. The 100 year flood line of the Gamagara River where drainage structures are be provided.

3. The 132kV Eskom power line - this line has been raised to accommodate the siding.

4. The three Assmang transmission lines - these lines have been raised to accommodate the siding.

5. The Bruce overland conveyor - a culvert has been placed over the conveyor.

6. The Sishen Saldanha (OREX) export railway line with a Rail-over-Rail bridge.

7. The DWA pipeline running parallel to the Dingleton provincial road - this has been protected with a culvert incorporated in the

bridge design.

The local siding joins up with the second railway balloon running outside of the first balloon.

Power Lines

Eskom Power Lines Existing Eskom Power Lines:

Existing Eskom Power lines (132 kV) from the Sishen traction station are present to the north of the farm Parson and transect the farm Bruce. Another line traverses the farms Mokaning and King parallel to the Port Elizabeth / Hotazel railway line.


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Three New Power Lines (132kV)

Approved New Power Lines:

Three power lines (132kV) have been taken from an existing Eskom Substation near Sishen Mine. The power lines are taken to an Eskom yard, situated at the plant area on the farm Parson. From the Eskom yard, two 22 kV lines are taken to the Bruce opencast operations and two 22kV lines are taken to the King / Mokaning opencast operations. The balloons can be electrified at 50kV a.c., in common with the Transnet OREX Line, and the take-off from the Transnet line is fully signalled and controlled from Saldanha. Power supply for traction on the siding is from the Transnet system.

The structure-series Eskom used for pylons is the "Steel mono pole Raptor Friendly" series. The intermediate suspension structure can be self-supporting or guyed structures depending on the landowner and/or environmental preferences.

Additional Power Supply

Approved Additional Power Supply:

The electricity shortage in this country has precipitated the need for the creation of additional power supplies on site. The mine intends to implement the use of additional diesel generators for this purpose. An additional 1.25MVA generator will be placed on Parsons and an additional 2 800kVA of generatored power has been placed at King, all of which are located within the existing plant areas on site (Bruce, Parson and King). These generators are located at the following coordinates:

King Genset – X = +81,417.940, Y = +49,365.570

Parsons Genset – X = +83,253.980, Y = +52,677.310

Fuel and Lubricant Storage

Temporary Fuel Storage

Approved Temporary Fuel Storage:

The temporary fuel storage facility consists of two (2) above ground temporary diesel storage facilities, each with a capacity of 61 m3. Each tank is double bunded (so-called “Transtanks”) and have been equipped with drip free nozzles. The structures have been established on concrete slabs with humps on all sides. A sloped, fully bunded area has been located between the two tanks in order to enable the collection and management of potential spillages from the tanks.

Additional Diesel and Lubricant

Storage

Approved Additional Diesel and Lubricant Storage

The operation of the diesel generators and the additional activities on site require the storage of additional fuel and oil. The mine has a storage capacity of 21 days. This translates to an additional 1312m3 of diesel and 276m3 lubricants being stored on site at any time.

All fuel is stored above-ground within designated and appropriately constructed hazardous material storage areas.

Solid Waste Management Facilities

Industrial and Domestic Waste Disposal Sites

Approved Industrial and Waste Deposal Sites:

Industrial waste is limited to oil, diesel and grease. This waste is sold in bulk back to the manufacturers and suppliers. Unwanted waste is disposed of by a contractor at an approved industrial waste site.


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Three central areas have been identified in which domestic waste is stored for collection by the Gamagara Municipality. The Gamagara Municipality disposes of the domestic waste at the local municipal waste disposal facility in the Kathu area. ditto

Chemical Storage Approved Chemical Storage:

The mine uses several petroleum products on the mine. These can be separated into two types of products, being bulk storage products and packaged products and will be stored as follows:

Bulk storage comprises above ground tanks in the vicinity of the workshops located at the Parsons Plant and at the workshop

areas on Bruce and King. The two (2) opencast operations and consist of diesel, petrol, lubrication oils and bitumen (bunker oil)

type products. The delivery area and storage areas are lined with a concrete sealed floor and are bunded to contain any spillage

or leakage and prevent contamination of the underlying earth. Sumps have been provided to allow contaminated storm water

and spillage to be pumped out and disposed of by contractor.

Packaged products are stored in areas lined with a concrete floor to prevent contamination of the underlying soils due to

spillages. As the quantities of these products are small and the area roofed thus preventing rainwater dispersal, the area is not

bunded. Spillages are treated with an absorbent type material and then disposed of as contaminated waste.

Contaminated Waste Approved Contaminated Waste Storage:

Contaminated waste such as oily rags, oil filters etc. are deposited in sealed drums at designated areas in the vicinity of the workshops at the Beneficiation Plant and the two Opencast operations. These drums are removed from, for disposal in an approved manner.

Tyres Approved Tyre Waste Storage:

Old tyres are removed from site by a contracted tyre company for re-cycling or disposal in an approved manner.

Lubrication Oils Approved Lubrication Oil Waste Storage:

Used lubrication oils are removed from site by the fuel and lubrication contractor, for re-cycling and re-use. This occurs in bulk from tanks designed for this purpose. The area surrounding the tanks containing the waste oil and collection point are bunded.

Office and Domestic Waste

Approved Office and Domestic Waste:

Office and domestic waste is collected and disposed of at the mine’s waste site. Three collection points have been provided by the mine, one at the farm Parson, and one at each of the opencast operations.

Domestic Waste Site on the farm Parson

Approved Domestic Waste site in terms of the NEMA – on the Farm Parson:

The waste disposal site is located on the remainder of the farm Parsons 564 RD, near Kathu in the Northern Cape Province, within the approved mining area.


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Uncontaminated rubble is collected and transported by trucks via the existing road network at the mine and is transported to the waste disposal site. The waste is collected on a weekly basis. Offloading and compaction takes about 5-10 minutes, which implies that the waste is exposed to the atmosphere within an enclosed building for only a very short period of time during normal operational conditions. ditto

Temporary Hazardous Waste Disposal Facility

Approved Temporary Hazardous Waste Disposal Facility in terms of the NEMA:

The facility consists of an area where all hazardous waste can temporarily be stored prior to removal and disposal at a licensed hazardous waste disposal site. The proposed temporary storage facility is located adjacent to the proposed general waste disposal site.

Topsoil Stockpiles

Topsoil Stockpiles Approved Topsoil Stockpiles:

Due to the shallow soil cover at Khumani, all topsoil and subsoil has been / will be stripped (minimum of 0.25m or until hard rock is reached) from the:

Opencast pits.

Overburden and low-grade ROM stockpiles.

Overburden dump.

Paste disposal facility.

Parsons plant.

Discard stockpile.

Export stockpile.

Haul roads.

Seven topsoil stockpiles have been created (Total area: 106.110ha, height: ranges from 1.5m to 5m volume: 4,378,000m3). An eighth area is reserved for topsoil north of the rapid load out facility on Parsons.

Stockpiling of topsoil

The height of the topsoil stockpiles range between 1.5m and 5m. All topsoil stockpiles higher than 1.5m will require erosion control measures (i.e. terraces).

Overburden and low-grade ROM Stockpiles

Overburden and Low-grade ROM

Stockpiles

Approved Overburden and Low-grade ROM Stockpiles:

Three overburden stockpiles (three types) have been established on the Khumani property:

The overburden and waste rock, with an iron content of less than 50 percent and high in impurities (i.e. Al2O3 and K2O) will be

stockpiled on overburden dumps situated at the Paste Disposal Facility.

The waste rock and overburden from the KM_NTH opencast pit will be stockpiled as material for the Paste Disposal Facility walls.


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Material with an approximated 50 percent iron content and high Al2O3 and K2O will be stockpiled on the overburden and low

grade ROM stockpiles situated at the King / Mokaning and Bruce opencast workings. These stockpiles will be utilized once the

mine reaches the end of life should it be proven economically feasible to process and sell the product. The following is

anticipated:

o Currently, it is planned that 1.3 percent (1.6 million tons) of the Bruce overburden and low-grade ROM stockpiles will be

reworked. The remainder of the stockpile will remain as a rehabilitated overburden dump upon decommissioning.

o Currently, it is planned that 4.9 percent (19.4 million tons) of the King / Mokaning overburden and low-grade ROM

stockpiles will be reworked. The remainder of the stockpile will remain as a rehabilitated overburden dump upon

decommissioning.

Paste Disposal Facility

Paste Disposal Facility

Approved Paste Disposal Facility:

All residue derived from the Parsons Plant is thickened and disposed of at the approved paste disposal facility.

Khumani has developed a paste disposal facility to ensure that no significant environmental impacts occur.

The area of the paste disposal facility is 168.4854ha.

Water derived during the thickening process is returned to the Parsons Plant to be reused.

The paste disposal facility has been constructed by means of sound engineering and environmental principles.

Borrow Pits

Borrow Pits Approved Borrow Pits:

There are large volumes of borrow material available for use as bulk and engineered fill materials as well as road and sub ballast layer works. The hauling distances are expected to vary between 2km and 6km depending on the location of the borrow pit and the place where the material is needed.

Materials were tested to determine the suitability for use: road pavement layers, upper and lower sub-ballast layers, gravel wearing coarse, semi permeable material for the seepage cut-off and construction materials for paste disposal facility starter walls and storm water retention dams, and materials for engineered fills.

The engineering properties of the materials were evaluated in terms of the Technical Recommendations for Highways: Standards for Road Construction Materials 1980, (TRH14).

Mineral Processing

Mineral Processing The iron ore processing facility has been designed to process run-of-mine ores from the Bruce and Kingopencast pits. The first phase (phase 1) allows for 8 million dry metric tons product per annum, with a second phase (phase 2), ramping up to an approved 16 million dry metric tons product per annum.


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Bruce and King mining areas are each equipped with processing units, consisting of a primary gyratory crusher, scalping screen and secondary cone crusher. Run-of-mine (ROM) ore is reduced from a top size of one meter, to a crushed plant feed of less than 80mm.

Following the primary and secondary crushing operations the crushed ore is conveyed to the processing plant area, which is situated remotely from the mining areas, on the farm Parson.

On-grade and off-grade crushed ore is stockpiled separately with dedicated stackers, and reclaimed to be fed separately to the dedicated on grade and off grade processing plants. On grade ore requires only screening, while off grade ore requires further beneficiation, to conform to the market requirements.

On-grade ore requiring no beneficiation i.e. ore conforming to the required chemical specifications is washed, crushed to -32mm in closed circuit, and sized into three market related products:

Lumpy export product

Medium Sized product for export and local markets

Fines export product

Off-grade ore (i.e. ore not conforming to the required chemical specifications) is washed, crushed to -32mm in closed circuit and screened into a coarse fraction and a fine fraction, prior to the beneficiation processes.

Beneficiation is achieved by utilising JIG technology. JIGs separate the ore according to the specific density of the particles. The separating units operate in such a way that particles within the off-grade ore with densities generally less than 4.9 will be rejected as discards, while particles with a specific density greater than 4.9, will be recovered as a product. The products from the beneficiation processes are screened into the three market related sizes as mentioned above.

Reagents are not utilised in any of the beneficiation processes. A flocculating agent is required to assist in clarifying process water in the water reticulation circuit. This is achieved by utilising a conventional thickener. The clarified water is reticulated in the processing plants.

A significant amount of water is recycled in the processing plant, to reduce the magnitude of the clarifying requirement.

Thickened pulp from the thickener units is pumped to a secondary thickener, situated on farm King, to recover the remaining water from the thickened pulp. The secondary thickener produces a “paste”, which is deposited onto a “paste deposition facility”, designed specifically for this purpose.

Mine Offices Approved Mine Offices:

Mine offices have been established at the Bruce and King / Mokaning opencast areas for managers, engineers and administration staff.

The main administrative buildings have been situated at the plant (on Parson) and houses managers, engineers and administrative staff.

A separate engineering block has been established at the plant, which houses engineers, technical, and administration staff employed in the operation of the process plant.

A separate export office has been established at the load out facility, which is equipped with tearoom and ablution facilities.

Laboratory Approved Laboratory:


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A laboratory has been established at the plant, which is utilized for the testing and certification of the product being processed and exported from the mine.

Change House Approved Change House:

Staff facilities for washing, ablutions and the safe keeping of personal belongings have been established at the Bruce and King / Mokaning opencast areas as well as at the Plant. (

A laundry facility has been established at the King Mine to provide a washing service to Bruce, King and Parson for the cleaning of overalls and other clothing issued to staff.

Sewage plants have been established at the opencast and plant areas, to treat the sewage within the mine area.

Clinic / Training Centre

Approved Clinic / Training Centre:

A medical centre and a training centre has been established at the Parsons Plant.

Security Building Approved Security Building:

Security buildings have been established at the Bruce and King opencast area, as well as at the Plant area.

Plant Control Centre Approved Plant Control Centre:

A plant control centre has been established on the farm Parson for operators to monitor and control the process plant. The centre is equipped with offices, electronics, workshop, tearoom and ablutions for staff associated with the centre.

A Control Centre for the operation of the load out and discard areas has been established on the farm Parson.

Workshops / Stores / Substations

Approved Workshop, Stores and Substations:

The following infrastructure has been established:

Garage for the servicing and repair of mine vehicles at the Bruce and King / Mokaning opencast areas;

Stores on the Bruce and King / Mokaning opencast areas, as well as the plant, for the daily requirements of the mine (i.e.

spares).

Workshops on the Bruce and King / Mokaning opencast areas, as well as the plant, for the maintenance and repair of equipment

used on the mine (i.e. crusher screens and conveyors etc.).

Substations to house electrical equipment have been established at the Plant and the opencast operations.

Sumps equipped with a submersible pumps and oils traps have established at the workshops where lubricants and chemicals are

stored.

Vehicle cleaning facilities, linked to oil/water separator have been established.

Mess Facility Approved Mess Facility:

A mess area for train drivers and Transnet staff associated with the rapid load out facility has been provided at the export facility.


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Weighbridge Approved Weighbridge:

A weighbridge has been established at the Plant area for means of verification regarding weight of loaded and unloaded vehicles etc.

Explosives Magazine Approved Explosives Magazine:

The explosives magazine has been built to Sasol Nitro design with the finished structures having been approved by Sasol Nitro.

An exclusion zone of 800m radius within which there will be no buildings, other structures or public access is maintained.

Housing and Recreation

Housing and Recreation

Approved Housing and Recreation:

Assmang is not directly involved in the provision of housing. Housing is included as an element within the remuneration package to allow the employees to provide their own housing. By undertaking this view, Assmang envisages their employees becoming self-sustaining.

No permanent housing has been erected for employees on the site. The existing infrastructure and residential areas in and around Kathu, Postmasburg and Olifantshoek are utilised.

Transport

Transportation of Ore on site

Approved Transportation Of Ore on Site:

Haul trucks transport the blasted product to the crushers. Following the primary and secondary crushing operations, the crushed ore is conveyed to and is stacked in the ROM Yard at Parsons. Re-claimers are used to load the ore onto belt conveyors to transport the ore to the processing plant on the farm Parson.

From the plant the final product is transported via conveyor to the product stockpiles, from where it is loaded into the rapid load out facilities.

Transport of Ore off-site

Approved Transportation of Ore Off-site:

The final product is transported from the rapid loud-out facilities, via the OREX railline to Saldanha (for export) and the Port Elizabeth / Hotazel line (for local markets).

Water Pollution and Storm Water Management Facilities

Water Pollution and Storm Water Management

Facilities - Legalities

Storm water management infrastructure at Khumani does and will comply with the requirements of Government Notice Number 704, published in terms of the National Water Act, 1998 (Act 26 of 1998).

Government Notice No. 704 requires the following:

All clean water systems must be designed and operated in such a manner that they are at all times capable of handling the 1:50

year flood event on top of their mean operation level without spilling;

Any water arising from an area, which causes, has caused or is likely to cause pollution of a water resource, including polluted

storm water, must be contained within a dirty water system. In order to reduce the volume of polluted water, contaminated


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areas should be minimised. While clean water should be diverted to natural watercourses, polluted water should be re-used

wherever possible, thereby reducing the use of clean water;

Design, construct, maintain and operate any dam or tailings dam (in the Khumani situation, a paste disposal facility) that forms

part of a dirty water system to have a minimum freeboard of 0.8 m above full supply level.

The following criteria have therefore been assumed for design purposes at Khumani:

1:50 year, 24hr flood event.

Average precipitation in the annual wettest month.

Average operations water pumped to the Paste Disposal Facility.

0.8 m freeboard (incl. freeboard for wave action) on the Paste Disposal Facility.

Sewage Treatment Plants

Approved Sewage Treatment Plants:

During construction, chemical toilets and mobile ablution blocks will be provided for the construction workers. These toilets will be cleaned as and when required. The waste material will be taken by a contractor to a suitable waste water treatment facility.

During the operational phase the three main areas of operation, i.e.the Parsons Plant, Bruce opencast area and the King / Mokaning? opencast areas, will be supplied with sewage treatment plants designed to treat 120 to 140l of sewage per person per day. The rapid load-out facilities and the explosives magazine are equipped with smaller treatment facilities.

At each site, underground piping carries the sewage to a central collection tank capable of buffering the loading from the sewage plant. This tank also acts as a combined settling tank and aerobatic digester.

A secondary aerobic process comprising of a Bio Filter RBC (rotating biological concentrator), fixed film reactor unit, followed by a humus settlement tank and disinfection tank completes the process.

The discharges, following chlorination, from the sewage plants are:

Parsons Plant (2,33m3 / hr) – to the 5000m3 process water dam, forming part of the water employed in the plant process.

Rapid Load-Out Facilities (0.05m3 / hr) – to the storm water dam where the returning water is pumped to the process water dam

as described above.

Explosives magazine (0.02m3 / hr) – to the storm water dam where the water is allowed to evaporate.

Bruce opencast operations (1.33m3 / hr) – to the 300m3 mine water tank where the water will be used for mining activities.

King / Mokaning? opencast operation (1.2.1m3 / hr) – to the 300m3 mine water tank where the water will be used for mining

activities.

Once a day, the filter elements are washed using clean water and once a week the units moving parts are inspected and greased.

The settled sludge is emptied once a year or as necessary using an outside contractor. It is part of the contract for the contractor to safely dispose of the solid waste off-site.


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Additional Sewerage Works

Approved Additional Sewerage Works:

The expansion of capacity and operations on King required an increase in the number of staff on site. This growth in the workforce created the need for additional sewerage capacity. The peak workforce on King was 1800 during construction. This number has dropped to 600 for operations. The sewerage was designed to handle the peak conditions at 1800 people.

Parsons Plant Area

and Surroundings - Water Pollution and

Storm Water Management

Facilities

Approved Water Pollution and Storm Water Management Facilities at Parsons Plant Area and Surroundings

Surrounding Area:

All the storm water runoff from the upstream catchment of the plant area, ROM stockpile area and product stockpile area is diverted around the affected areas by means of berms and channels and has been sized for a 1:50 year flood event.

The surface runoff from the areas is collected in pollution control dams. All the pollution control dams are sized to contain the 1:50 year storm event, including a 0.8m freeboard. The pollution control dam capacities are:

Process plant pollution control dam: 34 000 m3

Product stockpile pollution control dam: 4 000 m3

Inside Parsons Plant:

All plant sections, which process ore or form part of the processing facility have been designed and laid out within proper sump areas, as contingency measures should spills occur. These have been constructed from concrete and are equipped with suitable vertical spindle centrifugal pumps, to allow for controlled evacuation of potential spillages.

The design of the volumetric proportions of the bunds allow accommodation of the maximum volume of the tank or container, which might drain or overflow in that particular catchment.

Sumps have been allowed for in the area of water treatment and clarification, and are similarly equipped with suitable sump pumps.

Potential overflows from the thickener and process water tank are channelled to the dedicated storm water dam.

Opencast Area - Water Pollution and


Facilities

Approved Water Pollution and Storm Water Management Facilities at Opencast Area

Diversion systems have been/will be constructed upslope of the King and Bruce opencast areas in order to divert clean water away from the contaminated areas. Clean runoff from upstream of the opencast areas is/will be diverted around the affected area by means of berms, sized so as to prevent spilling from a 1:50 year storm event. The diversion berms have been and will be constructed with overburden material from the mining area.

Groundwater seepage and direct rainfall water onto the opencast areas is pumped out by means of portable pumps. The water is used for dust suppression on the mine haul roads and operation water in the process plant.

Water within the opencast pit areas is contained within the pit perimeter in low-lying areas. The water is pumped to various areas within the pit perimeter should it be required by the mining activities.


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Primary and Secondary Crushers - Water Pollution and


Facilities

Approved Water Pollution and Storm Water Management Facilities at Primary and Secondary Crushers

All the storm water runoff from the upstream catchment of the King crusher and Bruce crusher, is diverted around the areas by means of berms and channels which are sized for a 1:50 year storm event to designated pollution control dams.

The sumps within the pollution control dams are lined to minimise seepage. All the pollution control dams are sized to contain the 1:50 year storm event including 0.8m freeboard. The pollution control dam capacities are:

King crusher pollution control dam: 1 500 m3

Bruce crusher pollution control dam: 1 700 m3

Water collected is used for dust suppression at the primary and secondary crushers at the Bruce and King / Mokaning opencast operations.

Dry materials from the paddock is then removed to the Overburden and Low-grade ROM Stockpiles. Sumps have been constructed at the crushers to contain the water from the dust suppression system. The sumps have been provided with silt traps and a submersible pump. Sludge and mud are removed and disposed of on the nearest overburden dump and/or low-grade ROM stockpile.

Stockpiles and dumps - Water

Pollution and Storm Water Management

Facilities

Approved Water Pollution and Storm Water Management Facilities at Stockpiles and Dumps

Diversion systems have been constructed upslope of the stockpiles and / or dump areas in order to divert clean water away from the contaminated areas. Clean runoff from upstream of the opencast areas is diverted around the affected area by means of berms, sized for a 1:50 year storm event. The diversion berms have been constructed with overburden material from the mining area.

Paste disposal facility - Water

Pollution and Storm Water Management

Facilities

Approved Water Pollution and Storm Water Management Facilities at Paste Disposal Facility

Under Drainage and Seepage Control System:

An under drainage and seepage control system with downstream paddocks has been designed and implemented to assist in lowering the phreatic surface in the starter wall, to maximize water return and to limit the release of potentially contaminated water into the downstream environment.

A layer of sand underlies the paste disposal facility. Supernatant water collects at the interface between the residue surface and the natural ground. In this area seepage into the underlying sand is likely to occur, as the sand will not be sufficiently blinded with residue. This seepage water will be confined to the sand layer and will flow down gradient towards the downstream environment. To capture and control this flow a combined under drainage and cut-off system is required.

Contaminated Runoff Control:

Any storm water runoff from the downstream embankment slopes will contain some eroded residue solids. In order to prevent the eroded residue solids from discharging into the surrounding environment, catchment paddocks are provided downstream of the embankment toe. The paddocks are sized to contain the peak runoff from the outer embankment expected from the 1:50 year recurrence interval storm and allow for sedimentation of any eroded solids and evaporation of storm runoff.

The catchment paddocks require periodic cleaning of deposited sediment. This should form part of normal operation and maintenance.


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Due to the site being positioned in a valley, storm water diversion forms a significant consideration in terms of the overall design.

The external catchment draining towards the paste disposal facility has an area of 171ha. The catchment is largely positioned to the east of the site. In order to divert the flows from each portion of the catchment, cut-off trenches and diversion bunds are required.

The sand is highly permeable and therefore any water entering the sand will drain rapidly. The deposition method results in the blinding of the surface of this sand layer with the residue material. This serves to reduce seepage from the basin once it has been covered by residue.

Containment:

A containment dam has been constructed to contain all precipitation. Supernatant water (above the paste in the paste facility) is pumped into the return water system when required, and is returned to the plant for reuse.

The slurry delivery system to the paste disposal facility has been designed to allow containment of potential spills at any location along the route for the full volume of the pipeline contents. A pipeline break will therefore result in the controlled spill of slurry into a spill collection ditch that discharges into an emergency paddock, where the slurry will be contained for subsequent removal, to prevent release into the environment.

Linear infrastructure - Water Pollution and Storm Water

Management Facilities

Approved Storm Water Management Facilities for Linear Infrastructure

Haul roads are constructed to allow storm water to run-over low points.

Storm water is allowed to run off the access roads to low points.

Culverts have been constructed where conveyors and roads cross the 1:100 year flood lines. The culverts have been constructed

such as to allow through flow of 1:100 year floods and debris.

The following have reference to the Rail Siding:

o Culverts are located at the lowest points along the long section.

o Long sections are used to determine the acceptable sizes of culverts so that the depth of the culvert does not exceed

the depth available under the railway line.

Workshops - Water Pollution and Storm Water Management

Facilities

Approved Water Pollution and Storm Water Management Facilities for Workshops

Maintenance workshops have been provided as part of the infrastructure in the vicinity of the Parsons Plant, and Bruce and King / Mokaning opencast operations. Oil / water separators have been installed on each of the water discharges of the three workshops.

The separators have three compartments. The first compartment collects sand, grit and stones and is emptied and cleaned once a year or when necessary. The material is disposed of with the waste being deposited in the oil contaminated waste skip for disposal.

Retained oils and grease in the second compartment are emptied once a year and discharged off site in line with the Mines contract for the disposal of such material. Water from the separator is collected in the third compartment before being pumped to the process water dam at Parson and the mine water tank at the Bruce and King / Mokaning operations, depending on where the workshop is located.


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Laboratory Acid Treatment Plant

Approved Water Pollution and Storm Water Management Facilities for Laboratory Acid Treatment Plant

Weak diluted acids are used in the laboratory at the Parsons Plant. These solutions are discharged from sinks in the laboratory. Prior to the discharge of these solutions into the sewage system, they are treated in an acid neutralising treatment plant to a neutral pH.

Potable Water Supply

Potable Water Supply

Approved Potable Water Supply

With the start of the Kumba iron ore mining operation, the Vaal-Gamagara water scheme was built with one of the main purposes being to supply water from the Vaal River to the Sishen mining operations. The magnitude of the dewatering requirements at Kumba Iron Ore MIne necessary to create dry mining conditions was not foreseen at the time of the construction of the Vaal-Gamagara pipeline. In recent years, the dewatering programs at both Kumba operations and further south at Assmang’s Beeshoek Mine near Postmasburg have started pumping more and more water into the pipeline.

Although Kumba currently discharges excess water into the pipeline, water demand from the pipeline is also on the increase. Population numbers in the Kathu area as well as the manganese mines that rely on water from the pipeline are on the increase. More importantly, however, is the fact that water pumped from the Vaal River is very expensive and projects are underway to substitute as far as possible the water from the Vaal River with groundwater from the Kumba and Beeshoek mines.

Operational Phase Water is contracted to be supplied at a rate of 800m3/hour from an abstraction point on the existing Sedibeng water pipeline to a point on the Farm Parsons.

Coordinates of the Sedibeng Pipeline Abstraction Point on the Farm Parsons:

Reference X Coordinate

South Y-Coordinate

North

Abstraction Point from the Sedibeng Pipeline

27º 51’ 48.2” 22º 58’ 14.5”

Water supply is potable water, and is used to top up the 10 000m3 make-up Gamagara Tank, and for certain other uses. Water in the plant system is recycled where possible to minimise the potable water top-up demand.

Khumani plans to utilize 4.5 million m3 per year.

A 10 000m3 and two (2) other potable water dams have been established at the Parsons Plant in which the water from the Sedibeng Pipeline is stored. From the potable water dam, the water is pumped to potable water tanks (150m3), which have been established at the plant and the opencast areas to provide water for domestic, workshop and wash bay purposes.

Dirty water from the pits, sewage facilities, workshops and wash bays is re-used in the plant process and/or mining activities.

Assmang’s objective is to reduce the volume of water obtained by maintaining the re-use of water.

Disturbance of Water Courses


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Disturbance of Water Courses

Two (2) river diversions have been approved for Khumani:

Drainage channel diversion associated with the King/Mokaning Low Grade Stockpile; and

Diversion of the non-perennial drainage channel around the King West opencast mining area.


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2.2 Proposed Infrastructure and Upgrades

As part of the original Khumani mining operations there was always the philosophy that low-

grade material will be processed in the future. Process enhancements now allow for low

grade material to be beneficiated.

To give effect to the reclaiming philosophy, a new beneficiation plant will be required to

process material previously considered as discard and now designated low grade. The plant

designed to beneficiate this material will be known as the WHIMS 2 Plant. The

implementation of this plant will result in a need for various additional equipment such as

reclaiming infrastructure and conveyors. The implementation of this plant, will further

ensure that the already approved Off Grade 2 plant now can produce two streams of product,

i.e. product directly considered as final product for earmarked markets, and product

considered as low-grade with the potential of be reprocessed to fulfil the requirements for

earmarked markets.

The sections below provide more details on the infrastructure required. The sections are

broken down into various sub-sections to represent the overall reclaiming strategy and the

associated activities of the mine. Infrastructure is labled for ease of reference on the map

shown in Figure 2.1 and Appendix A.

2.2.1 WHIMS 2 Plant (C)

The first WHIMS Plant was approved, constructed and completed on Khumani in 2013. As part

of the optimisation of the current processing activities, an additional WHIMS Plant (C) is

proposed as part of the infrastructure expansion project (Figure 2.1). The new facility will

be located on the western side of the Khumani access road (R523) and north of the Parsons

Low Grade Stockpile (A) (previously known as the Parsons Discard Dump with the Parsons Low

Grade Stockpile (A) forming part of this application). The facility will comprise an area of

approximately 23ha.

Referring to Figure 2.1; the New Parsons Low Grade Conveyor (F) will convey low grade

material from the existing Parsons Plant to the Low Grade Stockpile (A) and to the Tertiary

By-pass Stockpile (E). The Reclaimimg Product Conveyor (G) will convey product from the

Low Grade Reclaim Facility (B) to the new WHIMS 2 Plant (C). The Low Grade Conveyors (D)

will convey product from the already approved Off Grade 2 facility.




Figure 2.1: Proposed new infrastructure on the farm Parsons

2.2.2 Parsons Low Grade Stockpile Expansion (A)

The existing and approved discard stockpile now referred to as the Low Grade Stockpile on

the farm Parsons, will be expanded to accommodate the low grade product from the plants

which will be reclaimed in the future. The facility will be expanded by approximately 245ha,

as depicted by (A) in Figure 1 resulting in an overall footprint of 356.3ha.

Material, reclaimed from the (expanded) Low Grade Stockpile (A), will be processed at the

WHIMS 2 Plant (C) as part of the reclamation process.

2.2.3 Low Grade Reclaim Facility (B)

The Low Grade Reclaim Facility (B) will be located on the northern side of the Parsons Low

Grade Stockpile (A) (Figure 2.1). The facility will comprise an area of approximately 13ha.

The facility will comprise reclaiming infrastructure which may include a conveyor and loading

equipment. From the Low Grade Reclaim Facility (B), the material will be conveyed to WHIMS

2 Plant (C), and after WHIMS 2 Plant will be conveyed either to the Parsons product stockpile

yard or will be returned via the New Parsons Low Grade Conveyor (F) Low Grade Stockpile

(A) for further stockpiling and possible processing.



2.2.4 Tertiary By-pass Stockpile (E)

Referring to Figure Figure 2.1, proposed infrastructure will allow feed to the Low Grade

Stockpile (A) and the Tertiary By-pass Stockpile (E) from either the existing Parsons Plant

(New Parsons Low Grade Conveyor (F)) or the proposed Off Grade 2 Plant (shown in yellow to

the right of the R523 and south-east of the existing Parsons Plant). The Off-Grade 2 Plant

was approved in October 2013 by NCDENC and the DMR. The Off-Grade 2 Plant is part of the

processing optimisation strategy, which aims at ensuring that Khumani reaches its optimal

approved production target of 16 million tons per annum.

Low grade material from the existing Parsons Plant and the Off-Grade 2 Plant will be

transported via conveyors to a transfer bin, just west of the Dingleton Road (R523). From

the transfer bin, the material will be transported via the Low Grade Conveyors (D) to either

the Parsons Low Grade Stockpile (A) or the Tertiary By-pass Stockpile (E).

The Tertiary By-pass Stockpile (E) will be utilised during times when access to the Low Grade

Stockpile (A) is not available (for example during maintenance periods, expansion activities,

or logistical constraints). The facility will be located on the western side of the Khumani

access road (R523) and just east of the Low Grade Stockpile (A) (previously known as the

Parsons Discard Dump). The facility will comprise an area of approximately 30ha.

All conveyors will be associated with service roads of less than 8m in width.

2.3 Additional Low Grade Stockpiles

2.3.1 King ROM Stockpile (J)

The King ROM (Run of Mine) Stockpile (J) (refer to Figure 2.2), will be located to the south

west of the existing King Mine crushing facility on the farm King and will comprise an area of

approximately 48ha. The material deposited on the King ROM Stockpile (J) is ROM material

that is to be stockpiled when down stream equipment is unable to accept material due to

maintenance, breakdown repair and other constraints. In time, the ROM material that has

been stockpiled will be reclaimed and processed through the King Mine crushing facilities and

conveyed to the Parsons Plnat for further beneficiation.




Figure 2.2: Proposed new stockpiles on the farm King

2.3.2 King/Mokaning Low Grade ROM Stockpile Expansion (H)

Referring to Figure 2.2, the existing King/Mokaning Low Grade ROM Stockpile on farm King

will be expanded to accommodate material from the King Mine opencast pit. This expansion

is indicated as (H) on the map. During the application phase it was initially indicated as a

stand-alone stockpile. To optimize stockpiling and design requirements, the facility will be

integrated with the existing King/Mokaning Low Grade Stockpile.

The King/Mokaning Low Grade Stockpile is located east of the decommissioned Port Elizabeth

/ Hotazel railway line and the south of the King opencast pit. The stockpile will be an

extended to the west by 58ha.

2.3.3 Bruce Low Grade ROM Stockpile and Overburden Dump Expansion (K)

Referring to Figure 2.3, the existing Bruce Low Grade ROM Stockpile and Overburden Dump

on farm Bruce will be expanded. Based on the current mining schedule the mine has

determined that the areas for the Bruce Low Grade ROM and Overburden Dump will not be

sufficient in the long term and will require expansion.



The Bruce Low Grade ROM Stockpile and Overburden Dump area is proposed to be extended

by 75ha to increase the capacity of the stockpiling area. The area originally approved for the

Bruce Low Grade ROM Stockpile and Overburden Dump was 268ha thus increasing the area to

343ha in total.


Figure 2.3: Proposed stockpile expansion on the farm Bruce

2.4 Ancillary Infrastructure

Additional infrastructure will include:


High Pressure Grinding Roll (HPGR) Crushing Facility to be located within the

approved Parsons Plant area;

Haul roads; and

22kV power lines to accommodate the WHIMS 2 Plant and the reclamation activities.

2.5 Bulk Supporting Services

The proposed activities will tie into all the existing approved facilities and services on

Khumani which will include:

Potable water from the Sedibeng Water Scheme;



Electricity from the BKM substation located on the farm Parsons;

Use of existing sewerage facilities;

Use of existing and approved waste disposal facilities (domestic and temporary

hazardous site) on Parsons and waste management protocol; and

No expansion required on the existing Paste Disposal Facility.

2.6 Mining Activities

Please note: All mining activities on Khumani have already been approved by the

previous EMPs submitted to the DMR and NCDENC. The following is a summary of the

current mining activities on Khumani as approved. The mining work programme as

submitted for mining activities is still applicabnle as the change in processing activities

does not change the production output from mining at Khumani.

Khumani mines high-grade hematite iron ore. Iron ore in the Sishen/Postmasburg area is

preserved within a sequence of Proterozoic sediments of the Transvaal Supergroup and

Olifantshoek Group. The ore deposits occur within the Wolhaarkop Breccia, which overlies

the dolomites of the Cambellrand Formation and is overlain by the Sishen shale.

The northern iron ore deposits on the farms Bruce, King and Mokaning are relatively shallow

lending themselves to economical opencast mining.The ore and associated overburden are

removed by truck and shovel operations.

As an integral part of the mining operations, backfilling is employed to minimise both the

final voids left open at the end of mining and the size of the waste dumps.

The opencast area is subdivided into four areas, namely Bruce A, B, C and King/Mokaning.

These areas are associated with 19 individual opencast pits.

Iron ore is transported via conveyors for washing and screening in the beneficiation plant.

Thereafter, it is transported via conveyor to the rapid load out siding and loaded to be railed

to Saldanha for export. The local railway siding will allow for transport of iron ore to Port

Elizabeth for the local market.

2.7 Proposed Project Planning and Associated Activities



2.7.1 Pre-Construction Phase

The pre-construction phase has been included as a project phase to afford the applicant

sufficient time to address all the environmental authorisations required for the proposed

operation (i.e. in terms of the MPRDA, NEMA and NWA), as well as to address other regulatory

requirements. In addition the development of various management plans, action plans and

identification of potential services providers will also be undertaken during this phase.

The Mine commits to obtain all necessary environmental authorisations from the relevant

government departments, before undertaking any construction activities.

No impact assessment is undertaken for the pre-construction phase as the activities assessed

are all process related.

2.7.2 Construction Phase

The following activities may result in impact on the bio-physical and socio-cultural

environment:

Site clearance:

o Stripping of vegetation for infrastructure development;

o Stripping of topsoil and subsoil as the construction activities start on site;

Construction activities:

o Construction of the WHIMS2 Plant;

o Enlargement of the Low Grade Stockpile on Parsons;

o Construction of Low Grade Reclaim Facility on Parsons;

o Constuction of Tertiary By-pass Stockpile on Parsons;

o Construction of King ROM Stockpile on King;

o Expansion of the the King/Mokaning Low Grade ROM Stockpile;

o Expansion of the the Bruce Low Grade ROM Stockpile and Overburden Dump;

o Construction and expansion of conveyor belts; and

o Upgrade of the existing stormwater management structures.

Decommissioning and Closure activites:

o Stockpile shaping and stabilising for closure;

o Removal of Plant and associated infrastructure; and

o Landscaping of footprint area.

The following impacts may arise due to the above mentioned activities:



Loss of vegetation, which may included senstitive strata, such as the Kameeldoring

tree;

Loss of topsoil;

Impact on the water system with an increase in runoff and associated siltation

potential;

Loss of sensitive aquatic systems, such as the pans present on Parsons;

Possible compaction of soils by the establishment of topsoil stockpiles and berms;

and

Dust dispersion from infrastructure construction activities.

An impact assessment (Section 7) has been undertaken for the life of the project as the


be implemented. It should however be noted, that the management measures included are

based on the management measures recommended and approved as part of prior EMPs and

conditions stipulated in approved Environmental Permits and Licenses.

2.7.3 Operational Phase

The Operational Phase of the project will begin shortly after the Construction Phase due to

the current mining operations taking place and the need for the stockpile areas. The

following activities are envisaged during the operational phase:

Stockpiling of overburden;

Stockpiling of low grade material

Stockpiling of ROM;

Dust suppression;

Processing of Low grade material; and

Final product handling and transportation.

During the operational phase, the following activities could impact on the bio-physical

environment and the cultural/social setting:

Impact on surface- and groundwater system due to the operational activities;

Dust dispersion from workings and haul roads;

Dust dispersion from ROM, low grade and product stockpiles;

Clean and dirty water control and maintenance; and

Operation of the plant.



An impact assessment (Section 7) has been undertaken for the operational phase as the


be implemented.

2.7.4 Decommissioning and Closure Phase

After the Operational Phase has been finalised, Khumani will commence with the

Decommissioning and Closure Phase of their operation in line with their approved

environmental authorisations. The following activities are envisaged during the

decommissioning and closure phase:

Recovery of all saleable infrastructure;

Demolition of all buildings and structures, unless buildings and/or infrastructure can

remain as a social or economic contribution to the area;

Ripping of all compacted areas, which will be followed with amelioration and

vegetation;

Shaping of all remaining piles and slopes to blend in with the surrounding

environment;

Amelioration and vegetation of all disturbed areas;

Maintenance of all re-vegetated areas up until such areas initiate succession and

create a sustainable cover;

Monitoring of key environmental variables (i.e. air quality, soil, flora, groundwater

and surface water) in order to demonstrate stability of rehabilitated areas;

Weed management after closure, limited to surface areas disturbed by mining

activities/operations; and

Monitoring for a specific period after closure or up until such time that all areas

create a sustainable cover and ecosystem (in accordance with legislative

requirements).

An impact assessment (Section 7) has been undertaken for the decommisisiong and closure

phase as the activities specified may trigger impacts requiring mitigation and management

measures to be implemented.



3 PROJECT ALTERNATIVES



Regulation 31 (2)

2 f) A description of the need and the desirability of the proposed activity

2 g) A description of identified potential alternatives to the proposed activity, including

advantages and disadvantages that the proposed activity or alternatives may have on the

environment and the community that may be affected by the activity.

2 i) Description and comparative assessment of all alternatives identified during the

environmental impact assessment process

A number of alternative options have been identified during the Scoping and EIA Phases. A

high-level qualitative risk assessment was performed to determine the most preferred option

in each case from an economic and/or environmental perspective.

It should be noted that Khumani is an approved mining area, with a detailed mine layout. It

is the philosophy of the mine to utilise their existing infrastructure or areas in close proximity

thereof, for any additional infrastructure required. In terms of the proposed infrastructure

and upgrades required at Khumani, Assmang aims to utilise areas within their approved

mining area and to avoid undisturbed sites. The infrastructure associated with this project

is mostly associated with the expansion of existing, approved infrastructure footprints, with

the King ROM Stockpile the only stand-alone stockpile located within the King mining area.

Based on the abovementioned, location alternatives have not been considered as part of this

application.

3.1 Activity Alternatives

No activity alternatives were considered for the project. The mine is committed to the

reclaiming of low-grade material as part of their process to optimally utilise their resources

and therefor the activities presented in this application is submitted for approval. The

activities proposed present the least footprint impact and is considered to be the most

economically feasible option.



3.2 Needs and Desireability of the Project

The project should be seen as a continuation of Khumani’s commitment made in the Mining

Right Application and subsequent EMPs, to reclaim all low grade material as far as practically


Through Khumani’s ongoing commitment to optimise its existing mineral resources,

the operational team has identified the need for additional process facilities required

to optimise beneficiation and still meet its approved production allocation. The

approved Khumani Mining Right Application, submitted by Assmang, stipulated the

mine’s intention to reuse low grade material by reclaiming same in the future. The

proposed project ensures that the mine fulfils this commitment.

3.3 No-Go Principle



beneficiation and still meet its approved production allocation. Based on the current mining

schedule the mine has determined that the areas for the Bruce Low Grade ROM and

Overburden Dump will not be sufficient in the long term and would require expansion. The

Bruce Low Grade ROM and Overburden Dump is proposed to be extended by 75ha to increase

the capacity of the dump.

Not reclaiming the low-grade material will result in the presence of extensive infrastructure

(stockpiles) requiring shaping and stabilising as part of the closure conditions stipulated in

the approved EMPs. Reusing material throughout the life of mine, can be regarded as ongoing

rehabilitation, whilst also resulting in an economic benefit to both the mine and iron ore






4 DETAILED ENVIRONMENTAL DESCRIPTION

This section of the report relates to Section 31(2) of the GNR543 published in Government


Regulation 31 (2)

2 d) A description of the environment that may be affected by the activity and the manner in

which the physical, biological, social, economic and cultural aspects of the environment may

be affected by the proposed activity

2 j) A summary of the findings and any recommendations of any specialist report or a report on

a specialized process

This chapter of the report provides a summarised description of the environment as obtained

from specialist investigations undertaken in 2014, and from specialist studies conducted

during different phases of the mine’s development. The information plays an important role

in identifying the significance of the potential impacts which may occur as a result of the

proposed project.

4.1 Geology

The farm Parsons is situated in the northern part of the Maramane Dome. Carbonate rocks of

the Campbellrand Subgroup and iron formations of the Asbesheuwels Subgroup of the

Transvaal sequence define the dome. The eastern part of Maramane Dome is exposed. The

red beds of the Gamagara Formation of the Olifantshoek Group overlie the Transvaal

sequence along an angular unconformity to the west.

The south-eastern and central parts of Bruce are characterised by higher topography than

the surroundings, which is defined by the Manganore Iron-formation. This includes chert

breccia, banded ironstone, shale and laminated iron ore. The ore deposits occur within the

Wolhaarkop Breccia, which overlies the dolomites of the Cambellrand Formation and in turn

is overlain by the Sishen shale.These geological formations can be seen in Figure 4.1.




Figure 4.1: Geological Map of the Khumani Mine area.

4.2 Topography

The general topography is characterised by fairly flat terrain, with no steep inclines, except

for the two (2) mountain ranges to the west (Langberg range) and a smaller range to the east

(Kuruman Heuwels). Altitudes range from approximately 1360 metres above mean sea level

(mamsl) in the south to 1200mamsl in the north. Various landform elevations occur on the

farms King, Parsons and Mokaning, with the highest elevations on the southern portion of

Mokaning farm (1365mamsl) and on the border between Mokaning and King (1347.3mamsl).

The area on the farm Bruce consists of relatively flat river valleys in the south to a mixture

of mining disturbed and flat uncultivated land in the north. Altitudes range from

approximately 1200 metres above mean sea level (mamsl) in the south, where the Gamagara

River flows, as well as the north of the property, with the land gradually increasing in gradient

to approximately 1260mams in the centre of the project area.

The area where the proposed infrastructure will be situated are shown in (Figure 4.2).




Figure 4.2: Topographical map of the Khumani mine area.

4.3 Climate

Information contained in this section was obtained from Khumani EMP Amendment

undertaken in 2011, the Air Quality Assessment undertaken by Airshed Planning Professionals

(Pty) Ltd in 2005 and the Air Quality Gap Analysis undertaken by Prism EMS (Pty) Ltd in 2015.

The proposed infrastructure upgrades are located in an area that is characterised by a low

rainfall. Most of the rainfall in this semi-arid region occurs in summer and autumn months

between December and April.

4.3.1 Precipitation

Records from the previous study from South African Weather Service for the Postmasburg and

Kuruman Weather Stations (years 2000 and 2003) and from the Sishen Weather Station for

the years 1961 to 2001 (Sishen Iron Ore Mine EMPR, 2002) show that the mean annual rainfall

for the area is approximately 386 mm, while the observed records for the Parsons Farm for

the three year period show 353 mm. The data obtained from the weather station on site for

the period 2012, 2013 and 2014, indicated a mean annual rainfall for the area of

approximately 418, 154, and 314 mm respectively, refer to Figure 4.3.



Figure 4.3 Average Monthly Temperature measured at Parsons Weather Station (2012-2014)

4.3.2 Temperature

Although the Northern Cape is mainly semi desert, the western areas of the Northern Cape,

including Namaqualand, a small section of the Green Kalahari and Calvinia, Nieuwoudville

and Loeriesfontein in the Karoo fall into the winter rainfall area from April to September.

Sharing the same climate as Namaqualand, these two sub regions will give you displays of

wild flowers during spring months from July to October.

The Northern Cape’s weather is typical of desert and semi desert areas. This is a large dry

region of fluctuating temperatures and varying topographies. The annual rainfall is sparse,

only 50 to 400mm per annum. In January, afternoon temperatures usually range from 34 to

40º C. In 1939 an all time high of 47.8º C was recorded at the Orange River. Summer

temperatures often reach 40º C . Refer to Figure 4.4 for average monthly temperatures from

the Parsons Weather Station.



Figure 4.4 Average Monthly Temperature measured at Parsons Weather Station (2012-2014)

4.3.3 Wind

The weather station that monitors standard meteorological parameters has been operational

on Parsons Farm at the Salvage Yard, north of processing plant and west of

stackers/reclaimers since the end of November 2011. The station experienced problems with

data capturing during the first few months of operation, but is now yielding results on a

regular basis. The graphs for wind roses and different measured parameters are presented

below.

In terms of the data collected from the weather station, the spatial and annual variability in

the wind field for Parsons Farm is clearly evident in Figure 4.5. The predominant wind

direction is from north-northeast and south southwest, with frequent winds also occurring

from the north and south. Over the three-year period, frequency of occurrence was over 8%

from the south and south south-westerly sector, with south-westerly winds occurring over 7%

of the time. Less frequent winds (above 6% of the time), but stronger were noted from the

north, north-north-easterly and north-easterly sector.



Figure 4.5: Period Wind roses recorded at Parsons Weather Station for period (2012-

2014)

Calm conditions (wind speeds less than 0.5 m/s) occur for less than 11.8% of the time, with

winds between 0.5-2.1 m/s occurring for 40% of the time. The data is in good agreement with

data sourced for the previous study for the SAWS automated weather station in Kathu,

indicating that the average wind speeds over this site for the period November 2011 to end

November 2014 is 2.21 m/s.

During daytime there is an increase in winds from north-northwest, north and northwest,

with frequencies of greater than 10%. Nocturnal wind flow reflects more dominant winds

from the south, south-southwest and southwest. Frequent winds from the south occur for

approximately 10% of the time. Night-time conditions also reflect a decrease in wind speeds

with average wind speed decreasing to 1.87 m/s in comparison to daily wind speeds of

between 2.55 m/s. Refer to Figure 4.6 for indictation of seasonal wind directions as measures

at Parsons Weather Station.



Figure 4.6: Period Wind roses recorded at Parsons Weather Station for period (2012-

2014)

4.4 Soils, Land use and Land Capability

Information contained in this section was obtained from Khumani EMP Amendment

undertaken in 2011 and the Soils and Land Capability Assessment undertaken by GCS (Pty)

Ltd in 2005.

4.4.1 Soil

Soil distribution is strongly linked to the topography of the area. In turn, the topography is

closely linked to the underlying surface geology. Hard rock outcrops characterise the

topographic highs of the area. The outcrops generally comprise quartzites and the iron ore

bearing ironstones. These outcrops form prominent hills or ridges with moderate to steep

slopes. In these areas, soils are very shallow to non-existent, occurring as erratic pockets of

orange sands within the outcrops. The pockets can be as deep as 1m. These soils are classified

as Mispah Form soils, with minor occurrences of Hutton Form soils.



The very gently sloping areas between the hills and ridges are generally underlain by calcrete

or dolomite. The calcrete is overlain by orange fine sands, which can be classified as

Plooysburg Form soils. The calcrete surface is undulating, with isolated boulder outcrops

occurring within the soils. The soil depth is highly variable, being between about 0,3m to

greater than 2m.

On the lower slopes, between the Plooysburg Form soils and the Mispah Form soils are Hutton

Form soils. These areas are characterised by abundant, to numerous surface boulders,

derived from the outcrops upslope thereof, which have moved by gravity down slope to be

deposited on the ground surface. Refer to (Figure 4.7) for the soil map.


Figure 4.7: Soil Types.

The Hutton Form soils are characteristically dystrophic and non-luvic in the B1- horizon,

indicative of Lillieburn Family soils while the Plooysburg Form soils are non luvic – Brakkies

family and the Augrabies Form soils have a non-bleached red A horizon and are non-luvic,

characteristic of the Khubus Family. The Hutton and Plooysburg Form soils examined on site

comprise dry, yellowish red to red, apedal, loose, fine sands, with little observed

differentiation between the topsoil and the B1-horizon sandy loams. The topsoil of the Mispah

Form and Augrabies Form soils is also very similar in structure.



4.4.2 Land Capability

The Mispah Form soils can be classified as wilderness land or non-arable land. Although the

remainder of the area is underlain by Plooysburg and Hutton Form soils, due to the variability

of soil depth and the presence of isolated rock outcrops within these soils, as well as abundant

to numerous scattered boulders on the surface, these soils are classified as low yield grazing

land.

The site is located within the mining area and surrounded by infrastructure associated with

the mining industry and as a result, has no specific land capabilities other than that of mining

and mining related activities. There are no substantial areas of arable land or wetland areas

within the site, some pans do exist in the proposed low grade stockpile area on King and

Bruce. Refer to Table 4.1 for Land Capability Classes.

Table 4.1: Land Capability Classes

CLASS DESCRIPTION

CLASS I:

WETLAND

Diagnostic O horizon at the surface.

A horizon that is gleyed throughout more than 50% of its volume and is significantly

thick, occurring within 750 mm of the surface.

CLASS II:

ARABLE LAND

Does not qualify as a wetland.

The soil is readily permeable to the roots of common cultivated plants throughout

a depth of 0.75 m from the surface.

pH value between 4,0 and 8.4.

Low Sodium Absorption Ratio (SAR) and Salinity.

The soil has a permeability of at least 1.5-mm per hour in the upper 0.5 mm of

soil.

The soil has less than 10% (by volume) rocks or pedocrete fragments larger than

100-mm in diameter in the upper 0.75 m.

Has a slope (in %) and erodibility factor (K) such that their product is <2.0.

Occurs under a climatic regime, which facilitates crop yields that are at least

equal to the current national average for these crops or is currently being irrigated

successfully, or is scheduled for irrigation by the Department of Water and

Sanitation.

CLASS III:

GRAZING LAND

Does not qualify as wetland or arable land.

Has soil, or soil-like material, permeable to roots of native plants, that is more

than 250-mm thick and contains less than 50% by volume of rocks or pedocrete

fragments larger than 100 mm in diameter.

Supports, or is capable of supporting, a stand of native or introduced grass species,

or other forage plants, utilizable by domesticated livestock or game animals on a

commercial basis.

CLASS IV:

WILDERNESS

LAND

Land which does not qualify as wetland, arable land or grazing land.



4.4.3 Land Use

Kumba Iron Ore Mine, a large opencast mining operation, is situated directly north of the

farm Parson, northwest of the farm King and west of the farm Bruce. Besides the mining

operations, other activities in the region include livestock farming, and small residential

communities and business trade. The land use on site is currently mining and mining related

operations.

The main land uses in the study area are:

Livestock grazing;

Game farming; and

Mining.

Figure 4.8 indicates the current land use of the mining area.


Figure 4.8: Current Land Use within the Khumani mine area.

4.5 Heritage and Sites of Cultural Significance

No archaeological artifacts have been identified in the footprint areas where infrastructure

is planned. The sites as identified during the original EIA for Khumani will be maintained as

per the management conditions.



It is possible that sub-surface features of an archaeological nature (ostrich eggshell cache,

high density artifact horizons, and burials) may be found during activities. In the event of

these being found, an archaeologist will be contacted immediately to assess significance and

recommend mitigation measures.

4.6 Biodiversity

The biodiversity description was undertaken by GCS Water & Environment as part of the

detailed Ecological Assessment (2014) (Appendix C-1). A desktop study was performed for

the Bruce expansion area to serve as an update to the previous studies conducted previously

for that area.

4.6.1 Regional Ecology

The Savanna Biome is the largest biome in southern Africa, covering about 46% of its area.

The term savanna is widely accepted as describing a vegetation type with a well-developed

grassy layer and an upper layer of woody plants. Many environmental factors correlate with

the distribution of different savannah vegetation types, including landform, climate, soil

types, fire and a very specific fauna. South African savannas of nutrient-poor substrates are

characteristically broad-leaved and without thorns, while those of nutrient-rich substrates

are fine-leaved and thorny. Nutrient-rich savannas have high grass layer productivity and the

grasses are acceptable to grazers, resulting in a high grazing capacity (Knobel, 1999).

The diversity of African savanna is exceptional, comprising more than 13,000 plant species,

of which 8,000 are savanna endemics. Specifically, dry savannas have more than 3,000. This

diversity equals that of the South African grasslands and is only exceeded by Fynbos (Knobel

1999). Similarly, in respect of animal diversity, savannas are without peer, including

approximately 167 mammals (15% endemism), 532 birds (15% endemism), 161 reptiles (40%

endemism), 57 amphibians (18% endemism) and an unknown number of invertebrates

(Knobel, 1999). Flagship species include the Starburst Horned Baboon Spider (Ceratogyrus

bechuanicus), ground Hornbill (Bucorvus leadbeateri), Cape Griffon (Gyps coprotheres), Wild

dog (Lycaon pictus), Short-Eared Trident Bat (Cloeotis percivali) and the White Rhino

(Ceratotherium simum) (EWT, 2002).

Conservation within and of the savanna biome is good in principle, mainly due to the presence

of a number of wildlife reserves. Urbanisation is not a threat, perhaps because the hot, dry

climate and diseases prominent in the savanna areas have hindered urban development. Much



of the area is used for game farming and the importance of tourism and big-game hunting in

the conservation areas must not be underestimated. Savannas are the basis of the African

wildlife and ecotourism industry and play a major role in the meat industry.

Surprisingly little is known about the vegetation as most studies have been done in nature

reserves and game farms, but five major regions are present, three of which are represented

in the study area. Sweet Bushveld occurs on fertile soils in the dry and hot valleys of the

Limpopo River and the thorny, small-leaved vegetation is dominated by Acacia species that

increase to dense, impenetrable thickets at the expense of the grass layer when overutilised.

Mixed Bushveld varies from short, dense bushveld to a rather open tree savanna.

On shallow, infertile soils the broad-leaved Red Bushwillow (Combretum apiculatum)

dominates, whereas on deeper, leached soils the Silver Clusterleaf (Terminalia sericea)

becomes dominant. The Waterberg moist mountain bushveld is a typical example of moist,

infertile savanna. Due to the high proportion of unpalatable grasses, the area has become

known as ‘sour bushveld’. An interesting phenomenon is the presence of many plant species

showing affinities with the flora of the Drakensberg, which indicates an ancient link with this

range (Knobel, 1999).

The vegetation that characterises this area has developed many survival strategies, including

the ability to produce tannins that are triggered when the leaves are browsed, the production

of toxic sap, the development of thorns or their adaptation to sourveld areas that are not

generally favoured by grazers. The interaction of vegetation, fire and animals play important

roles in maintaining savanna ecosystems (Knobel, 1999). Over thousands of years, the savanna

system and the antelope that inhabit them have developed side by side. Grasses, for example,

have become well adapted to defoliation, as much a defensive response to constant pressure

by grazers as to the regular veld fires that rage through the savanna in the dry seasons.

4.6.2 Freshwater Ecosystems

The proposed development is situated in quaternary catchment D41J in the Lower Vaal

Management Area (WMA4), Sub water management area Molopo. The recently published Atlas

of Freshwater Ecosystem Priority Areas in South Africa (Nel et al, 2011a) (The Atlas), which

represents the culmination of the National Freshwater Ecosystem Priority Areas project

(NFEPA), a partnership between SANBI, CSIR, WRC, DEA, DWA, WWF, SAIAB and SANParks,

provides a series of maps detailing strategic spatial priorities for conserving South Africa’s

freshwater ecosystems and supporting sustainable use of water resources. Freshwater

Ecosystem Priority Areas (FEPA’s) were identified through a systematic biodiversity planning



approach that incorporated a range of biodiversity aspects such as ecoregion, current

condition of habitat, presence of threatened vegetation, fish, frogs and birds, and

importance in terms of maintaining downstream habitat. The Atlas incorporates the National

Wetland Inventory (SANBI, 2011) to provide information on the distribution and extent of

wetland areas.

According to the NFEPA database, no pans are present on the proposed Parsons site (Figure

4.9). This was confirmed during the 2014 site visit. There are numerous pans present in the

adjacent areas of the proposed expansion, but none within the footprint area. A wetland was

however identified to be present on the proposed Bruce Expansion site. The wetland was

characterized as an Eastern Kalahari Bushveld Depression. It is recommended that the Present

Ecological State (PES) and Ecological Importance and Sensitivity (EIS) of this pan must be

determined, to quantify the impacts associated with the proposed Bruce Expansion.

The following important observations can be made:

Flagship river: Ga-Magara river runs near the site; and

A wetland was identified to be present on the proposed Bruce Expansion site.


Figure 4.9: NFEPA’s of the study area



4.6.3 Flora

4.6.3.1 Botanical diversity

A total of 70 plant species were recorded during the field investigations (April 2014). During

the April 2014 survey a well-developed herbaceous stratum (Table 4.2) is represented by 28

forbs (40%) and 18 grass species (25.7%). A physiognomically dominant shrub and tree layer

is represented by 12 shrub species (17.1%) and 5 tree species (7.1%). This floristic diversity is

represented by 32 families (Table 4.3), dominated by Poaceae (20 species, 29.1%), Fabaceae

(8 species, 11.4%) and Asteraceae (7 species, 10.0%). The physiognomy and diversity

exhibited by natural habitat with the study areas is regarded representative of the regional

vegetation types. Degradation and transformation is noted on a local and regional scale. It is

therefore concluded that the vegetation is in a sub climax status.



Table 4.2: Growth form recorded on Parson during the April 2014 survey GROWTH FORM NUMBER PERCENTAGE

Climber 2 2.9

Forb 28 40

Geophyte 4 5.7

Grass 18 25.7

Parasite 1 1.4

Shrub 12 17.1

Tree 5 7.1

Total 70 100

Table 4.3: Plant families recorded on Parson during the April 2014 survey GROWTH FORM NUMBER PERCENTAGE GROWTH FORM NUMBER PERCENTAGE

Acanthaceae 1 1.1 Liliaceae 1 1.1

Aizoaceae 1 1.1 Loranthaceae 1 1.1

Amaranthaceae 1 1.1 Malvaceae 2 2.3

Amaryllidaceae 3 3.4 Meliaceae 1 1.1

Anacardiaceae 1 1.1 Mimosaceae 1 1.1

Asclepiadaceae 1 1.1 Oleaceae 1 1.1

Asteraceae 9 10.2 Oxalidaceae 1 1.1

Bignoniaceae 1 1.1 Papaveraceae 1 1.1

Boraginaceae 1 1.1 Pedaliaceae 1 1.1

Capparaceae 4 4.5 Poaceae 23 26.1

Chenopodiaceae 2 2.3 Rhamnaceae 1 1.1

Combretaceae 1 1.1 Scrophulariaceae 1 1.1

Commelinaceae 1 1.1 Selaginaceae 1 1.1

Cucurbitaceae 1 1.1 Solanaceae 2 2.3

Cucurbiteae 1 1.1 Sterculiaceae 2 2.3

Ebenaceae 1 1.1 Tiliaceae 2 2.3

Ehretiaceae 1 1.1 Zygophyllaceae 2 2.3

Fabaceae 11 12.5

Illebracaceae 1 1.1

Lamiaceae 1 1.1

4.6.3.2 Flora species of conservation importance

South Africa’s Red List system is based on the IUCN Red List Categories and Criteria Version

3.1 (finalized in 2001), amended to include additional categories to indicate species that are

of local conservation concern (Table 4.4). The IUCN Red List system is designed to detect risk

of extinction (Table 4.5). Species that are at risk of extinction, also known as threatened or



endangered species are those that are classified in the categories Critically Endangered (CR),

Endangered (EN) and Vulnerable (VU) (SANBI. 2011).

Table 4.4: Botanical conservation data for the Northern Cape

Table 4.5: Plant species conservation status in the Northern Cape

No ‘Threatened’ species were recorded on Parson during the survey period in the study area.

Though a field investigation was not conducted, the occurence of ‘Threatened’ species on

the Bruce expansion area is unlikely due to the proximity to several mining activities. Since

much of the remaining natural habitat within the study area comprises primary climax status

woodland habitat, the possibility that Red Data species might be present within the study

area cannot be excluded at this stage. Species included in the ‘Declining’ category was

recorded during the site investigation on Parson (refer Table 4.6). The definition implies that

the species is declining but the population has not yet reached a threshold of concern and

limited loss of habitat may be permitted. If individuals will not be conserved in situ, plants

should be rescued and used as mother stock for medicinal plant cultivation programmes.

Table 4.6: Conservation important plant species recorded during the April 2014 survey TAXON STATUS ANNOTATIONS

Total number of taxa 4864

Endemic taxa 1302

% of SA flora occurring in province 23.50%

Threatened taxa 295

Endemic threatened taxa 236

% of national threatened flora 11.20%

Taxa of conservation concern 739

Endemic taxa of conservation concern 584

Status Total

Critically Endangered, Possibly Extinct 7

Critically Endandered 16

Endangered 46

Vulnerable 231

Near Threatened 57

Critically Rare 29

Rare 284

Declining 11

Data Deficient (insufficient information) 63

Data Deficient (taxonomically problematic) 129



Acacia erioloba Declining (National status) Abundant through the study area, legal

implications - National Forest Act, 198

4.6.3.3 Protected tree species (National Forest Act)

According the National Forests Act, 1998 (Act No. 84 of 1998), the Minister may declare a

tree, group of trees, woodland or a species of trees as protected. The prohibitions state that

‘No person may cut, damage, disturb, destroy or remove any protected tree, or collect,

remove, transport, export, purchase, sell, donate or in any other manner acquire or dispose

of any protected tree, except under a license granted by the Minister’.

Table 4.7: Protected tree species of the region

4.6.3.4 Vegetation development drivers

Development of the regional (natural) vegetation is generally the result of complex

interacting driving forces that include climatic-, geological-, topographical- and moisture

gradients typical of the arid savanna regions of southern Africa. Little transformation is

evident from livestock farming and suboptimal management strategies (fire management)

that tend to result in minor changes to the herbaceous and shrub layer. These changes are

strongly reflected in localised species changes.

4.6.3.5 Macro habitat types and variations observed

Natural (untransformed) vegetation of the study area and the surrounds is strongly

representative of the regional vegetation types, exhibiting extremely limited (localised)

divergence from the species composition, diversity and vegetation structure described by

Mucina and Rutherford (Vegmap, 2006). Typical of the vegetation of the region is that

extremely little zonality is observed in vegetation forms.

Results of previous studies from 2006, the photo analysis and site investigations revealed the

presence of the following macro habitat types and variations on the farm Parson

• Degraded and Transformed Habitat, including;

o Degraded Woodland; and

Taxon Family

Acacia erioloba Fabaceae

Acacia haematoxylon Fabaceae

Boscia albitrunca Capparaceae

Olea europaea subsp. africana Oleaceae



o Overgrazed Area.

• Woodland Community (Bruce and Parson), including the following:

o Natural Woodland – Open Tarchonanthus camphoratus veld.

Degraded and transformed habitat

These areas generally comprise parts of the landscape where anthropogenic effects caused

an irreversible change in the vegetation. Clearance of land for building of roads, houses and

the mining of resources resulted severe changes to the habitat.

Degraded Woodland

This habitat is characterised by an area that are affected by grazing activities, but not to the

extent that the natural woodland character has been compromised entirely. A cattle kraal is

situated within this area, attributing to the degraded nature of this area. While the largest

extent of the species composition remains similar to the surrounding natural woodland

variations, but some surface disturbances caused the influx of poor quality species to render

the vegetation in a sub climax status. This area does not exhibit any particular aspect of

sensitivity.

Woodland community

Natural woodland of the site is representative of the natural variations that is encountered

on a local and regional scale. The physiognomy is dominated by a well-developed tree/ shrub

layer that tends to encroach where intense and high grazing pressure is applied. A species

rich herbaceous layer is characteristic of the region, comprising a grass layer of which the

composition provides an indication of the reaction of the herbaceous layer on grazing

strategies. Imbedded within this savanna type are various local and regional variations that

establish based on soil characteristics. Localised areas of atypical habitat occur where

underlying geology is exposed.

Open Tarchonanthus camphoratus veld

The localised dominance of the shrubs Tarchonanthus camphoratus, Acacia mellifera, Grewia

flava and Rhigozum trichotomum provides evidence of the reaction of the vegetation on high

grazing pressure. Similarly, the grass sward tends to become less diverse and an increase in

poor quality species is observed.

Much of the tree and shrub layer remained the same with the dominant trees on Parson being

Acacia erioloba and Boscia albitrunca. A noteworthy exception is that Acacia haematoxylon

occurs at much lower intervals compared to the open Acacia erioloba veld, which is probably



also a reaction on either high grazing pressure, or the competitive increase in abundance of

other woody species.

The tree and shrub layer on Bruce consisted mainly off Acacia erioloba (Not abundant in

Bruce), Boscia albitrunca, Acacia hebeclada, Acacia mellifera, Grewia flava, Lycium spp.,

Rhigozum obovatum, Rhigozum trichotomum, Rhus ciliata, Salsola rabieana, Tarchonanthus

camphoratus, Ziziphus mucronata.

Noteworthy grasses on Parson include Aristida stipitata, Eragrostis pallens, E. lehmanniana,

Schmidtia pappophoroides, S. ciliata and Tricholaena monachne, with the less abundant

Aristida congesta subsp. congesta, Cenchrus ciliaris, Melinis repens, Pogonarthria squarrosa

and A. stipitata. The forb layer is similarly less diverse than in the open woodland, containing

Geigeria ornativa, Oxalis semiloba, Hermannia tomentosa, Indigofera alternans, Monechma

divaricatum and Senna italica.

Noteworthy grasses on Bruce were Aristida adscensionis, Aristida congesta subsp. barbicollis,

Aristida congesta subsp. congesta, Aristida stipitata, Cymbopogon plurinodis, Enneapogon

cenchroides, Enneapogon desvauxii, Eragrostis curvula, Eragrostis echonochloidea,

Eragrostis lehmanniana, Eragrostis nindensis, Eragrostis trichophora, Fingerhuthia africana,

Melinis repens, Pogonarthria squarrosa, Schmidtia pappophoroides, Stipagrostis uniplumis.

Shrubs that were recorded in 2006 included Aloe grandidentata, Aloe hereroensis,

Ammocharis coranica, Babiana hypogea, Boophone disticha, Crinum bulbispermum, Felicia

muricata, Geigeria pectidia, Mariscus congestus, Moraea polystachya, Nerine laticoma,

Orbea lutea, Oxalis corniculata, Oxalis semiloba subsp. semiloba, Pentzia spp.,

Protasparagus spp., Senna italica, Solanum supinum.

Protected trees were recorded within this unit and a moderate probability is estimated for

other species of conservation importance occurring within this unit.

4.6.3.6 Botanical sensitivity of the study area

Botanical sensitivity values are presented in Table 4.8. These estimations are used to ascribe

a sensitivity index value to units of the respective variations.

Habitat sensitivity is categorised as follows:

Low

No natural habitat remaining; this category is represented by developed/ transformed areas,

nodal and linear infrastructure, areas of agriculture or cultivation, areas where exotic species

dominate exclusively, mining land (particularly surface mining), etc. The possibility of these



areas reverting to a natural state is impossible, even with the application of detailed and

expensive rehabilitation activities. Similarly, the likelihood of plant species of conservation

importance occurring in these areas is regarded negligent.

Medium – low

All areas where the natural habitat has been degraded, with the important distinction that

the vegetation has not been decimated and a measure of the original vegetation remain,

albeit dominated by secondary climax species. The likelihood of plant species of conservation

importance occurring in these areas is regarded low. These areas also occur as highly

fragmented and isolated patches, typical to cultivated fields, areas that have been subjected

to clearing activities and areas subjected to severe grazing pressure. The species composition

of these areas is typically low and is frequently dominated by a low number of species, or

invasive plants.

Medium

Indigenous natural habitat that comprehend habitat with a high diversity, but

characterised by moderate to high levels of degradation, fragmentation and habitat

isolation; and

Also include areas where flora species of conservation importance could potentially

occur, but habitat is regarded marginal.

Medium – high

Indigenous natural vegetation that comprise a combination of the following attributes:

• The presence of habitat that is suitable for the presence of these species;

• Areas that are characterised by a high/ moderate-high intrinsic floristic diversity;

• Areas characterised by moderate to low levels of habitat fragmentation and isolation;

• Regional vegetation types that are included in the lower conservation categories,

particularly prime examples of these vegetation types;

• Low to moderate levels of habitat transformation; and

• A moderate to high ability to respond to disturbance factors.

It may also include areas that are classified as protected habitat, but that are of a moderate

status.

High

Indigenous natural vegetation that comprehend for a combination of the following attributes:

• The presence of plant species of conservation importance, particularly threatened

categories (Critically Endangered, Endangered, Vulnerable);



• Areas where ‘threatened’ plants are known to occur, or habitat that is highly suitable

for the presence of these species;

• Regional vegetation types that are included in the ‘threatened’ categories (Critically

Endangered, Endangered, Vulnerable), particularly prime examples of these

vegetation types;

• Habitat types are protected by national or provincial legislation (Lake Areas Act,

National Forest Act, draft Ecosystem List of NEM:BA, Mountain Catchment Areas Act,

Ridges Development Guideline, Integrated Coastal Zone Management Act, etc.);

• Areas that have an intrinsic high floristic diversity (species richness, unique

ecosystems), with particular reference to Centres of Endemism; and

• These areas are also characterised by low transformation and habitat isolation levels

and contribute significantly on a local and regional scale in the ecological

functionality of nearby and dependent ecosystems, with particular reference to

catchment areas, pollination and migration corridors, genetic resources. A major

reason for the high conservation status of these areas is the low ability to respond to

disturbances (low plasticity and elasticity characteristics).

A medium high floristic sensitivity is therefore estimated for this type located on the farm

Parson.

Table 4.8: Floristic sensitivity estimations of the study area

4.6.4 Fauna

The study area is located within the regional vegetation community of Kathu Bushveld

(Eastern Kalahari Bushveld Bioregion). This regional vegetation community is listed as Least

threatened (VEGMAP, 2006). The Eastern Kalahari Bushveld Bioregion is situated within the

Savanna Biome of South Africa.

It is important to view the study area on an ecologically relevant scale; consequently, all

sensitive animal species (specific faunal groups) known from the Northern Cape Province are

included in this assessment. Detailed regional and scientific data on all faunal groups are

lacking (notably for most of the invertebrate groups) and as a result only data sets on specific

faunal groups allow for habitat sensitivity analyses based on the presence/ absence of

Criteria RD Species

Landscape

sensitivity Status

Species

diversity

Functionality/

Fragmentation Total

Sensitivity

Index

Sensitivity

Class

Degraded woodland 4 3 3 4 5 117 37% Medium/Low

Open Tarchonanthus camphoratus veld 7 5 8 7 8 221 70% Medium/High



sensitive faunal species (Red Data species) and their specific habitat requirements. The

following faunal groups were included in these analyses:

• Butterflies (Invertebrata: Insecta: Lepidoptera – Nymphalidae, Lycaenidae,

Hesperiidae, Pieridae and Papilionidae). References used include the IUCN Red List

(2011) – http://www.iucnredlist.org and the South African Butterfly Conservation

Assessment (SABCA, 2011) – http://sabca.adu.org.za.

• Frogs (Amphibia: Anura). References used include the Atlas and Red Data Book of the

South Africa, Lesotho and Swaziland, the Giant Bullfrog Conservation Group (2011) –

http://www.up.ac.za/bullfrog and a Complete Guide to the Frogs of Southern Africa

(du Preez & Carruthers, 2009).

• Reptiles (Reptilia: Testudines and Squamata). References used include the IUCN Red

List (2011) and the South African Reptile Conservation Assessment (SARCA, 2011) –

http://sarca.adu.org.za.

• Birds: All bird groups (Roberts VII Multimedia: Birds of Southern Africa, PC Edition).

• Terrestrial Mammals (Mammalia: Insectivora, Chiroptera, Primates, Lagomorpha,

Pholidota, Rodentia, Carnivora, Tubulidentata, Proboscidea, Hyracoidea,

Perissodactyla and Artiodactyla). References used include the Red Data Book of the

Mammals of South Africa: A Conservation Assessment (Endangered Wildlife Trust -

2004).

As more data become available, additional faunal groups are likely to be added to these

assessments. Dragonflies and Damselflies (Invertebrata - Insecta: Odonata) are some

examples of possible future inclusions.

Animals known to be present in the Q-grids 2723CC, 2722BA, 2722BB and 2722BD were

considered potential inhabitants of the study area (all species known from the Northern Cape

Province were included in the assessment to limit the known effects of sampling bias, except

for birds which have been sampled extensively and the data for the Q-grids is accepted as

accurate).

4.6.5 Faunal diversity of the site

The presence of 19 animal species was confirmed during the April 2014 site investigation

(refer to Appendix C1), by means of visual sightings, tracks, scats and burrows:

• Four insects;

• Two reptiles;

• Eleven birds; and

• Two mammals.



The 19 species found to occur in the study area during the April 2014 survey included no Red

Data species.

The presence of fourty four animal species was confirmed during the 2006 site investigation

(refer to Appendix C1), by means of visual sightings, tracks, scats and burrows:

• Two reptiles;

• Thirty four birds; and

• Eight mammals.

4.6.6 Red data faunal assessment

The estimated probabilities of occurrence (PoC) of Red Data fauna taxa are based on:

• the size of the study area;

• the location of the study area;

• the diversity and status of faunal habitat within the study area as well as other

ecological characteristics; and

• the connectivity of the study area to surrounding faunal habitats.

A total of 92 Red Data animals are known to occur in the Northern Cape (butterflies, frogs,

reptiles and mammals) and in the Q-grids 2722BA 2722BB and 2722BD (birds)

The following categories are included:

• 19 taxa are listed as Data Deficient (DD);

• 25 taxa are listed as Near Threatened (NT);

• 38 taxa are listed as Vulnerable (VU);

• 5 taxa are listed as Endangered (EN); and

• 5 taxa are listed as Critically Endangered (CR).

An assessment of the PoC for these animals yielded the following probabilities (refer Table

4.9.

• 63 RD species have an estimated low PoC for the study area;

• 7 RD species have an estimated moderate-low PoC for the study area;

• 8 RD species have an estimated moderate PoC for the study area;

• 7 RD species have an estimated moderate-high PoC for the study area; and

• 7 RD species were confirmed to be present in the study area.

In addition to the above-listed Red Data species of the Northern Cape and the Q-grids 2722BA,

2722BB and 2722BD, ten animal species (some overlap does occur) have protected status



(NEMBA) within the Northern Cape (www.speciesstatus.sanbi.org). PoC for these species was

estimated as follows:

• 7 species have a low PoC; and

• 3 species have a moderate-high PoC.

Table 4.9: Protected species of the Northern Cape Province

4.6.7 Faunal habitat types

The close relationship between vegetation units and specific faunal composition has been

noted in several scientific studies. For the purpose of this investigation, floristic units are

therefore considered representative of the faunal habitat types. The following habitat types

were condensed from the botanical assessment:

• Degraded Faunal Habitat; and

• Natural Faunal Habitat.

4.6.7.1 Degraded faunal habitat

The degraded woodland and pans or impoundments of the study area are deemed degraded

faunal habitat. In contrast to the transformed habitat of the study area, the degraded faunal

habitat retained some of the ecological elements of the region and some intrinsic biodiversity

value. The degraded faunal habitat includes fragments of variable ecological integrity and

biodiversity value (some fragments have lost more of the original ecological elements and

likely faunal species, especially invertebrates, than others do). These fragments of degraded

faunal habitat exhibit medium faunal sensitivities:

• Degraded Woodland: medium faunal sensitivity.

4.6.7.2 Natural faunal habitat

Scientific name Common name NEMBA statusProbability

assessment

Aonyx capensis African Clawless Otter Protected Low

Atelerix frontalis South African hedgehog Protected Low

Ceratotherium simum White rhinpcerus Protected Low

Circus ranivorus African Marsh Harrier Protected Low

Crocuta crocuta Spotted hyaena Protected Low

Diceros bicornis Black rhinocerus Protected Low

Felis nigripes Black footed cat Protected Moderate/High

Parahyaena brunnea Brown hyeana Protected Moderate/High

Spheniscus demersus African penguin Protected Low

Vulpes chama Cape fox Protected Moderate/High



The study area included various natural terrestrial faunal habitats. Open Tarchonanthus

camphoratus and open Acacia erioloba veld differ slightly in terms of floristic attributes and

consequently faunal community structure (most notably invertebrates), but significant

overlap of larger animals’ assemblage structures exist between the different natural faunal

habitats of the study area. The natural faunal habitats of the study area differ slightly in

terms of status, diversity, linkage and sensitivity, but these differences are insignificant.

The estimated faunal sensitivities of all the natural faunal habitats in the study area are

estimated to be medium-high faunal sensitivity:

• Open Tarchonanthus camphoratus veld: medium-high faunal sensitivity.

4.6.8 Faunal habitat sensitivity assessment

During the field assessment, the study area was investigated and assessed in terms of the

following biodiversity attributes:

• Habitat status: level of habitat transformation and degradation vs. pristine faunal

habitat;

• Habitat diversity: the number of different faunal habitat types (both on micro- and

macro-scale) found within the proposed site and bordering areas;

• Habitat linkage: the degree to which the faunal habitat of the proposed site is linked

to other natural areas enabling movement of animals to and from the habitat found

on site;

• Red Data species: the degree to which suitable habitat for the red data species likely

to be found in the study area (larger study area) is located on each site; and

• Sensitive faunal habitat: the relative presence of faunal sensitive habitat type

elements such as surface rock associated with outcrops and hills as well as wetland

elements.

Table 4.10: Faunal habitat sensitivity of the study area

The current habitat sensitivity on the farm Bruce could not be analised due to only having

the 2006 information available for that area.

4.7 Hydrology

Criteria Status Diversity Linkage Red data SensitivitySensitivity

Index

Sensitivity

class

Community

Degraded Woodland 5 6 5 4 6 52% Medium

Open Tarchonanthus camphoratus veld 7 7 8 6 7 70% Medium/High

Criteria Ranking



The hydrological description was undertaken by GCS Water & Environment as part of the

detailed Hydrological Assessment conducted in 2014 (Appendix C-2).

The area of the proposed upgrades falls within the Lower Vaal Water Management Area. The

area is situated in the catchment of the Gamagara River, the quaternary catchment being

D41J (Figure 4.10). The site is located on gently sloping to hilly terrain with rivers flowing in

a north-westerly direction. The major river traversing the site is the Gamagara River, which

flows from the east to west north of the Parsons Plant area. The river then flows north to

confluence with the Kuruman River.

Iron ore, diamonds and manganese are mined in the water management area. Farming

activity ranges from extensive livestock production and rain fed cultivation to intensive

irrigation enterprises at Vaalharts. Kimberley, which straddles the divide between the Lower

Vaal and Upper Orange water management areas, is the largest urban centre in the area.

More than 50% of the yield from natural water resources in the tributary catchments within

the water management area is supplied from groundwater.

Water quality is of special concern in the lower reaches of the Harts and the Vaal Rivers

because of the high salinity of leach water from the Vaalharts irrigation scheme. To counter

this problem, better quality water is transferred from the Orange River to the Douglas Weir

in the lower reaches of the Vaal River for blending purposes.




Figure 4.10: Surface water management areas of the greater mining right area.

4.7.1 MAP and MAE

The climate data used for the Hydrology study was obtained from the Water Resources of

South Africa, 2005 Study (WR2005), and Water Research Commission Report Numbers TT 380

to 382/08. Please note the data differs from the data discussed in Section 4.3.1 which were

taken from the Parsons Weather Station. The MAP calculated for this area is 357.74mm while

the MAE is 2 351mm. MAE is more than five times greater than MAP; which confirms the arid

nature of the area.

Table 4.11: Mean annual rainfall and evaporation in mm/month

MONTH RAINFALL (MM) EVAPORATION (MM)

Oct 27.13 249.53

Nov 41.49 283.20

Dec 52.81 311.46

Jan 65.65 293.29

Feb 56.41 235.40

Mar 55.66 203.85

Apr 29.67 148.50

May 10.70 111.86



MONTH RAINFALL (MM) EVAPORATION (MM)

Jun 4.36 84.87

Jul 1.97 96.35

Aug 3.40 140.86

Sep 8.49 191.84

Mean Annual 357.74 2351.00

4.7.2 Peak Rainfall

The 24-hour peak rainfall depths were obtained for the site in order to calculate the design

flood peaks. These values were obtained using the Design Rainfall Estimation software

(Smithers, 2000). This software analyses gauged rain data in South Africa and tabulates peak

rainfall depths for various storm durations and return periods. The closest reliable rainfall

station nearby the Khumani area is the Olifantshoek station at Olifantshoek Dam, which has

rainfall and evaporation data records from December 1959 to September 2000. Only this data

was utilised for the study. The 24-hour design rainfall depths used are shown in Table 4.12:

Table 4.12:24-hour design rainfall values

STATION NAME OLIFANTSHOEK

Station Number

Return Period (years) 2 5 10 20 50 100

Design Rainfall (mm) 45 64 77 91 109 124

4.7.3 Mean Annual Runoff (MAR)

The runoff data for the quaternary catchment D41J was extracted from the WR2005 database.

The calculated MAR (for rivers in the region) can be seen in Figure 4.11.



Figure 4.11: Runoff in Regional Rivers

This indicates an MAR equivalent to 0.42mm of runoff over a wide area. It was, however,

considered that on a more local scale, higher values of runoff could be expected. This higher

runoff would not accumulate in rivers and streams, but would tend to infiltrate into the beds

of smaller watercourses. Down-scaled runoff would be expected to be distributed as shown

in Figure 4.12:

Figure 4.12: Runoff into Local Rivers

It is clear that runoff in this area is both rare and directly linked to abnormal rainfall events.

The local runoff simulated equates to a mean of 0.66mm per annum runoff, with monthly

peak values in the order of 2.8mm.

0

0.5

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[m

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Runoff in Region

Oct

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0

0.5

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[m

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Localised Runoff (with restricted mobility)

Oct

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It would seem that these simulated runoff values don't agree with traditional methods used

for estimating peak floods. Simple Rational Method flood calculations indicate up to 27 mm

runoff in a 1.5 hour period that would produce a 1:50 year flood in the areas being developed.

In upstream clean water catchments this runoff is estimated at 24 mm in the same 1.5 hour

period. These higher flood runoff values are accepted for the following reasons:

1. Sandy soils in the region have a limited infiltration rate. It has been seen that with

extreme storm events, where rain falls with a high intensity, a surface layer within

the soil becomes saturated and further rain runs off.

2. It is noted that extreme storm events in the region are often extremely localised and

can occur over an area of 1 km2, or less.

3. Localised runoff peaks are not expected to be mobile and often tend to infiltrate into

the beds of watercourses rather than to flow downstream.

There is little data available on area reduction factors that apply in these extreme arid

conditions and for the purpose of this study, extreme point rainfall and runoff values

expected are applied over the full study area.

4.7.4 Normal Dry Weather Flow (NDWF)

The GaMagara River and the tributaries within the existing and proposed development area

are normally dry and only flow for comparatively short periods after significant rainfall events

(Knight Piesold, 2005). There is thus no NDWF that would be impacted by the LGS extensions.

4.7.5 Downstream water users

There are no significant surface water users downstream of the mine due to the unreliability

of flow in the GaMagara River and its tributaries (Knight Piesold, 2005). Downstream users

(primarily the farming community) rely on groundwater abstraction for livestock watering

and domestic consumption (Knight Piesold, 2005). During a site visit on the 27th of March

2014, mine personnel confirmed that there are no significant surface water users downstream

of the mine area.

4.8 Geohydrology

Information in this section was optained from a Hydrocensus Study and Conceptual model

undertaken by Geo Pollution Solutions Gauteng (Pty) Ltd as part of the detailed

Geohydrological Assessment conducted in September 2011 (Appendix C-3).



4.8.1 General aquifer description



interbedded chert, ironstones, chert breccias, quartzites, conglomerates and shales which

would be indicative of primary and secondary aquifers. Groundwater flow will mainly be in

the form of fracture flow. Porosities vary greatly throughout the lithologies from 1% to 30%.

The dykes in the area that have not been permeated by faulting, form compartments where

water is dammed up and greatly disrupt groundwater flow; this phenomenon is known as

compartmentalisation. The shallow aquifers are of younger age than the dyke structures and

are therefore not intruded by these structures. The implication of this is that the shallow,

unconsolidated sandy aquifers were previously not affected by the dyke structures and water

could flow freely across the top of the dyke structures and the water levels would be more

constant throughout the area. As the water table has now been lowered, the effect of

compartmentalisation has now become relevant.

It is likely that the geohydrological regime in the study area is made up of two aquifer

systems. The first, the upper, semi-confined aquifer occurs in the calcrete or on the contact

between the calcrete and underlying Kalahari clay formation, if the latter is present. This

aquifer is, however, often poorly developed in the study area and only sustains livestock and

domestic water supply. Where thick clay layers are developed in this aquifer, a recharge lag

time to the underlying aquifer(s) often occurs. The second, deeper aquifer is associated with

fractures, fissures and joints and other discontinuities within the older hard rock geology of

the Transvaal Supergroup and associated intrusives. The aquifer occurs at depths of between

20m and 350m or even deeper in the study area. Where the upper aquifer is present, mining

in the BKM mine boundary area will completely destroy it but the dewatering effects of the

aquifer will not be so widespread due to its limited depth. The most significant dewatering

effect as well as contamination, if present, will be on the deeper secondary aquifer with

higher transmissive properties and more dynamic hydraulic properties.

Theoretically, water entering the system will migrate vertically downwards until a perched

aquifer is encountered. As the perched aquifer did not feature very prominently during

drilling, it is likely that the recharging water might be retarded, but the majority will

continue to migrate downwards into the saturated zone. From there it will migrate in the

direction of the hydraulic gradient until it eventually enters surface water bodies (i.e. rivers

or springs) from where it will flow out as surface water.



4.8.2 Hydrocensus

The hydrocensus was mostly conducted in a 12km radius of the mine boundary. The potential

radius of influence on the groundwater regime around an iron ore mine in this area has been

shown from nearby examples to be potentially significant. The radius of influence depends

strongly on geological structures such as faults (preferred groundwater flow paths), and dykes

(horizontal flow barriers), groundwater gradients and nearby mining operations where

dewatering already occurs and the presence of other groundwater production boreholes in

the area. The western side yielded more boreholes along the Gamagara River than on the

eastern side because of the greater abundance of farm owned property on the western side.

The survey was also extended beyond the 12km radius to the SW where the contact zones of

the numerous SW-NE striking dykes could form preferential groundwater flow paths and hence

render this area potentially more prone to dewatering influences. Water levels of the

boreholes located vary from 4.84mbgl (metres below ground level) to 110.8mbgl. The deep

water levels are characteristic of the dewatered areas. Any boreholes where the static water

level could not be measured were excluded from the hydrocensus. This had no influence on

the data, as there were enough boreholes available with easy access to water levels. The

positions of all the boreholes relative to the area are shown in Figure 4.13.

The majority of the boreholes visited were equipped with wind pumps for the supply of

domestic water as well as for livestock watering. No irrigation was noted in the area during

the hydrocensus.


13-843 June 2015 Page 98

(Please refer to Appendix C for the high resolution figure.)

Figure 4.13: Hydrocensus points


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4.8.2.1 Boreholes Visited

There are 80 hydrocensus boreholes. The main characteristics of the hydrocensus data are

summarised in Table 4.14.

4.8.2.2 Groundwater Levels

Water levels of the boreholes located vary from 4.6mbgl (metres below ground level) at

borehole SIS6, Sishen Portion 24 to 86.4mbgl at borehole JKN1 on the farm Jenkins. Deeper

water levels are characteristic of the potentially dewatered areas.

Table 4.13: Groundwater Statistics (2013) YEAR 2013 (MBGL)

Minimum 4.6 (SIS6)

Maximum 86.4 (JKN1)

Average 17.5

Approximately 43% of the boreholes visited were equipped with wind pumps for the supply

of domestic water and/or for livestock watering. No irrigation was noted in the area during

the hydrocensus.

The two boreholes located on Parsons were provisionally equipped with pumps and meters

but were not in use at the time of the investigation.


13-843 June 2015 Page 100

Table 4.14: Summary of hydrocensus (Please refer to Appendix C for the high resolution Table).


13-843 June 2015 Page 101


13-843 June 2015 Page 102

4.8.3 Groundwater Quality

Water was sampled from nine (9) boreholes around the site during the investigation, and

submitted for major cation and anion analyses to determine water quality in the area. These

are the boreholes sampled during November 2013. The results from these analyses are

contained in Table 4.15


13-843 June 2015 Page 103

Table 4.15: Hydrochemistry results for the hydrocensus points.


13-843 June 2015 Page 104

4.8.4 Conceptual model

A conceptual model is a representation of the perceived reality of a given scenario based on

known information/data of that area/scenario. The more information that is known about an

area will result in a better conceptual model. The conceptual model represents the best idea

if how the aquifer works under a specific set of conditions. Developing a good conceptual

model for an area requires that we have detailed information including geology, water

quality, recharge, abstraction in the area, groundwater flow direction, sources, sinks, rivers

in the area, hydraulic parameters and accurate water levels. It must be noted that once a

conceptual model has been developed, it may become obsolete over time as more data are

gathered and a better understanding of the area is gained. The data has its limitations in

terms of lacking data on the northern, south-eastern and eastern areas.

4.8.4.1 Conceptual Model Boundaries

Due to the fact that the dewatering is taking place in shallow as well as deep aquifers the

lateral extent of the dewatering has the potential of having an effect over a considerable

area. The dykes in the area could be partially permeable because of high hydraulic gradients

and faulting creating preferential flow paths across the dykes. A likely boundary in the south

is located on a structure on the farm Macarthy where a spring has formed on the surface. The

location of this spring is S 27.93960 E 23.04245. The spring is reported to be perennial and

has reportedly not ceased flowing for the last 15 years. The total depth from ground surface

to the aquifer ranges from approximately 5 metres to 100 metres. The furthest points away

from the point of dewatering will experience the least effect and therefore least water level

drop.

4.8.4.2 Groundwater Consideration

a. Hydraulic properties



interbedded cherts, ironstones, chert breccias, quartzites, conglomerates and shales which

would be indicative of primary and secondary aquifers. Typical transmissivities will be in the

order of 10 m2/d. Water flow will be in the form of fracture flow in the fractured aquifers

and porous flow in primary aquifer systems.

b. Discharge/Pumping from the aquifer


13-843 June 2015 Page 105

Water is constantly pumped in the area, hence the dewatering. Exact quantities and histories

of pumping are not known, although it is possible to conclude that dewatering commenced

during the 1970s.

c. Flow directions

Due to the extraction taking place in the area it is assumed that the natural conditions no

longer exist. Therefore the general flow direction will be towards the major points of

abstraction in the area. Flow directions will as a rule of thumb follow the topography of the

area.

4.9 Air Quality

The air quality data used was from the previous Khumani EMP Amendment 2011, and from

the Air Quality Gap Analysis undertaken by Prism EMS (Pty) Ltd in 2015

Sources that may contribute to air pollution include, blasting activities associated with the

mining operations, windblown dust from the various mine stockpiles in the area, vehicle

emissions (the N14 runs between the farms Bruce and King), household fuel combustion,

biomass burning (from veld fires and agriculture) and various miscellaneous fugitive dust

sources (agriculture activities, wind erosion of open areas and vehicle entrainment of dust

along unpaved and paved roads).

Sensitive receptor areas in the vicinity of the mine are road users on the N14, the towns of

Olifantshoek and Kathu. In addition, there are various farms and homesteads surrounding the

proposed area.

Dingleton is in the process of being demolished with residents relocated to Kathu, and will

thus not be a sensitive receptor.

Khumani currently has an ambient air and weather monitoring programme that includes

dusfall monitoring, Particulate Matter 10 microns (PM10) and meteorological monitoring. Dust

fallout is measured at:

Eight (8) unique locations using single dust monitoring units (all situated within mine

premises).

Four (4) directional dust monitoring units (DustWatch), that are located at different

locations in order to provide sampling data from four (4) different wind directions,

with the aim of indicating the predominant direction of dust loading in the area.

PM10 monitoring is conducted at:


13-843 June 2015 Page 106

Seven (7) PM10 monitoring locations (E-Samplers manufactured by Met One

Instruments, Inc.) that are located at strategic locations to capture ambient

concentration of particulate matter on mine premises [five (5) instruments are co-

located with dust monitoring points, while two (2) are independent, stand-alone

sites].

Three (3) monitoring locations with handheld instrument (SKC Deployable Particulate

Sampler System with Portable Air Kit for 24-hour sampling) once a month for 24 hours.

A meteorological Station (EM-02-WXT weather station with Vaisala all-weather sensor)

measures temperature, relative humidity, rainfall, hail, barometric pressure, as well as wind

direction, wind speed, and wind gusts via ultrasonic anemometer. The station is located in

the Salvage Yard on the Parsons Farm (coordinates: 27°51'23.05"S; 22°58'34.59"E), east of the

Dingleton Road.

4.9.1 Single Dust Monitoring Units

Khumani introduced their current dust monitoring programme in February 2007 with seven

(7) single dust monitoring units (this coincided with the issuance of the Mining Right and

approved EMP at the end of January 2007, and mechanical erection at the Parsons

Beneficiation Plant that commenced on 9 March 2007), adding a single dust monitoring unit

in June 2009 (as the mine reached its full production capacity of 10 million tons per annum),

and at the same time decommissioning two sites that were located at the future opencast

pits. Two (2) more monitoring sites were commissioned in January 2011, making the current

setup of eight (8) single (unique) monitoring units at present.

The results from single bucket monitoring units were averaged over the calendar year, as

well as over the seasons (quarterly) to establish the contribution of mine to the dust loading

in the mining area. The results were also compared against National Dust Control Regulations

(NDCR) that were published on the 01 November 2013 in the Government Gazette (GG 36974).

The standard states 600mg/m2/day for residential areas and 1 200mg/m2/day for non-

residential areas.

The results for all the single monitoring sites comply with the Dustfall Standard, with

exception of site BKM15, refer to Figure 4.15. Site BKM15 has exceeded the standard for

acceptable dustfall rates for non-residential areas in 2013 – when measured values exceeded

1 200mg/m2/day during May and June, during this time construction activities associated

with the King TFR Mainline Deviation Project was ongoing. Construction activities are now

complete.


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Figure 4.14 Single dust monitoring units (annual average results per site 2007-2014)

0

200

400

600

800

1000

1200

1400

BKM 03 BKM 04 BKM 05 BKM 06 BKM 07 BKM 08 BKM 09 BKM 13 BKM 15 BKM 16

2007

2008

2009

2010

2011

2012

2013

2014

Residential

Non-Residential


13-843 June 2015 Page 108

4.9.2 Directional Dust Monitoring Units

Directional monitoring units (DustWatch) were commissioned in February 2007 at three (3)

locations, while one (1) more unit was commissioned in February 2009, bringing the total for

directional units to four (4).

The results from directional bucket monitoring units (DustWatch) were averaged over the

calendar year, as well as over the seasons (quarterly) to establish the contribution of mine

to the dust loading in the mining area.

The results for all the directional monitoring sites comply with Dustfall Standard, on the

annual average level, refer to Figure 4.16. Monitoring site BKM02 exceeded the non-

residential standard from East South and West sectors in 2012 and East and South sectors in

2013 during the spring season - September, while monitoring site BKM12 exceeded the non-

residential standard during spring season 2013 (September) from three sectors (East, South

and West). Site BKM02 is situated to the south of Mokaning farm and was considered as

background site until middle of 2012, when the construction of the Transnet rail line was

undertaken in the immediate vicinity of the site, thus increasing the dust load to current

elevated levels. Monitoring site BKM12 is located immediately north of the said railway. Old

line section has been de-commissioned and receives most of its dust load from the trains

passing next to it. Even during previous years the results from this site were elevated when

compared with other directional sites.



Figure 4.15 Directional DustWatch dust monitoring units (annual average results per site 2007-2014)

0

200

400

600

800

1000

1200

1400

BKM02 N

BKM02 E

BKM02 S

BKM02 W

BKM11 N

BKM11 E

BKM11 S

BKM11 W

BKM12 N

BKM12 E

BKM12 S

BKM12 W

BKM14 N

BKM14 E

BKM14 S

BKM14 W

2007

2008

2009

2010

2011

2012

2013

2014

Residential

Non-Residential



4.10 Visual

The visual description was from the previous Khumani EIA/EMP as part of the EMP

Amendment 2011.

The semi-arid open nature of the landscape renders it particularly sensitive to visual

intrusion, especially from mining activities or any other surface infrastructure such as the

proposed various infrastructure at Khumani. However, the landscape character and sense of

place is also determined, to a large extent, by the existing mining activities in the region.

The expectation of visitors to the area and those persons travelling along the N14 will

therefore be of a mining area and not a pristine landscape devoid of human intervention.

Trees were planted along the N14, by khumani to aid as a visual screen.

Presently, the Kumba Iron Ore Mine spoil dumps can be seen from distances of 15 to 20 km,

both from the west and east along the N14. Khumani Stockpiles are less visible from a

distance. To the south of the Khumani, along the N14, are extensive areas where mining

activities, both current and past, are evident. These “intrusions” into the landscape

therefore contribute to the sense of place and landscape characteristics of the study area.

4.11 Noise

The noise description was from the previous Khumani EIA/EMP as part of the EMP

Amendment 2011.

The area in which the proposed the proposed infrastructure upgrades are to be established

is characterised by the following environments:

A rural farming community where the farmsteads are located at large distances

apart;

The existing large opencast operation at Kumba;

The existing opencast operation at Khumani; and

The N14 and the railway lines that cross the area.

Areas in the proximity of existing mining activities will already be subjected to the noise

emissions from diesel-powered equipment and other mining processes. However, unless

farmsteads are very close to these sources of noise, the pre-development ambient noise

levels are still expected to be very low.

The major sources of noise from the current mining operations are:



The diesel powered equipment, such as bulldozers, FELs, construction and haul trucks

used during both the construction and operational periods of the mine;

The drilling of rock inside the open pit;

The handling of material inside the pit, e.g. the loading of haul trucks;

The hauling of ore and waste rock from the open pit to the surface;

The dumping of ore and waste rock at the crushing plant and on the waste rock dumps

respectively. During this process the use of reverse warning hooters may be audible

over long distances, particularly during the night;

The crushing and screening of ore in the plant area.

Limited noise may result from the proposed infrastructure, although this may be considered

to be insignificant as the proposed location is already surrounded by mining activities.

4.12 Social Conditions

The data contained in this section of the report was obtained from Quantec Regional Data,

2012 for the John Taolo Getswe District Municipality.

4.12.1 Introduction and approach

When conceptualising a proposal to develop a greenfields mine, the anticipated social and

environmental impacts are generally broad and not limited to one specific area or town. The

proposed expansion project falls within the Northern Cape Province, John Taolo District

Municipality and Gamagara Local Municipality.

In order to assess the potential impact of the proposed project, it is important to consider

the particular Province, district municipalities, and local municipalities as well as the nearby

towns in a holistic way.

4.12.2 Regional Context (John Taolo Gaetsewe District Municipality)

The Northern Cape Province is the largest province in South Africa with a land area the size

of 361 830km2. The province has a population density of two (2) persons per every km2.

Prominent languages include Afrikaans, English, Nama, SeTswana and Xhosa

(www.northerncape.org.za). The Province is divided into 5 DMs. These are again subdivided

into 4 LMs. Major Towns include Calvinia, Colesberg, Kuruman, Springbok and Upington.



The John Taolo District Municipality is divided into the following Local Municipalities:

The Gamagara Local Municipality consists of the following main towns (Statistics SA, 2001):

Refer to Table 4.16 for town area and population numbers.

Table 4.16: Gamagara Local Municipality

PLACE AREA (KM2) POPULATION

Dibeng 8.58 4 023

Dingleton 1.56 2 866

Ditloung 0.62 3 044

Kathu 8.53 8 247

Olifantshoek 3.51 3 985

Remainder 2 449.38 1 048

Source: Statistics SA, 2001

4.12.3 Local Context (Gamagara Local Municipality)

District Municipalities

John Taolo Gaetsewe;

Namakwa;

Pixley ka Seme;

Siyanda; and

Frances Baard.

Local Municipalities

Joe Morolong ;

Ga-Segonyana; and

Gamagara.

Gamagara Local Municipality

Dibeng;

Dingleton;

Ditloung;

Kathu; and

Olifantshoek.

http://en.wikipedia.org/



The Gamagara Local Municipality covers the smallest area in the JTGDM, namely 2 619 km2

(www.kgalagadi.gov.za), and it has the second smallest population size in the area after the

Kgalagadi District Management Area. The primary land use in the municipality is mining and

agriculture with iron ore and manganese being the prime minerals mined in the area and the

main focus of agriculture being on cattle and goats. Game farming and hunting are increasing

in popularity.

The municipal area of Gamagara consists of four towns (Kathu, Debeng, Dingleton

(demolishing) and Olifantshoek), a large farming community and the mining corporations

(Kgalagadi District Municipality, 2007).

4.12.3.1 Demographic Profile

1. Population and Household

According to Figure 4.16, the population size (persons) for the Gamagara District Municipality

increased by 25.47% over the 1995 to 2011 time period, whereas the John Taolo Gaetsewe

District Municipality only grew by 12.49% over the same period. Households have also grown

over the 1995 to 2011 time period, with the Gamagara Local Municipality showing a 30.36%

increase and the John Taolo Gaetsewe District Municipality by 27.23%.



Source: Quantec Research (Pty) Ltd

Figure 4.16: Population and household size (1995 – 2011)

2. Population Group

The Gamagara Local Municipality population are composed of mostly Black African persons

(49.96%) followed by 34.58% Coloured persons. The John Taolo Gaetsewe District

Municipality, however, shows an 87.36% Black African population with a much smaller

percentage of Coloured persons (8.76%). According to the 2011 Statistics SA census, Kathu

(Ward 4) has mainly a Coloured population (58.53%).

The sex ratio is 120,1 males per 100 female, which indicates more males than females

(Statistics South Africa, census 2011)

The main languages that are spoken in the area are: Afrikaans, Setswana and English.



3. Age

It is important to assess the age distribution of persons in order to determine both the current

and future needs of an area. Age is an important indicator as it relates to education, skills

and dependency. A young population may require an improved educational system, whereas

an older society may need an accented focus on healthcare. The largest percentage of people

in the Gamagara Local Municipality, 71.9% fall within the working age category (16-64 years

of age). 25.5% of the population are between the age of 0 and 14. And the elderly population

forms 2.5% of the municipality’s population. (Statistics South Africa, census 2011) Persons

younger than 15 years of age do not form part of the Economically Active Population (EAP)

of the area. The age and sex distribution for the Gamagara Local Municipality is depicted in

Figure 4.17 below.

Figure 4.17 Age and Sex distribution (2011)

4. Education

The largest percentage (89,5%) of the Gamagara Local Municipality population has obtained

some form of primary schooling (Figure 4.18). 24.9% of the population has attained matric

and a further 3.6% with higher education.



Figure 4.18 Education Level (2011)

4.12.3.2 Economic Profile

This section provides a delineation of the study area and a brief economic status quo

pertaining to employment and labour profile.

1. Employment and Labour

The employment status of the population has a variety of important implications.

Economically active and employed persons can contribute to the overall welfare of a specific

community by paying their taxes, looking after the youth and aged and by stimulating the

economy. However, should a community have a large number of economically inactive and /

or unemployed persons, the burden on the EAP of that community are amplified.

Figure 4.19 illustrates that the economic status of the Gamagara Local Municipality. It can

be seen that the largest part of the economically active population in the municipality is

employed. However, unemployment is still high with 22.4% of the youth in the area being

unemployed. (Statistics South Africa, census 2011)



Figure 4.19 Economic Status (2011)

The largest sector of employment in the Local Municipality is the mining sector, supplying

just over a third of the jobs in the area followed by wholesale and retail trade jobs which

make up around 12% of the total employment. The main reason for this distribution are that

the mines in the area, mainly Kumba and Khumani,are the largest employers in the municipal

Area.

The main average income of households in the Gamagara Local Municipality is between

R9,601 and R307,600 as derived from the census 2011 data (see Figure 4.20). It should

however be noted that around 10% of the population in the municipal area do not earn an

income.



Figure 4.20 Average household Income (2011)

2. Services and Infrastructure

Social service delivery centres on the provision of health, education and community

development facilities and services. The concept of service delivery also comprises various

elements such as affordability, quality, efficiency and access.

This indicator therefore examines the level of service provision in the study area. Services

assessed include sanitation, water, housing and electrification. There are three priority

services (water, sanitation and electricity) for the promotion of health, convenience and

quality of life.

a. Housing

According to the 2011 census, almost 75% of the households in the Gamagara municipality

live in formal dwellings. The second largest dwelling group in the municipality are workers’

hostels which can be associated with mining activities. Kumba (Sishen Iron Ore Mine, situated

next to Khumani) is converting its hostels into bachelor flats

(www.northerncapebusiness.co.za). The third largest dwelling type in Gamagara is informal

dwellings that are not in someone’s backyard. These settlements are an indication that

people are coming to the area from other areas to seek employment. Quite often these work

seekers are not successful because most of the jobs have already been filled and they lack

the funds to return home, or they do not earn enough to afford to rent a house or a room in

the area.



b. Energy Use

Figure 4.21 indicates that the use of electricity for lighting, cooking and heating was by far

the highest across all regions. Some gas, paraffin and wood is also used, but these energy

sources are being used less and less, mainly due to the fact that the majority of people live

in formal dwellings.

Figure 4.21 Type of Energy (2011)

3. Water and Sanitation

Figure 4.22 illustrates that 97% of the households in the municipality have access to piped

water inside their residence. With 3% of the households relying on boreholes for water supply.

As for sanitation, 87,6% of the households have flush toilets with a small percentage of

households making use of pit latrines (see Figure 4.23). (Statistics South Africa, Census 2011)



Figure 4.22 Access to Water (2011)

Figure 4.23 Access to Sanitation (2011)

.



5 PUBLIC PARTICIPATION PROCESS



Regulation 31 (2)

2 e) Details of the public participation process conducted in terms of the subregulation (1),including:

i. Steps undertaken in accordance with the plan of the study;

ii. A list of persons, organizations and organs of state that were registered as

interested and affected parties;

iii. A summary of comments received from and a summary of issues raised by

interested and affected parties, the date of receipt of these comments and the

response of the EAP to these comments; and

This section of the report further documents the process, which were followed to date with

respect to consultation of I&APs, stakeholders and the Government Authorities (Refer to

Appendix B).

5.1 Purpose of Public Participation

The Public Participation Process (PPP) is a requirement of the EIA/EMP process and ensures

that all relevant I&APs are consulted. The process ensures that all stakeholders have an

opportunity to raise their comments as part of an open and transparent process, which in

turn ensures for a complete comprehensive environmental study.

The purpose of PPP and the engagement process is to:

Introduce the proposed project;

Explain the EIA/EMP and PPP processes to be undertaken;

Determine and record public issues and concerns;

Provide opportunities for public input and gathering of local knowledge;

Inform a broad range of stakeholders about the project and the environmental

process to be followed;

Establish lines of communication between stakeholders and the project team;

Identify all the significant issues in the project; and

Identify possible mitigation measures or environmental management plans to

minimise and/or prevent environmental impacts, associated with the project.

Once the concerns of I&APs have been established, the EIA phase of the project will address

these concerns.



5.2 List of Authorities Consulted

The following Authorities have been identified and invited to become involved in the process

to date:

National Government Authorities:

Department of Water Affairs (DWA).

Department of Mineral Resources (DMR).

Provincial Government Authorities:

Department of Environment and Nature Conservation (NCDENC);

Department of Transport, Roads and Public Works;

Provincial Administration Northern Cape.

Catchment Agency:

Tshiping Water Users Association

District Municipalities:

ZF Mcgawu Districts Municipality;

John Taolo Gaetsewe District Municipality.

Local Municipalities:

Tsantsabane Local Municipality.

Gamagara Local Municipality

Other Authorities:

Transnet;

South African National Parks;

The Wildlife and Environment Society of South Africa (WESSA); and

The South African Heritage Resource Agency (SAHRA).

The reasons for the inclusion of Authorities in the consultation process are the following:

Inform the Authorities of the proposed activities at the Khumani;

Inform and discuss the projected timeframes of the project;

Determine the technical issues associated to the project;

Understand the concerns of the Authorities; and

Highlight the importance of the Authorities’ input in the EIA / EMP process.

Refer to Appendix B for proof of consultation report.

5.3 Scoping Phase



5.3.1 Identification of I&APs

A comprehensive list of I&APs who have been previously contacted for previous Khumani

projects has been updated by GCS through a process of networking, newspaper

advertisements and site notices.

5.3.2 Notification of Stakeholders

5.3.2.1 Site Notice

Site Notices were placed at the entrance to Khumani and at other key areas to inform the

public of the proposed development and its associated infrastructure. Refer to Appendix B

for proof of site notices.

5.3.2.2 BID

A Background Information Document (BID) (Refer to Appendix B) was sent to all I&APs by

means of email, fax and or post. The BID was compiled in English and it included details of

the proposed development, vital to the EIA process. The BID also included relevant contact

details and a comment/registration sheet for I&APs to complete. I&APs were invited to

register and send responses, by fax, telephone or email to GCS (Please refer to Appendix B

for a copy of the BID).

5.3.2.3 Advertisements

An advertisement regarding the proposed project, including background information, the

assessment process being followed was placed in the DFA newspaper, on 17 September 2014

(refer to Appendix B for a copy of the advertisement).

An advertisement was placed on the DFA newspaper notifying the I&APs on the availability

of the draft Environmental Scoping Report (ESR) on Friday, 31 October 2014. An additional

advertisement was placed in the Volksblad and Kathu Gazette on the 15th of May 2015, as

notification of the inclusion of the Dump expansion on the Farm Bruce.

5.3.3 Availability of Reports

The draft ESR was made available for public review and comments for a 40 day period from

23 October 2014 until 28 November 2014. The report was made available on the GCS Website,

www.gcs-sa.biz. I&APs were notified of the availability of the draft report via emails, faxes

and letters. Refer to Appendix B for proof of notification letters sent to I&APs. The draft ESR




was updated to a final version and was submitted to the competent authority for review on

the 12th of December 2014. No comments were received on the draft Scoping report from

I&APs.

An addendum to the ESR which served to include the expansion of the Dump on the farm

Bruce was submitted on the 15th of May 2015 for consideration by the department before

continueing with the EIA.

The draft EIA/EMP will be made available to all registered stakeholders for the required

public review period.

5.4 EIA Phase

5.4.1 Advertisements

An advertisement regarding the availability of the Final EIA/EMP reports will be placed in the

Kathu Gazette and Volksblad, (refer to Appendix B for a copy of the advertisement).

Availability of Reports

The draft EIA/EMP will be made available to all registered stakeholders on the Khumani

Project for the required public review period.



6 ENVIRONMENTAL MANAGEMENT GOALS AND OBJECTIVES

This section of the report relates to Section 33 of the GNR543 published in Government


REGULATION 33

c) A detailed description of the aspects of the activity that are covered by the draft environmental

management programme

k) Where appropriate, closure plans, including closure objectives.

6.1 Activities

Before the potential environmental impacts posed by the Khumani infrastructure and

stockpile upgrades can be identified, the activities associated with the establishment,

operation and decommissioning must first be identified.

The proposed infrastructure upgrades are described in detail in Section 2 of this EIA/EMP

report. The main activities which will create impacts during the different phases of the mine

life cycle were assessed during the impact assessment phase, and mitigation and management

measures proposed accordingly (Section 7). The main activities that were assessed are

summarised in Figure 6.1.



Figure 6.1: Proposed Activity Flowchart

6.1.1 Pre-Construction Phase

The applicant commits to obtain all necessary environmental authorisations from the relevant



After the Pre-Construction Phase has been finalised, the applicant will commence with the

Construction Phase for their mining activities and project related infrastructure in line with

their approved environmental authorisations. The activities anticipated in the Construction

Phase include:

Land and footprint clearance;

Topsoil stripping and stockpiling;

Establishment of surface infrastructure;

Waste handling; and

Dust suppression.




After the Construction Phase has been finalised, the applicant will commence the Operational

Phase. The applicant will commence with the Operational Phase of their activities in line

with their approved environmental authorisations. The activities anticipated in the

Operational Phase include:

Stockpiling ROM and low grade material;

Stockpiling overburden;

Processing of low grade material;

Transporting of material via conveyor;

Control of clean/dirty water separation;

Generation and handling of waste;

Hydrocarbon storage; and

Dust suppression.

6.1.4 Closure and Decommissioning Phase

Closure phase will be in line with approved EMP for mine closure. The infrustucture will be

decommissioned at the end of life of mine. The activities anticipated in the Closure and

Decommissioning Phase includes:

Removal of surface infrastructure; and

Active surface rehabilitation of disturbed areas.

Closure for mining activities is highly important as far as the environmental factors are

concerned. If mitigation measures are not followed properly it could have significant

negative impacts. As closure without mitigation factors could have a permanent effect on

the area and its surrounds.

The mine will be required to apply for a Closure Certificate according to Section 43 of the

MPRDA. Section 43 (1) of the MPRDA stated that “the holder of a … mining right …remains

responsible for any environmental liability, pollution or ecological degradation, and the

management thereof, until the Minister has issued a closure certificate to the holder

concerned”.

6.1.5 Post-Closure Phase



After the Closure and Decommissioning Phase has been finalised, the applicant will

commence with the Post-Closure Phase of their mining activities in line with their approved

EMP. The activities anticipated in the Post-Closure Phase include:

Residual impacts post closure;

Monitoring of surface and groundwater;

Monitoring of air quality; and

Annual performance assessments of closure goals.

6.2 Environmental Management Objectives


6.2.1.1 Land Clearance, Soil Stripping and Stockpiling

The environmental objectives associated with land clearance and removal of vegetation for

construction purposes are:

Understand the ecological characteristics of the area in which the mine is located,

implement an ecological (fauna and flora) rescue programme and establish an off-set

area;

To limit activities to the indicated and approved areas to ensure that no additional

land surface, vegetation and habitats outside of the project area are destroyed,

disturbed and/or alienated;

To avoid ecological sensitive areas as far as practically possible;

Delineate ecological sensitive (no-go) zones prior to construction taking place and

remain outside of these areas;

To investigate opportunities for offsetting (tying into the Provincial Conservation

Plan) where avoidance of sensitive areas is not possible;

Removal of weeds and other invasive species over the project area;

To prevent any cumulative impact associated with the removal of vegetation and

footprint clearance;

To reduce the dust dispersion as a result of the removal of earth material as far as

possible;

To ensure an effective surface run-off control system is in order from the

commencement of the construction activities to deal with the separation of clean

and dirty water;

To ensure that the necessary approvals are in-place should any red-data or protected

species be relocated or removed;



To strictly manage the activities taking place within the project areas by

implementing clear and effective ground rules;

Actively drive the process of the establishment of the Offset Area; and

To rehabilitate the area as per the closure objectives in order to address all

environmental impacts as far as possible and practical.

6.2.1.2 Establishment of Infrastructure and stockpiles

The environmental objectives associated with the establishment of infrastructure associated

with this project are:

To remain within the approved project scope and area; take care that no additional

land surface, vegetation and habitats outside of the project area are destroyed,

disturbed and/or alienated;

To ensure that the area over which the infrastructure will be placed is stable;

To ensure that the placement of infrastructure will not sterilize any potential future

mining reserves;

To prevent any cumulative impact associated with the removal of vegetation and

topsoil;

To manage any other nuisance dust which may occur as a result of the establishment

of new infrastructure;

To accommodate the use of natural material and colours where possible to reduce

the potential visual impact on the surrounding area; and



6.2.1.3 Waste handling

The objectives for waste generation and handling of domestic, diesel and chemical storage

are to:

Ensure that storage takes place in such a manner as not to cause any pollution to the

environment;

Ensure that temporary storage facilities comply with best practice guidelines;

Prevent any pollution of water resources by ensuring that an effective surface runoff

control system is in place;

Prevent, contain and clean up any spillages; and

Ensure that all facilities are monitored on a regular basis.




6.2.2.1 Low Grade Stockpiles, ROM Stockpile and Overburden stockpiling

The objective set for stockpiling activities are to:

Minimise spills from trucks and/converyors;

Minimise contamination of natural water resources;

Minimise dust generated from the stockpiles; and

Ensure that no other areas are disturbed except for the appoved areas.

6.2.2.2 Reworking Strategy

The objectives set for the reclaiming activities are to

Optimally rework all low grade material on the site;

Plan the reworking activities in a systematic manner to work towards ongoing

rehabilitation and closure;

Replace discard material from the reworking facilities on an approved and already

disturbed footprint area in a planned manner to enhance the philosophy of ongoing

rehabilitation.

6.2.2.3 Operation of Clean and Dirty Water Systems and Stormwater Management Systems

The objectives set for the clean and dirty water systems are:

To maintain all pollution control systems in such a manner as to reduce any possibility

of dirty water entering the stormwater management systems;

To operate the mine in a closed water circuit;

To ensure compliance to all best practices in terms of the operation of the

stormwater management systems;

To maintain the integrity of the stormwater management systems, including the

berms, bunds, drains;

To ensure that all dirty water systems are cleaned and maintained on a regular basis

to prevent pollution of the water resources and where pollution prevention is not

possible, to minimise the impact on water sources (ground and surface);

Implement the requirements of Water Use License or the DWS Best Practice

Guidelines where applicable;

To achieve overall legal compliance; and





6.2.2.4 Hydrocarbon Storage

The environmental management objectives for hydrocarbon storage are:

To ensure that all hydrocarbons are stored in a manner which will prevent any harm

to the environment;

To prevent spillages of hydrocarbons;

To capture, contain and manage any spillage; and

To ensure that any area which has been affected by a hydrocarbon spill is suitably

rehabilitated and monitored until rehabilitation efforts have been successful.

6.2.3 Closure and Decommissioning

6.2.3.1 Aftercare, Monitoring and Maintenance

The objectives for aftercare, monitoring and maintenance are to:

Ensure that monitoring takes place until rehabilitation measures are considered

successful.



7 IDENTIFICATION OF IMPACTS AND CONCERNS WITH MANAGEMENT MEASURES AND ACTION PLANS

This section of the report relates to Section 31 (2) and 33 of the GNR543 published in

Government Gazette No.33306 of 18 June 2010, under Section 24(5) of the NEMA.

Regulation 31 (2)

2 g) A description of identified potential alternatives to the proposed activity, including

advantages and disadvantages that the proposed activity or alternatives may have on the

environment and the community that may be affected by the activity.

2 h) An indication of the methodology used in determining the significance of potential

environmental impacts

2 j) A summary of the findings and any recommendations of any specialist report or a report

on a specialized process

2 k) A description of all environmental issues that were identified during the environmental

impact process, an assessment of the significance of each issue and an indication of the

extent to which the issue could be addressed by the adoption of mitigation measures

2 l) An assessment of each identified potentially significant impact including:

i. Cumulative impacts;

ii. The nature of the impact;

iii. The extent and duration of the impact;

iv. The probability of the impact occurring;

v. The degree to which the impact can be reversed;

vi. The degree to which the impact can cause irreplaceable loss of

resources and ;

vii. The degree to which the impact can be mitigated.

2 p) A draft Environmental Management Programme containing the aspects contemplated

in regulation 33

Regulation 33

b) Information on any proposed management or mitigation measures that will be taken to

address the environmental impacts that have been identified in a report contemplated by

these regulations, including environmental impacts or objects in respect of :

i) Planning and designing;

ii) Pre Construction and construction activities;

iii) Operation or undertaking of the activity;

iv) Rehabilitation of the Environment; and

v) Closure, where relevant

c) A detailed description of the aspects of the activity that are covered by the draft

environmental management programme



d) An identification of the persons who will be responsible for the implementation of the

measures contemplated in paragraph (b)

f) As far as is reasonably practical, measures to rehabilitate the environment affected by

the undertaking of any listed activity or specified activity to its natural or predetermined

state or to a land use which conforms to the generally accepted principal of sustainable

development ,including ,where appropriate, concurrent or progressive rehabilitation

measures

g) A description of the manner in which it intends to :

i) Modify, remedy, control or stop any action, activity or process which causes

pollution or environmental degradation;

ii) Remedy the cause of pollution or degradation and migration of pollutants;

iii) Comply with any prescribed environmental management standards or practices;

h) Time periods within which the measures contemplated in the environmental management

programme must be implemented

i) The process for managing any environmental damage, pollution, pumping and treatment

of extraneous water or ecological degradation as a result of undertaking a listed activity


The pre-construction phase has been included as a project phase, to afford the applicant

sufficient time to address all the environmental authorisations required for the proposed

operation (i.e. in terms of the MPRDA, NEMA and NWA), as well as to address other regulatory

requirements. In addition the development of various management plans, action plans and

identification of potential services providers will also be undertaken during this phase.

Khumani commits to obtain all necessary environmental authorisations from the relevant

government departments, before undertaking any construction activities. Khumani also

commits to obtaining the rezoning classification before any construction or operational

activities commence. Finally, Khumani commits to developing site specific action plans

and management plans to address all identified environmental impacts.

7.1 Environmental Impact Assessment Methodology

To ensure uniformity, the assessment of potential impacts was addressed in a standard

manner so that a wide range of impacts is comparable. The ranking criteria and rating scales

was applied to all specialist studies for this project.



Each impact identified was assessed in terms of probability (likelihood of occurring), scale

(spatial scale), magnitude (severity) and duration (temporal scale). To enable a scientific

approach to the determination of the environmental significance (importance), a numerical

value is linked to each rating scale.

The following criteria were applied to the impact assessment for the EIA/EMP:

Occurrence

Probability of occurrence (how likely is it that the impact may occur?); and

Duration of occurrence (how long may impact last?).

Severity

Magnitude (severity) of impact (will the impact be of high, moderate or low

severity?); and

Scale/extent of impact (will the impact affect the national, regional or local

environment, or only that of the site?).

Status of Impact

+: Positive impact

-: Negative impact

N: Neutral (no impact)

The process presented in Figure 7.1 shows the process followed during the impact

assessment.

Figure 7.1: Process for impact assessment.

In order to assess each of these factors for each impact, the ranking scales in Table 7.1 are

used.



Table 7.1: Ranking Scales used in Impact Assessment.

Status of Impact

+: Positive (A benefit to the receiving environment)

N: Neutral (No cost or benefit to the receiving environment)

-: Negative (A cost to the receiving environment)

Probability:=P

5 – Definite/don’t know

4 – Highly probable

3 – Medium probability

2 – Low probability

1 – Improbable

0 – Not applicable/none/negligible

Duration:=D

5 – Permanent

4 - Long-term (ceases with the operational life)

3 - Medium-term (5-15 years)

2 - Short-term (0-5 years)

1 – Immediate

0: Not applicable/none/negligible

Scale:=S

5 – International

4 – National

3 – Regional

2 – Local

1 – Site only

0 – Not applicable/none/negligible

Magnitude:=M

10 - Very high/don’t know

8 – High

6 – Moderate

4 – Low

2 – Minor

0: Not applicable/none/negligible

Once the above factors had been ranked for each impact, the environmental significance of

each was assessed using the following formula:

SP = (magnitude + duration + scale) x probability

Once the formula has been applied, the impact significance ratings (Table 7.2) are applied.

Table 7.2: Impact Significance Ratings

SIGNIFICANCE ENVIRONMENTAL SIGNIFICANCE POINTS COLOUR CODE

High (positive) >60 H

Medium (positive) 30 to 60 M

Low (positive) <30 L

Neutral 0 N

Low (negative) >-30 L

Medium (negative) -30 to -60 M

High (negative) <-60 H

The flow chart of activities that were assessed was provided previously in Figure 6.1.



7.2 Pre-Construction Phase

The applicant commits to obtain all necessary environmental authorisations from the relevant


No impact assessment is undertaken for the pre-construction phase as the activities

assessed are all process related.

7.3 Construction Phase

After the Pre-Construction Phase has been finalised, the applicant will commence with the

Construction Phase for their infrastructure and upgrades in line with their approved

environmental authorisations.

7.3.1 Geology

No direct impacts on geology are anticipated. Indirect impacts on the geology are anticipated

due to the locality of the new low grade stockpile expansion area on the farm Parsons. The

mining rights on the farm Parsons are not owned by Assmang but by Khumba Iron Ore Mine.

Agreements are in place between the two companies to allow Assmang to construct and utlise

the farm Parsons for operational activities.

7.3.2 Climate

No direct or indirect impacts on the climate are anticipated during the construction phase.

7.3.3 Topography

Impacts associated with topography as a result of construction include:


topsoil stripping and stockpiling, infrastructure establishment.

7.3.4 Soils, Land Use and Land Capability

Impacts on the soils, land use and land capability of the mining area as a result of construction

activities include:

Direct impact: loss of topsoil (soil stripping) in preparation for the construction

phase;




hydrocarbon spillages and/or leaks; and

Indirect impact: dust fallout as a result of exposed surfaces and vehcilular movement

on site.

This activitiy / impact will result throughout the life of mine as the facility increases.

7.3.5 Heritage and Sites of Cultural Significance

No direct or indirect impacts are anticipated.

7.3.6 Hydrology

Impacts on hydrology of the mining area as a result of construction activities include:

Direct impact: vegetation and topsoil clearance could obstruct drainage, cause

waterlogging and pollute water resources and reduce runoff to the river systems;

Direct impact: hydrocarbon spillages from equipment utilised in construction

activities could lead to the contamination of water resources;; and

Indirect impact: water quality and quantity deterioration due to changes in the

surface water regime.

The proposed construction activity is not likely to have any measurable impacts on local

surface water resources or water availability to other local water users.

7.3.7 Geohydrology

Impacts on geohydrology of the mining area as a result of construction activities include:

Direct impact: reduction in groundwater recharge, due to the compaction of surfaces

and the establishment of permanent infrastructure.

Accidental spillages from the bulldozers and trucks clearing the site are possible. Baseline

monitoring during this period should continue to ensure sufficient data is available to

evaluate the difference in natural trends and any changes occurring during the operational

phase.

7.3.8 Biodiversity

Impacts on biodiversity of the mining area as a result of construction activities include:




topsoil removal and vegetation disturbance;

Direct impact: displacement of faunal species and human/animal conflict during site

preparation activities; and

Indirect impact: loss of ecological connectivity and ecosystem functioning.

7.3.9 Air Quality

Impacts on air quality of the mining area as a result of construction activities include:

Direct impact: dust fallout from topsoil removal and vegetation removal; and

Indirect impact: emissions to air by vehicles will occur due to vehicles operating on

site.

Impacts associated with the dust emitting activities within the mine boundary (vehicle

movement and stockpiling) may be significant without mitigation and so every effort should

be made to mitigate against any fugitive emissions from these sources in order to protect

mine personnel from occupational exposure to dust.

7.3.10 Visual

Impacts on visual aspects of the mining area as a result of construction activities include:

Direct impact: soil stripping and footprint clearance will impact the perceptions of

people travelling past site and staying/working near the site.

The significance of visual impact associated with the surface infrastructure during the

construction phase will be moderate - low, and can be minimised to a low impact provided

recommended mitigation measures are successful.

7.3.11 Noise

Impacts on the noise environment of the mining area as a result of construction activities

include:

Direct impact: increased noise due to increased vehicular movement on site.

During construction there will be increase noise on the mine, however since the mine is in

full operation, this additional noice will have a medium significance without mitigation. With

mitigation the noise levels will decrease to a low impact.



7.3.12 Social

There will be no direct or indirect social impacts during construction.

7.3.13 Wetlands

Impacts on the wetlands of the mining area as a result of construction activities include:


7.3.14 Construction Phase Impact Assessment

Table 7.3 details the identified impacts and management measures for the construction

phase activities.



Table 7.3: Impacts and Management Measures for Construction Phase Activities.

POTENTIAL ENVIRONMENTAL IMPACT

ACTIVITY INFRASTRUCTURE

AREA

ENVIRONMENTAL SIGNIFICANCE

BEFORE MITIGATION

RECOMMENDED MITIGATION MEASURES


AFTER MITIGATION

ACTION PLAN PHASE PERSON ANNUAL MANAGEMENT

COST

M D S P

TO

TA

L

ST

AT

US

SP M D S P

TO

TA

L

ST

AT

US

SP

INFRASTRUCTURE DEVELOPMENT AREAS: 1. OVERBURDEN AREA 2. STOCKPILE AREAS 3. NEW INFRASTRUCTURE AREA

CONSTRUCTION PHASE ACTIVITIES: 1. LAND & FOOTPRINT CLEARANCE 2. TOPSOIL STRIPPING AND STOCKPILING 3. ESTABLISHMENT OF NEW INFRASTRUCTURE 4. UPGGRADE OF EXISTING INFRASTRUCTURE 5. WASTE HANDLING 6. DUST SUPPRESSION

GEOLOGY

No direct or indirect impacts anticipated.

1, 2, 3, 4 & 5

1, 2 & 3 0 0 0 0 0 N N No mitigation necessary. 0 0 0 0 0 N N N/A N/A N/A N/A

TOPOGRAPHY

Direct impact: alteration of topography

1, 2, 3, 4 & 5

1 & 2 6 4 3 3 39 - M

Demarcate footprint area clearly Minimise site clearance to the footprint area only

6 4 2 2 24 - L All areas are to be dermacted clearly. All construction must take place within designated areas.

Construction Environmental Officer

Included in construction costs

SOILS, LAND USE AND LAND CAPABILITY

Direct impact: loss of topsoil

1, 2, 3, 4 & 5

1, 2 & 3 10 5 1 5 80 - H

Minimise the stripping footprint as far as possible. Tosoil should be stripped where infrastructure is placed and site clearance take place

10 5 1 5 80 - H Ensure that soil management methods are communicated and implemented by contractors and staff.



Direct impact: soil compaction

1, 2, 3, 4 & 5

1, 2 & 3 4 4 1 2 18 - L

Avoid clearance and earthworks after heavy rain. Drive only on approved roads

2 4 1 1 7 - L Adhere to Soil Stripping, Soil Stockpiling and Soil Management Plan Implement Vehicle Operating Plan

Constuction Environmental Officer


Direct impact: soil erosion

1, 2, 3, 4 & 5

1, 2 & 3 6 4 1 3 33 - M

Demarcate the footprint area clearly. Manage storm water flow with temporary erosion control measures where possible (cut-off trenches or berms). Schedule construction as soon as possible after site clearing.

4 4 1 2 18 - L

Adhere to Stormwater Management Plan Ensure that all design drawings include effective erosion control measures. Ensure the required erosion protection measures are monitored and corrected where necessary.







AREA


BEFORE MITIGATION



AFTER MITIGATION


COST

M D S P

TO

TA

L

ST

AT

US

SP M D S P

TO

TA

L

ST

AT

US

SP



Direct impact: soil contamination

1, 2, 3, 4 & 5

1, 2 & 3 6 2 1 5 45 - M

Store solid waste in approved waste disposal area. Remove waste regularly (approved contractor). Chemicals and fuels to be stored in bunded areas. Vehicles to be correctly maintained to prevent oil leakages and in the approved workshop areas on either Parson, Bruce or King area. Any hydrocarbon spills to be cleaned immediately. Significant spills should be reported to the regulatory authorites withn 24 hours and a clean up strategy should be formulated.

4 2 1 2 14 - L

Adhere to Waste Storage and Handling Plan Adhere to Spill Management Plan Adhere to the Emergency procedures Report and implement spill clean-up uprocedures



HERITAGE


1, 2, 3, 4 & 5

1, 2 & 3 0 0 0 0 0 - N N/A 0 0 0 0 0 - N N/A N/A N/A N/A

HYDROLOGY

Direct imact: Vegetation and topsoil clearance could obstruct drainage, cause water to stand in some areasand pollute water resources

1, 2, 3, 4 & 5

1, 2 & 3 4 4 2 3 30 - M

Rehabilitate open areas as soon as practically possible. Vegetate open areas as soon as practically possible. Only remove vegetation within demarcated areas. Manager stormwater systems and runoff.

4 2 2 2 16 - L

Adhere to Storwater Management Plan Implement the surface water-monitoring programme to prevent, manage and monitor potential erosion. Construct the required erosion protection measures. Adhere to Rehabilitation Plan



Direct impact: Contamination of water resources due to hydrocarbon spillages

1, 2, 3, 4 & 5

1, 2 & 3 6 3 3 3 36 - M

Ensure clean and dirty water separation Implement immediate spill clean-up procedures Undertake emergency water monitoring Notify water users of potential pollution immediately Inform relevant authority immediately

4 3 2 2 18 - L Adhere to Stormwater Management Plan Adhere to Water Quality Monitoring Plan Adhere to Spill Management Plan







AREA


BEFORE MITIGATION



AFTER MITIGATION


COST

M D S P

TO

TA

L

ST

AT

US

SP M D S P

TO

TA

L

ST

AT

US

SP



Indirect impact: pollution of water resources

1, 2, 3, 4 & 5

1, 2 & 3 10 3 3 3 48 - M

Fix damaged stormwater management structure Implement immediate spill clean-up procedures Notify water users of potential pollution immediately Inform relevant authority in terms of the conditions of the license

6 2 2 2 20 - L Adhere to Stormwater Management Plan Adhere to Water Quality Monitoring Plan Adhere to Spill Management Plan



Indirect impact: water quality deterioration

1, 2, 3, 4 & 5

1, 2, 3, 4, 5 & 6 10 3 3 3 48 - M

Ensure stormwater management on site Undertake water quality monitoring Notify water users of potential pollution immediately Inform relevant authority immediately Update the groundwater model to include the new stockpiles in a time series Undertake a waste classification on the low grade material to establish the waste type and disposal requirements in terms of the relevant Norms and Standards.

4 2 2 2 16 - L

Adhere to Stormwater Management Plan Adhere to Water Quality Monitoring Plan Adhere to Spill Management Plan Waste charcaterisation and Classification of all residue stockpiles (i.e. low grade stockpiles and paste disposal material)



GROUNDWATER


1, 2, 3, 4 & 5

1, 2 & 3 0 0 0 0 0 - N N/A 0 0 0 0 0 - N N/A N/A N/A N/A

TERRESTRIAL BIODIVERSITY (FAUNA AND FLORA)

Direct impact: Loss of floral species of conservation importance

1, 2, 3, 4 & 5

1, 2 & 3 10 4 2 4 64 - H

Minimise the area to be cleared. Identify important species in the footprint areas. Conduct detailed, multi-seasonal walk-through prior to construction activities. Compile list of protected and Red Data species. Develop relocation programme if possible, or invest ruther into the current nursery on site. Apply for relevant permits with authorities prior to the

10 4 2 3 48 - M

Adhere to Biodiversity Conservation Plan Adhere to Alien and Invasive Vegetation Management Plan Adhere to Flora and Fauna Relocation Programme Built onto the existing nursery on site and the tree planting strategy







AREA


BEFORE MITIGATION



AFTER MITIGATION


COST

M D S P

TO

TA

L

ST

AT

US

SP M D S P

TO

TA

L

ST

AT

US

SP



removal of protected plant species. Develop an offset area action plan which should be signed of by the NCDENC

Direct impact: Loss of fauna species of conservation importance

1, 2, 3, 4 & 5

1, 2 & 3 8 4 2 5 70 - H

Minimise the area to be cleared. Identify important species in the footprint areas. Develop relocation programme. The importance to finalise and conclude the current Offset Area process must be emphasised. Implement biodiversity offset principles (if necessary).

6 5 2 4 52 - M

Develop a timeframe and programme for the finalisation of the Offset Area and keep track of the process with feedback to commenting stakeholders. It is important to take cognisance of the increase in footprint disturbance on the mine when finalising the Offset Area footprint requriements. Note, that the focus should be on the residual footprint, which should therefore assess what volume of residue stockpile will remain after reworking has completed. Adhere to Alien and Invasive Vegetation Management Plan Adhere to Biodiversity Offset Plan Adhere to Flora and Fauna Relocation Programme



Direct impact: Displacement of faunal species and human/animal conflict

1, 2, 3, 4 & 5

1, 2 & 3 4 4 2 5 50 - M

Identify a protocol that will allow for protection of animals during construction phases, this should include no hunting and/or poaching of animals. Implement awareness programmes.

4 4 2 4 40 - M Adhere to Environmental Awareness Programme







AREA


BEFORE MITIGATION



AFTER MITIGATION


COST

M D S P

TO

TA

L

ST

AT

US

SP M D S P

TO

TA

L

ST

AT

US

SP



Direct impact: Loss of ecological connectivity and ecosystem functioning

1, 2, 3, 4 & 5

1, 2 & 3 6 4 2 5 60 - M

Minimise the area to be cleared. Identify important species in the footprint areas.

4 4 2 4 40 - M

Develop a timeframe and programme for the finalisation of the Offset Area and keep track of the process with feedback to commenting stakeholders.



AIR QUALITY

Direct impact: dust-fallout

1, 2, 3, 4 & 5

1, 2 & 3 4 1 2 4 28 - L

Dust monitoring by means of single dust buckets in the eight major wind directions should be continued. A workable system to monitor PM10s’ should be implemented. Minimise dust liberation by watering/wetting surfaces Monitoring of fence-line fallout dust Treating of haul roads with dust retardant Strictly enforced speed limits on haul roads Limiting of transfer of material

2 1 1 4 16 - L

Implement dust monitoring progamme in terms for the Dust Montiroing Gap Analysis undertaken by Prism EMS during 2014. Strictly enforced speed limits on haul roads Dust suppression to be implemented as per the approved EMP and subsequent dust monitoring studies where these have improved the monitoring protocol.



Direct impact: vehicle entrained dust

1, 2, 3, 4 & 5

1, 2 & 3 4 1 2 4 28 - L

Dust monitoring Minimise dust liberation by watering/wetting surfaces Treating of haul roads with dust retardant to limit the use of water as a dust suppressant.

2 2 1 2 10 - L Adhere to Dust Fallout Management Plan Strictly enforced speed limits on haul roads



Indirect impact: emissions to air by vehicles

1, 2, 3, 4 & 5

1, 2 & 3 4 1 2 4 28 - L Monitor vehicular emissions Dust supression and speed control

2 2 1 2 10 - L Implement a Vehicle Maintenance Plans All vehicles must services regurlarly during th construction phase



VISUAL





AREA


BEFORE MITIGATION



AFTER MITIGATION


COST

M D S P

TO

TA

L

ST

AT

US

SP M D S P

TO

TA

L

ST

AT

US

SP



Direct impact: soil stripping and footprint clearance

1, 2, 3, 4 & 5

1, 2 & 3 4 4 2 4 40 - M

Minimise the stripping footprint to only cover the areas to be cleared and stripped Limit vegetation loss

4 4 1 3 27 - L

Adhere to Soil Stripping, Soil Stockpiling and Soil Management Plan Adhere to Visual Screening Plan (tree planting strategy)



NOISE

Direct impact: vehicular movement

1, 2, 3, 4 & 5

1, 2 & 3 4 2 2 5 40 - M

Implement acoustic screening measures such as the planting of endemic tree species as is currently being undertaken by the mine, similar to the intitiative by the mine along the N14 on Parson Farm Undertake regular vehicle maintenance and keep records of such monitoring Undertake noise monitoring

4 1 2 2 14 - L Adhere to Provincial Noise Regulations Adhere to Noise Management Plan Adhere to Vehicle Maintenance Plans



Direct impact: construction

1, 2, 3, 4 & 5

1, 2 & 3 6 4 2 5 60 - M

Implement acoustic screening measures such as the planting of endemic tree species as is currently being undertaken by the mine, similar to the intitiative by the mine along the N14 on Parson Farm. Utilise only state of the art equipment Undertake noise monitoring

4 4 1 2 18 - L Adhere to Provincial Noise Regulations Adhere to Noise Management Plan



SOCIAL


1, 2, 3, 4 & 5

1, 2 & 3 0 0 0 0 0 - N N/A 0 0 0 0 0 - N N/A N/A N/A N/A

WETLAND

Direct impact: wetland destruction

3 2 6 5 3 5 70 - H

No mitigation possible. The low grade stockpile encrouches the pans. The pans will be permanently destroyed.

6 5 3 5 90 - H

Develop a timeframe and programme for the finalisation of the Offset Area and keep track of the process with feedback to commenting stakeholders. It is important to take cognisance of the increase in footprint disturbance on the mine when finalising the Offset Area footprint requriements. Note,

N/A N/A N/A





AREA


BEFORE MITIGATION



AFTER MITIGATION


COST

M D S P

TO

TA

L

ST

AT

US

SP M D S P

TO

TA

L

ST

AT

US

SP



that the focus should be on the residual footprint, which should therefore assess what volume of residue stockpile will remain after reworking has completed. Adhere to Alien and Invasive Vegetation


3 1 10 3 3 3 48 - M

Maintain stormwater management structures Implement immediate spill clean-up procedures Undertake emergency water monitoring Notify water users of potential pollution immediately Inform relevant authority immediately

6 2 2 2 20 - L Adhere to Stormwater Management Plan Conduct Water Quality Monitoring Adhere to Spill Response Plan



7.4 Operational Phase

The Operational Phase will commence once construction is completed. The applicant will

commence with the Operational Phase for their reclaiming and stockpiling activities and

project related infrastructure in line with their approved environmental authorisations.

7.4.1 Geology

No direct or indirect impacts on the geology of the area due to the operational phase of the

project.

7.4.2 Topography

Impacts associated with topography as a result of the operational phase include:

Direct impact: topographical changes will continue through the increase of the

stockpile footprints and then they will decrease as a result of the reclaiming

activities.


Impacts on the soils, land use and land capability of the project area as a result of operational

activities include:

Direct impact: soil erosion due to exposed surfaces; and

Direct impact: soil contamination due to operation vehicles and equipment and

potential hydrocarbon spillages and/or leaks.


Impacts on the heritage environement of the project area as a result of operational activities

include:

Indirect impact: unearthing of archaeological and/or paleontological artefacts as

operational activities progress.

7.4.5 Hydrology

Impacts on hydrology of the project area as a result of operational activities include:

Indirect impact: pollution of water resources due to spillages and dust fallout; and

Indirect impact: water quality and quantity deterioration due to changes in the

surface water regime.



The proposed activity is not likely to have any measurable impacts on local surface water

resources or water availability to other local water users.

7.4.6 Geohydrology

Impacts on geohydrology of the project area as a result of operational activities include:

Direct impact: groundwater quality impacts due to potential spillages and

contamination.

7.4.7 Biodiversity

Impacts on the biodiversity regime of the project area as a result of operational activities

include:

Direct impact: Encroachment of invasive species due to the presence of mining

activities in the area;

Indirect impact: impacts on surrounding habitats.

7.4.8 Air Quality

Impacts on the air quality environment of the project area as a result of operational activities

include:

Direct impact: dust fallout from the stockpiles, and

Indirect impact: emissions to air by vehicles will occur due to vehicles operating on

site.

Dust emissions will occur during operational activities, particularly associated with loading

and offloading of material and the transport of the ROM and low-grade materials either via

truck or conveyor.

7.4.9 Visual

Impacts on visual aspects of the project area as a result of operational activities include:

Direct impact: Increase in dust could lead to a visual impact.

The significance of visual impact associated with the surface infrastructure during the

operational phase will be moderate - high, and can be minimised to a moderate impact

provided recommended mitigation measures are successful..



7.4.10 Noise

Impacts on the noise environment of the project area as a result of operational activities

include:

Direct impact: increased noise due to increased vehicular movement on site; and

Direct impact: operation of the plant

7.4.11 Social

No Impacts envisaged

7.4.12 Wetlands

Impacts on the wetlands of the mining area as a result of construction activities include:


7.4.13 Operational Phase Impact Assessment

Table 7.4 details the identified impacts and management measures for the operational phase

activities.



Table 7.4: Impacts and Management Measures for Operational Phase Activities.

Please note: Mining activities has been approved in a previous EIA/EMP and has not been included in this assessment.


INFRASTRUCTURE AREA

ACTIVITY


BEFORE MITIGATION



AFTER MITIGATION

ACTION PLAN PHASE PERSON ANNUAL

MANAGEMENT COST

M D S P

TO

TA

L

ST

AT

US

SP M D S P

TO

TA

L

ST

AT

US

SP

INFRASTRUCTURE AREAS: 1. LOWGRADE STOCKPILE 2. OVERBURDEN 3. HAUL ROADS 4. NEW INFRASTRUCTURE AREA

OPERATIONAL PHASE ACTIVITIES: 1. STOCKPILING LOW GRADE MATERIAL 2. STOCKPILING OF OVERBURDEN 3. PROCESSING OF LOW GRADE MATERIAL 4. TRANSPORTING OF MATERIAL VIA CONVERYOR 5. CONTROL OF CLEAN/DIRTY WATER SEPARATION 7. GENERATION AND HANDLING OF WASTE 8. HYDROCARBON STORAGE 9. DUST SUPPRESSION

GEOLOGY


1, 2, 3 & 4 1, 2, 3, 4, 5, 6, 7, 8 & 9

0 0 0 0 0 N N N/A 0 0 0 0 0 N N N/A N/A N/A N/A

TOPOGRAPHY


1, 2, 3 & 4 1, 2 6 4 3 3 39 - M

Design the disposal technicques and schedules in such a manner that it is conducted in a way to create the least impact on the geomorphology of the area (i.e. desing the stockpile with the aim of closure, still within the reworking strategy)

6 4 2 2 24 - L Keep to the approved layout and dimensions as far as possible.

Operation Mine Manager Included in operational costs


1, 2 3 6 4 3 3 39 - M

Optimize the reworking protocol of the stockpiles to ensure that the topography is disturbed for the least amount of time. Implement ongoing rehabilitation as areas become available for shaping

6 4 3 3 39 - M

Design and implement a stockpile reworking philosophy, indicating the planned areas to be rewored, schedule of times and volumes, in order to work towards the annual closure plans and final closure plan.



Direct impact: soil erosion 1, 2, 3 & 4 1, 2, 3, 4, 5, 6, 7, 8 & 9

6 4 1 3 33 - M

Demarcate the footprint area clearly. Manage storm water flow with temporary erosion control measures where possible (cut-off trenches or berms). Optimize the reworking protocol of the stockpiles to ensure that the topography is disturbed for the least amount of time. Design the disposal technicques and scheudles in such a manner that it is conducted in a way to create the least impact on the geomorphology of the area (i.e. desing the stockpile with the aim of closure, still within the reworking strategy)

4 4 1 2 18 - L

Adhere to Stormwater Management Plan Soil Stripping, Soil Stockpiling and Soil have to take place as per previously approved management measures

Operation Environmental Officer

Included in operational costs




INFRASTRUCTURE AREA

ACTIVITY


BEFORE MITIGATION



AFTER MITIGATION


MANAGEMENT COST

M D S P

TO

TA

L

ST

AT

US

SP M D S P

TO

TA

L

ST

AT

US

SP



Direct impact: soil contamination 1, 2, 3 & 4 1, 2, 3, 4, 5, 6, 7, 8 & 9

6 2 1 5 45 - M

Store solid waste in approved waste disposal area. Remove waste regularly (approved contractor). Chemicals and fuels to be stored in bunded areas. Vehicles to be correctly maintained to prevent oil leakages. Adhere to recommended vehicle maintenance schedule and environmental policies Provide spill kits and follow spill procedures on site for collection of contaminated soil Ensure correct functioning of storm water management Ensure correct bunding of hydrocarbon and chemical storage areas

4 2 1 2 14 - L Adhere to Waste Storage and Handling Plan Adhere to Spill Management Plan



HERITAGE


1, 2, 3 & 4 1, 2, 3, 4, 5, 6, 7, 8 & 9

0 0 0 0 0 N N N/A 0 0 0 0 0 N N N/A N/A N/A N/A

Indirect impact: Unearthing of archaeological/paleantological artefacts

1, 2, 3 & 4 1, 2, 3, 4, 5, 6, 7, 8 & 9

10 2 2 3 42 - M Cease mining immediately Do not remove/damage artefact

4 2 1 2 14 - L Employ registered Archaeologist to assess before proceeding with mining

Operational Environmental Officer

R 50 000.00

HYDROLOGY

No direct impacts anticipated - - 0 0 0 0 0 N N N/A 0 0 0 0 0 N N N/A N/A N/A N/A


1, 2, 3 & 4 1, 2, 3, 4, 5, 6, 7, 8 & 9

10 3 3 3 48 - M

Fix damaged stormwater management structure Implement immediate spill clean-up procedures Undertake emergency water monitoring Notify water users of potential pollution immediately Inform relevant authority immediately

6 2 2 2 20 - L

Adhere to Stormwater Management Plan Adhere to Water Quality Monitoring Plan Adhere to Spill Management Plan


Included in operational

costs




INFRASTRUCTURE AREA

ACTIVITY


BEFORE MITIGATION



AFTER MITIGATION


MANAGEMENT COST

M D S P

TO

TA

L

ST

AT

US

SP M D S P

TO

TA

L

ST

AT

US

SP



Indirect impact: hydrocarbon spillages

1, 2, 3 & 4 1, 2, 3, 4, 5, 6, 7, 8 & 9

10 2 3 3 45 - M

Ensure clean and dirty water separation Implement immediate spill clean-up procedures Undertake emergency water monitoring Notify water users of potential pollution immediately Inform relevant authority immediately as per the conditions of the environmental license

4 2 1 2 14 - L




costs

Indirect impact: water quality/quantity deterioration

1, 2, 3 & 4 1, 2, 3, 4, 5, 6, 7, 8 & 9

10 3 3 3 48 - M

Ensure clean and dirty water separation Undertake water quality monitoring in terms of the approved Water Use License Notify water users of potential pollution immediately Inform relevant authority immediately of any significant incidents as required in terms of the environmental license Identify alternative water provider, if necessary

4 2 2 2 16 - L




costs

GROUNDWATER

Direct impact: groundwater quality deterioration

1, 2, 3 & 4 1, 2, 3, 4, 5, 6, 7, 8 & 9

4 5 3 3 36 - M Prevent infiltration of contaminated water Rre-circulation of contaminated water should be optimised.

4 5 3 3 36 - M

Adhere to Stormwater Management Plan Undertake Water Quality Monitoring Adhere to Spill Management Plan Ensure that the closed water circuit is enforced on site, i.e. all dams (stormwater dams) are equipped with pumps in a working conditions and operational.



costs


Indirect impact: impact on surrounding habitats

1, 2, 3 & 4 1, 2, 3, 4, 5, 6, 7, 8 & 9

2 2 2 2 12 - L

Prevent the spread of impacts to adjacent habitat by containing activities to mining area only. Prevent invader species spreading.

1 2 2 2 10 - L Update the weed eradication protocol to include all new areas as applied for in this report.

Operational Environmental Office


costs




INFRASTRUCTURE AREA

ACTIVITY


BEFORE MITIGATION



AFTER MITIGATION


MANAGEMENT COST

M D S P

TO

TA

L

ST

AT

US

SP M D S P

TO

TA

L

ST

AT

US

SP



Direct impact: human-animal conflicts and interactions

1, 2, 3 & 4 1, 2, 3, 4, 5, 6, 7, 8 & 9

4 4 2 4 40 - M Identify a protocol that will allow for protection of animals Implement awareness programmes.

4 4 1 3 27 - L Adhere to Environmental Awareness Programme



costs

AIR QUALITY

Indirect impact: emissions to air by vehicles

1, 2, 3 & 4 1, 2, 3, 4, 5, 6, 7, 8 & 9

6 2 2 4 40 - M Monitor vehicular emissions Ensure that all vehicles are in good working order.

2 2 2 2 12 - L Adhere to Vehicle Maintenance Plans



Direct impact: dust-fallout 1, 2, 3 & 4 1, 2, 3, 4, 5, 6, 7, 8 & 9

6 3 2 3 33 - M

Dust monitoring programmes must be continued. The monitoring programmes should be updated periodically to ensure that the best standards and methods for the purpose of Khumani is being implemented. Minimise dust liberation by treating roads and surfaced with a dust suppression, and where this is not possible or economically feasible, the watering/wetting of surfaces Strictly enforced speed limits on haul roads

4 2 1 2 14 - L Adhere to Dust Fallout Management Plan



costs

VISUAL

Direct impact: infrastructure – and stockpiles

4 4 & 5 8 5 3 4 64 - H

Ensure that the stockpiles are designed with closure in mind, and that the reworking of these faciltieis are undertaken in a phased method to minimise the impact on the overall geomorphology of the area during the operational phase. Use screening, similar to what is currently being undertaken at Khumani with the planning of endemic tree species, at the new WHIMS Plant area to limit visual intrusion

6 5 2 4 52 - M Adhere to Operation Plan Adhere to Construction Plan


NOISE




INFRASTRUCTURE AREA

ACTIVITY


BEFORE MITIGATION



AFTER MITIGATION


MANAGEMENT COST

M D S P

TO

TA

L

ST

AT

US

SP M D S P

TO

TA

L

ST

AT

US

SP



Direct impact: vehicular movement 1, 2, 3, 4 & 5 1, 2, 3, 4, & 5

6 4 2 5 60 - M Implement acoustic screening measures Undertake regular vehicle maintenance

4 1 2 2 14 - L Adhere to Provincial Noise Regulations Adhere to existing EMP


Included in operation costs

Direct impact: plant operation 4 5 6 4 2 2 24 - L Utilise only state of the art equipment 4 4 2 2 20 - L

Adhere to Provincial Noise Regulations Adhere to measures in the existing EMP

Operational Phase

Environmental Officer

Included in operation costs

SOCIAL

Indirect impact: longer life of mine, securing current jobs

1, 2, 3, 4 & 5 1, 2, 3, 4, 5, 6, 7, 8

& 9 4 2 4 5 50 + M

Communicate employment criteria to the employees, operational phase being initiated Implement skills development to allow career progression and portable skills transfer

6 4 4 5 70 + H Adhere to Social and Labour Plan Adhere to Recruitment Policy Adhere to Skills Development Plan

Operational Mine Manager Included in operational

costs

WETLAND

Direct impact: wetland destruction 3 2 6 5 3 5 70 - H No mitigation possible. The low grade stockpile runs through the pans

10 5 3 5 90 - H Adhere to Mining Work Programme Adhere to Operational Plan

Operational Mine Manager Included in operational costs



7.5 Decommissioning and Closure Phase

After the Operational Phase has been finalised, the applicant will commence with the

Decommissioning and Closure Phase for their mining activities and project related

infrastructure and stockpiles in line with their approved environmental authorisations. It

should be noted, that the overall aim of this project is to reduce the overall environmental

liaibilities of the mine by reducing the size and presence of residue stockpiles on site.

Closure for mining activities is highly important as far as the environmental factors are

concerned. If mitigation measures are not followed properly it could have hegative impacts.

The mine will be required to apply for a Closure Certificate according to Section 43 of the

MPRDA. Section 43 (1) of the MPRDA stated that “the holder of a … mining right …remains

responsible for any environmental liability, pollution or ecological degradation, and the

management thereof, until the Minister has issued a closure certificate to the holder

concerned”.

It is therefore assumed that all environmental impacts will be successfully addressed and

managed at this phase. When the decision is taken to decommission the mine, monitoring of

key environmental variables in order to demonstrate and ensure acceptable

quality/rehabilitation measurements will be undertaken.

Following cessation of mining, it is customary that all infrastructure will be decommissioned

and removed from site in a systematic and regulated manner. Following this, active surface

rehabilitation will be undertaken until the end of mine land use is attained.

7.5.1 Geology

No direct or indirect geological impacts are anticpated during the decommissioning and

closure phase.

7.5.2 Topography

Impacts associated with topography as a result of the decommissiiong and closure phase

include:






Impacts on the soils, land use and land capability of the mining area as a result of

decommissioning and closure sactivities include:


rehabilitation activities contributing to vehicular movement on site;




Direct impact: change in land use after mining; and

Direct impact: change in land capability as agricultural land will be lost once mining

related activities cease.

Post-closure land use will depend on the success and outcomes of the rehabilitation phase.


No direct or indirect impacts associated with decommissiong and closure with regards to

heritage and sites of cultural significance are anticipated.

7.5.5 Hydrology

Impacts on hydrology of the mining area as a result of decommissiong and closure activities

include:

Direct impact: surface water contamination;

Direct impact: increase in runoff and contribution to catchment; and

Direct impact: siltation during to water running off site once the berms and

stormwater structure are decommissioned.

7.5.6 Geohydrology

Impacts on geohydrology of the mining area as a result of decommissiong and closure

activities include:

Direct impact: groundwater quality impacts due to potential spillages and

contamination.

7.5.7 Biodiversity



Impacts on the biodiversity regime of the mining area as a result of decommissioning and

closure activities include:

Direct impact: disruption to faunal and floral communities that have established on

site during the operational phase; and

Direct impact: re-establishment of faunal and floral communities during the

rehabilitation process (Self succession).

7.5.8 Air Quality

Impacts on the air quality environment of the mining area as a result of decommissioning and


Direct impact: fugitive dust emissions;

Direct impact: dust entrainment from vehicles on site as a result of driving on

exposed surfaces; and

Indirect impact: wind-blown dust as rehabilitation activities takes place.

There will be fugitive dust emissions resulting from the removal of infrastructure and the

landscaping of the mining areas.

7.5.9 Visual

Impacts on visual aspects of the mining area as a result of decommissioning and closure

activities include:

Direct impact: landscaping of the entire site and berm removals.

Direct impact: removal of infrastructure from site and re-establishment of vegetated

areas.

The significance of visual impact associated with the mining operation during the closure

phase will be moderate for most of the activities, and can be minimised to a low impact

provided recommended mitigation measures are successful. The removal/dismantling of all

surface infrastructures will greatly reduce the visual impact. The shaping and vegetation of

discard dumps will also minimise the visual impact and reduce the intrusion.

7.5.10 Noise

Impacts on the noise environment of the mining area as a result of decommissioning and


Direct impact: increased noise due to rehabilitation activities; and

Direct impact: reduction in noise levels due to mining cessation.



The noise levels during decommissioning will be negligible.

7.5.11 Social

Impacts on the social environment of the mining area as a result of decommissioning and


Direct impact: out-migration of job seekers as the mining operations cease;

Direct impact: job losses;

Direct impact: a reduction in economic activities due to job losses and mine closure;

and

Indirect impact: increased crime due to job losses and impacts on economic activity

in the area.

It is important that the mine adhere to the comitments made in the Social and Labour Plan

with regards to closure.

7.5.12 Wetlands

No further direct or indirect impacts on wetlands.

7.5.13 Decomissioning and Closure Phase Impact Assessment

Table 7.5 details the identified impacts and management measures for the decommissioning

and closure phase activities.



Table 7.5: Impacts and Management Measures for Closure and Decommissioning Phase Activities.


APPLICABLEMINE AREA

ACTIVITY

ENVIRONMENTAL SIGNIFICANCE BEFORE MITIGATION


ENVIRONMENTAL SIGNIFICANCE AFTER MITIGATION


MANAGEMENT COST M D S P

TO

TA

L

ST

AT

US

SP M D S P

TO

TA

L

ST

AT

US

SP

MINE AREAS (BRUCE, KING AND MOKANENG): 1. PITS 2. OVERBURDEN 3. DUMPS 4. INFRASTRUCTURE AREAS 5. ROADS

DECOMISSIONING & CLOSURE ACTIVITIES: 1. REMOVAL OF SURFACE INFRASTRUCTURE 2. ACTIVE SURFACE REHABILITATION OF DISTURBED AREAS

GEOLOGY

No direct impacts anticipated 1, 2, 3, 4 & 5 1 &2 0 0 0 0 0 N N N/A 0 0 0 0 0 N N N/A Decommissioning and Closure

N/A N/A

TOPOGRAPHY

Direct impact: reshaping of area

1, 2, 3, 4 & 5 1 &2 6 4 3 3 39 - M

The area must be ripped.. All slopes to be shaped to accommodate natural flow and vegetation establishment. All slopes to be safe for animals and humans Selfsuccession will be promoted, where it does not succeed the client will investigate a revegation programme

6 4 2 2 24 - L

Adhere to Rehabilitation Plan Adhere to Revegetation Plan Adhere to Stormwater Management Plan

Decommissioning and Closure

Environmental Officer Included in decommissioning and closure costs


Direct impact: soil compaction 1, 2, 3, 4 & 5 1 &2 4 4 1 2 18 - L

Correct use of vehicles to prevent compaction Avoidance of work in very wet or waterlogged conditions Use tracked vehicles instead of wheeled vehicles where possible Avoid clearance and earthworks after heavy rain Drive only on demarcated roads

2 4 1 1 7 - L

Adhere to Soil Stripping, Soil Stockpiling and Soil Management Plan Implement Vehicle Operating Plan Adhere to Rehabilitation Plan Adhere to Revegetation Plan






APPLICABLEMINE AREA

ACTIVITY






TO

TA

L

ST

AT

US

SP M D S P

TO

TA

L

ST

AT

US

SP



Direct impact: soil contamination

1, 2, 3, 4 & 5 1 &2 6 2 1 5 45 - M

Prevent spillage of fuel and oils Adhere to recommended vehicle maintenance schedule and environmental policies Provide spill kits and follow spill procedures on site for collection of contaminated soil Ensure correct functioning of storm water management structure until all structures are decommissioned. Ensure correct bunding of hydrocarbon and chemical storage areas

4 2 1 2 14 - L

Adhere to Waste Storage and Handling Plan Spill Management methods must be adhered to Adhere to Vehicle Maintenace Plan



Direct impact: soil erosion 1, 2, 3, 4 & 5 1 &2 6 4 1 3 33 - M

Minimise infrastructure footprint Manage stormwater and stormwater management measures Employ cut-off trenches or berms until area is established The mine willl investigate an appropriate seed mix for the rehabilitation purposes should self-succession not establish on rehabilitated sites

4 4 1 2 18 - L

Adhere to Rehabilitation Plan Adhere to Revegetation Plan Adhere to Stormwater Management Plan



Direct impact: change in land use

1, 2, 3, 4 & 5 1 &2 8 5 1 5 70 - H Plan land use after mining with the local authorities and in consultation with specialist

8 5 1 4 56 - M Adhere to Rehabilitation Plan Adhere to Revegetation Plan



HERITAGE

No direct or indirect impacts anticipated

1, 2, 3, 4 & 5 1 &2 0 0 0 0 0 N N N/A 0 0 0 0 0 N N N/A Decommissioning and Closure

N/A N/A

HYDROLOGY




APPLICABLEMINE AREA

ACTIVITY






TO

TA

L

ST

AT

US

SP M D S P

TO

TA

L

ST

AT

US

SP



Direct impact: Surface water contamination

1, 2, 3, 4 & 5 1 &2 8 2 2 4 48 - M

Prevent spillage of fuel and oils Adhere to recommended vehicle maintenance schedule and environmental policies Provide spill kits and follow spill procedures on site for collection of contaminated soil Ensure correct functioning of storm water management structure

4 2 2 2 16 - L

Adhere to Rehabilitation Plan Adhere to Stormwater Management Plan Adhere to Revegetation Plan Adhere to Water Quality Monitoring Programme



Direct impact: Siltation 1, 2, 3, 4 & 5 1 &2 4 3 2 4 36 - M

Re-establish vegetated areas in a timely manner through active planting and maintenance Minimise erosion through erosion control measures such as the use of energy dissipaters and other technologies.

4 3 2 2 18 - L

Adhere to Rehabilitation Plan Adhere to Stormwater Management Plan Adhere to Revegetation Plan Adhere to Water Quality Monitoring Programme



GROUNDWATER

Indirect impact: groundwater quality

1, 2, 3, 4 & 5 1 &2 8 2 2 4 48 - M Manage water ingress Manage hydrocarbons to avoid spillages

4 3 2 3 27 - L

Adhere to Rehabilitation Plan Adhere to Water Monitoring Programme Adhere to Spill Management Plan




Direct impact: disruption to faunal and floral communites established on site

1, 2, 3, 4 & 5 1 &2 8 2 2 5 60 - M

Limit activities to areas requiring rehabilitation only Ensure these areas are demarcated and fenced off Selfsuccession will be promoted, where it does not succeed the client will investigate a revegation programme as quickly as possible to minimise impact on faunal and floral communities

6 2 1 3 27 - L Adhere to Rehabilitation Plan Adhere to Revegetation Plan






APPLICABLEMINE AREA

ACTIVITY






TO

TA

L

ST

AT

US

SP M D S P

TO

TA

L

ST

AT

US

SP



Direct impact: re-establishment of faunal and floral communites

1, 2, 3, 4 & 5 1 &2 6 2 1 3 27 + L

Re-establish vegetated areas in a timely manner through active planting and maintenance Minimise erosion Manage alien and invasive plant/weed establishment Consider active introduction of faunal species

8 5 3 4 64 + H Adhere to Rehabilitation Plan Adhere to Revegetation Plan



AIR QUALITY

Direct impact: fugitive dust emissions

1, 2, 3, 4 & 5 1 &2 4 2 2 4 32 - M

Implement appropriate dust mitigation measures Re-covering of exposed areas Implement dust suppression where necessary Rehabilitate exposed areas as soon after infrastructure removal as possible

2 2 2 3 18 - L Adhere to Rehabilitation Plan Adhere to Dust Management Plan



Direct impact: vehicle entrained dust

1, 2, 3, 4 & 5 1 &2 4 1 2 4 28 - L

Implement appropriate dust mitigation measures Re-covering of exposed areas Implement dust suppression where necessary Rehabilitate exposed areas as soon after infrastructure removal as possible Manage vehicle movement on site and ensure speed limts are adhered to

2 2 1 2 10 - L

Adhere to Rehabilitation Plan Adhere to Dust Management Plan Adhere to Vehicle Operation Plan Adhere to South African Road Rules



Indirect impact: wind-blown dust off rehabilitated areas

1, 2, 3, 4 & 5 1 &2 4 4 2 4 40 - M

Ensure effective rehabilitation of exposed areas Monitor final rehabilitation for three years after closure (or according to legislative requirements at the time)

2 2 2 2 12 - L Adhere to Rehabilitation Plan Adhere to Dust Management Plan Adhere to Revegetation Plan



VISUAL




APPLICABLEMINE AREA

ACTIVITY






TO

TA

L

ST

AT

US

SP M D S P

TO

TA

L

ST

AT

US

SP



Direct impact: landscaping and berm removal

1, 2, 3, 4 & 5 1 &2 5 2 2 4 36 - M

All slopes to be shaped to accommodate natural flow and vegetation establishment. All slopes to be safe for animals and humans Selfsuccession will be promoted, where it does not succeed the client will investigate a revegation programme




Direct impact: landscaping of Discard dump

1, 2, 3, 4 & 5 1 &2 6 5 2 4 52 - M

All slopes to be shaped to accommodate natural flow and vegetation establishment. All slopes to be safe for animals and humans Selfsuccession will be promoted, where it does not succeed the client will investigate a revegation programmed




Direct impact: removal of surface infrastructure

1, 2, 3, 4 & 5 1 &2 6 5 2 4 52 - M

The area is to be resurfaced. All depresions and slopes will be modeled to ensure a natural surface flow regime. Materials which can be resold will be removed and resold All other waste will be discarded appropriately Re-establishment of Indigenous vegetation will be encouraged




NOISE




APPLICABLEMINE AREA

ACTIVITY






TO

TA

L

ST

AT

US

SP M D S P

TO

TA

L

ST

AT

US

SP



Direct impact: rehabilitation equipment and demolition activities

1, 2, 3, 4 & 5 1 &2 6 3 2 4 44 - M

Activities will be limited to the hours of 07h00to 18h00 on weekdays. Vehicles will be equipped with mufflers to ensure noise reduction Employees will be briefed on the need to keep noise to a minimum




Direct impact: reduction in noise with cesation of mining activities

1, 2, 3, 4 & 5 N/A 6 4 1 3 33 + M

Remove infrastructure in a timely manner to minimise noise Remove all vehicles/machinery from site that are not required for rehabilitation activities

10 4 2 4 64 + H Adhere to Closure Plan



SOCIAL

Direct impact: out-migration of job seekers

1, 2, 3, 4 & 5 1 &2 8 2 2 5 60 - M

Communicate decommissioning and closure prior to the decommissioning and closure phase being initiated

10 5 2 5 85 - H Adhere to Social and Labour Plan Adhere to Retrenchment Policy



Direct impact: loss of jobs 1, 2, 3, 4 & 5 1 &2 10 5 2 5 85 - H

Communicate job losses/retrenchment prior to the decommissioning and closure phase being initiated




Direct impact: reduced economic activity

1, 2, 3, 4 & 5 1 &2 10 4 3 4 68 - H Notify the LM of mine closure prior to decommissioning and closure phase

6 3 3 3 36 - M Adhere to Social and Labour Plan Decommissioning and Closure





APPLICABLEMINE AREA

ACTIVITY






TO

TA

L

ST

AT

US

SP M D S P

TO

TA

L

ST

AT

US

SP



Indirect impact: increased crime

1, 2, 3, 4 & 5 1 &2 6 4 2 3 36 - M

Enforce access control to limit loitering of people Engage with adjacent land owners to form a Community Forum Employ security guards on site Consult with the SAPS and/or community watch organisations

8 2 2 2 24 - L Adhere to Social and Labour Plan Adhere to Access Control Procedures



WETLANDS

No further direct impacts anticipated

1, 2, 3, 4 & 5 1 &2 0 0 0 0 0 N N N/A 0 0 0 0 0 N N N/A Decommissioning and Closure

N/A N/A



7.6 Post Closure and Residual Impacts

After the Closure and Decommissioning Phase has been finalised, the applicant will

commence with the Post-Closure Phase of their mining activities in line with their approved

environmental authorisations.

Although it is assumed that all impacts will be managed, mitigated and rehabilitated by the

proposed closure objectives, some post closure and residual impacts may still remain.

Table 7.6 details the post closure impacts that may remain once the mine has been

decommissioned.



Table 7.6: Impacts and Management Measures for Post Closure Impacts.


APPLICABLE MINE AREA

ACTIVITY


BEFORE MITIGATION



AFTER MITIGATION


MANAGEMENT COST

M D S P

TO

TA

L

ST

AT

US

SP M D S P

TO

TA

L

ST

AT

US

SP

MINE AREAS: 1. LOWGRADE STOCKPILE 2. OVERBURDEN 3. HAUL ROADS 4. INFRASTRUCTURE AREA 5.OC AREAS

POST-CLOSURE ACTIVITIES: MONITORING AND MAINTENANCE

GEOLOGY

No impacts anticipated 1, 2, 3, 4 & 5 - 0 0 0 0 0 N N N/A 0 0 0 0 0 N N N/A N/A N/A N/A

TOPOGRAPHY



Indirect impact: soil erosion 1, 2, 3, 4 & 5 - 8 2 2 4 48 - M

Erosion due to water and wind may occur Poor vegetation establishment on site may increase erosion potential Ensure vegetation cover is adequately established Ensure the area is free draining

4 2 1 2 14 - L

Adhere to Rehabilitation Plan Adhere to Revegetation Plan Adhere to Soil Stripping, Soil Stockpiling and Soil Management Plan Adhere to Stormwater Management Plan

Post-Closure

Environmental Office

N/A

HERITAGE


HYDROLOGY


GROUNDWATER

Indirect impact: groundwater quality deterioration

1, 2, 3, 4 & 5 - 4 5 3 3 36 - M

Maintain water quality monitoring up until closure certificate is obtained Implement water management measures if/when required

4 5 3 3 36 - M Adhere to Water Quality Monitoring Programme

Post-Closure


N/A


Direct impact: faunal and floral reestablishment

1, 2, 3, 4 & 5 - 2 2 1 3 15 + L Ensure vegetation establishment is self-sustaining to support faunal re-establishment

6 5 2 4 52 + M Adhere to Revegetation Programme

Post-Closure


N/A

TRAFFIC


AIR QUALITY

Direct impact: improvement in air quality

1, 2, 3, 4 & 5 - 4 4 2 4 40 - M

All mining related activities with the potential to generate dust will have ceased Ensure erosion is maintained Ensure vegetation reestablishment is self-sustaining

6 5 2 2 26 + L Adhere to Revegetation Programme

Post-Closure


N/A





ACTIVITY


BEFORE MITIGATION



AFTER MITIGATION


MANAGEMENT COST

M D S P

TO

TA

L

ST

AT

US

SP M D S P

TO

TA

L

ST

AT

US

SP

MINE AREAS: 1. LOWGRADE STOCKPILE 2. OVERBURDEN 3. HAUL ROADS 4. INFRASTRUCTURE AREA 5.OC AREAS

POST-CLOSURE ACTIVITIES: MONITORING AND MAINTENANCE

VISUAL


NOISE


SOCIAL

Direct impact: loss of jobs 1, 2, 3, 4 & 5 - 10 5 2 5 85 - H Communicate job losses/retrenchment prior to the decommissioning and closure phase being initiated


Post-Closure


N/A

WETLANDS




7.7 Cumulative Impacts

Section 2 of the NEMA requires the consideration of cumulative impacts as part of any

environmental assessment process. Furthermore this is carried forward into Regulation 543

which requires assessment of cumulative impacts in an EIA Report. EIAs have however

traditionally failed to come to terms with such impacts, largely as a result of the following

considerations:

Cumulative effects may be local, regional or global in scale and dealing with such

impacts requires co-ordinated institutional arrangements; and

EIA’s are typically carried out on specific developments, whereas cumulative impacts

result from broader biophysical, social and economic considerations which typically

cannot be addressed at the project level.

Cumulative impacts associated with this type of development could lead to initial,

incremental or augmentation of existing types of environmental degradation, including

impacts on the air, soil and water present within the habitat. Pollution of these elements

might not always be immediately visible or readily quantifiable, but incremental or fractional

increases might rise to levels where biological attributes could be affected adversely on a

local or regional scale. In most cases are these effects are not bound and are dispersed, or

diluted over an area that is much larger than the actual footprint of the causal factor.

Similarly, developments in untransformed and pristine areas are usually not characterised by

visibly significant environmental degradation and these impacts are usually most prevalent

in areas where continuous and long-term impacts have been experienced.

The nature of the development is such that pollution and degradation of the surrounding

areas are expected to some extent.

Cumulative impacts are assessed over the entire lifespan of the mining operation and are

therefore not broken down into the construction, operation and decommission phases as was

performed for the EIA.

7.7.1 Geology

Cumulative Impacts associated with geology as a result of the proposed operation include:

Direct impact: the removal of ore as part of regional mining activities and the

reclaiming of lower grade material to ensure the least amount of material remaining

at the end of LOM.

There are various other iron ore mines in the area and this has permantly altered the geology

of the greater region.



7.7.2 Topography

Cumulative impacts associated with topography as a result of the proposed operation include:

Direct impact: the permanent altering of the topography resulting in the alteration

of the regional run-off.

There are various other iron ore mines in the area and this has permantly altered the

topography of the greater region.


Cumulative impacts associated with soil, land use and land capability as a result of the

proposed operation includes:

Direct impact: Loss of soils and land use reducing the economic potential for grazing land.


The only matter that may have a cumulative impact is if graves or any other site of historical

or archaeological importance is found during the construction, operation and closure phases

of the mine. It should be noted that the subterranean presence of archaeological and/or

historical sites, including graves, features or artefacts is always a distinct possibility.

7.7.5 Hydrology

Cumulative impacts associated with hydrology as a result of the proposed operation includes:

Indirect impact: water quality and quantity deterioration of downstream water users

over the life of mine.

7.7.6 Geohydrology

Cumulative impacts associated with geohydrology as a result of the proposed operation

includes:

Direct impact: the deterioration of groundwater quality and recharge potential.

7.7.7 Biodiversity

Cumulative impacts associated with biodiversity as a result of the proposed operation

includes:



Direct impact: loss of faunal and floral species of conservation importance due to

mining related activities result in an overall decline of specie diversity within the

province.

7.7.8 Air Quality

Cumulative impacts associated with air quality as a result of the proposed operation includes:

Direct impact: dust fallout throughout the life of mine, this is additional impact in

an area that already has increased dust emission from surrounding mining activities.

The potential increase in dust liberation and fall-out within the immediate and surrounding

areas is of concern. This could be a significant impact when considered in conjunction with

the impacts on air quality and dust liberation and fall-out as a result of the surrounding mining

activities.

7.7.9 Social

Cumulative impacts associated with social aspects as a result of the proposed operation

includes:

Direct impact: in-migration of job seekers;

Direct impact: increase in employement opportunites during all phases of the

operation;

Potential cumulaitive impacts are anticipated with regard to impacts on employment figures.

The potential to exacerbate unemployment figures within the province is possible in the long

term.

Direct impact increased need for water resources, which could put strain on the

already strained Sedibeng pipeline, if a close water ciruit is not effectively

maintained.

Direct Impact increased need for power, which could put strain on the already

strained electricity circuit in the area.

Table 7.7 details the identified impacts and management measures for the cumulative

activities.

Assmang (Pty) Ltd: Khumani Iron Ore Mine EIA/EMP Khumani Proposed Infrastructure Expansion Infrastructure Expansion


Table 7.7: Impacts and Management Measures for Cumulative Activities.



ACTIVITY


BEFORE MITIGATION



AFTER MITIGATION


MANAGEMENT COST

M D S P

TO

TA

L

ST

AT

US

SP M D S P

TO

TA

L

ST

AT

US

SP

MINE AREAS: 1. LOWGRADE STOCKPILE 2. OVERBURDEN 3. HAUL ROADS 4. INFRASTRUCTURE AREA 5. ROADS

CUMULATIVE IMPACTS: IMPACTS CONSIDERED ON A REGIONAL SCALE

GEOLOGY

Direct impact: removal of ore, and reclaiming of lower grade material and ROM

1, 2, 3,4 & 5 Mining and Reclaiming

8 5 3 5 80 - H

Adhere to the prescribed mining works programme and approved EMPs. Ensure optimisation of the processing activities for optimal reclamation.

6 4 1 4 44 - M Adhere to all approved EMPs. All Phases N/A N/A

TOPOGRAPHY

The permanent altering of the topography resulting in the alteration of the regional run-off.

1, 2, 3, 4 & 5 - 8 5 2 5 75 - H No mitigation possible as a permanent pit will remain

8 5 2 5 75 - H N/A Operation; Decommissioning and Closure; Post-Closure

N/A N/A


Loss of soils and land use reducing the economic potential for grazing land

1, 2, 3, 4 & 5 Local mining 10 5 1 5 80 - H

Minimise the stripping footprint as far as possible. No further mitigation possible as topsoil will be removed permanently.

10 5 1 5 80 - H Stripping, Soil Stockpiling and Soil Management Methods that ensure minimal loss of soils.

All Phases N/A N/A

HERITAGE


HYDROLOGY


1, 2, 3, 4 & 5 Regional

watercourses 4 4 2 3 30 - M

Fix damaged stormwater management structure Implement immediate spill clean-up procedures Undertake emergency water monitoring Notify water users of potential pollution immediately Inform relevant authority immediately Adhere to approved Water Use Licence and conditions

4 2 2 2 16 - L


All phases N/A N/A





ACTIVITY


BEFORE MITIGATION



AFTER MITIGATION


MANAGEMENT COST

M D S P

TO

TA

L

ST

AT

US

SP M D S P

TO

TA

L

ST

AT

US

SP



Indirect impact: water quantity deterioration

1, 2, 3, 4 & 5 Regional

watercourses 6 4 2 3 36 - M

Ensure clean and dirty water separation Undertake water quality monitoring Notify water users of potential pollution immediately Inform relevant authority immediately Identify alternative water provider, if necessary

4 4 2 2 20 - L


All phases N/A N/A

GROUNDWATER

Indirect impact: groundwater quality deterioration

1, 2, 3, 4 & 5 Local mining 4 5 3 3 36 - M Maintain water quality monitoring Implement water management measures if/when required

4 5 3 3 36 - M Adhere to Water Quality Monitoring Programme

Decommissioning and Closure; Post-Closure

N/A N/A


Direct impact: Loss of floral & faunal species of conservation importance

1, 2, 3, 4 & 5 Local mining 2 2 3 3 21 - L

Minimise the area to be cleared. Identify important species in the footprint areas. Conduct detailed, multi-seasonal walk-through prior to construction activities. Compile list of protected and Red Data species. Develop relocation programme.

2 2 2 3 18 - L

Adhere to Biodiversity Conservation Plan Adhere to Alien and Invasive Vegetation Management Plan Adhere to Flora and Fauna Relocation Programme

All Phases N/A N/A

Direct impact: Loss of ecological connectivity and ecosystem functioning

1, 2, 3, 4 & 5 Local mining 8 4 2 5 70 - H

Minimise the area to be cleared. Identify important species in the footprint areas. Develop relocation programme. Identify suitable offset area(s), taking cognisance of existing and formal (declared) conservation programmes in the immediate region. Implement biodiversity offset principles (if necessary).

6 4 2 4 48 - M

Adhere to Biodiversity Conservation Plan Adhere to Alien and Invasive Vegetation Management Plan Adhere to Flora and Fauna Relocation Programme

All Phases N/A N/A

AIR QUALITY





ACTIVITY


BEFORE MITIGATION



AFTER MITIGATION


MANAGEMENT COST

M D S P

TO

TA

L

ST

AT

US

SP M D S P

TO

TA

L

ST

AT

US

SP



Direct impact: dust-fallout 1, 2, 3, 4 & 5 Regional air quality

4 1 2 4 28 - L

Dust monitoring Minimise dust liberation by watering/wetting surfaces Monitoring of fence-line fallout dust Spraying of haul roads with dust retardant Strictly enforced speed limits on haul roads Limiting of transfer of material

2 1 1 4 16 - L Adhere to Dust Fallout Management Plan

All Phases N/A N/A

NOISE


SOCIAL

Direct impact: In-migration of job seekers

1, 2, 3, 4 & 5 Regional economy

10 4 2 4 64 - H

Communicate employment criteria to the community (e.g. in newspapers, community forum notice boards, etc) prior to the operational phase being initiated Use local or existing labour should as far as possible to aid in the management of in-migration.

6 2 2 3 30 - M Adhere to Social and Labour Plan Adhere to Recruitment Policy

All phases N/A N/A

Increase electricity demand in the area.

1, 2, 3, 4 & 5 Regional economy

10 5 3 5 90 - H Electricity must be used only when required for the operation of the mine.

4 4 2 3 30 - M

Assmang must always be in contact with Eskom to ensure that the demand of electricity does not put too much pressure on the grid and infrastructure.

All phases Mine manager

Cost must be considered throughout all phases

WETLANDS




8 MONITORING AND AUDIT MANAGEMENT PROGRAMME

This section of the report relates to Section 33 of the GNR543 published in Government Gazette

No.33306 of 18 June 2010, under Section 24(5) of the NEMA.

Regulation 33

e) Proposed mechanisms for monitoring compliance with and performance assessment

against the environmental management programme and reporting thereon

Furthermore, Regulation 55 (1) (2) of the MPRDA Regulations, R527 require that the holder of

a mining right conduct monitoring on a continuous basis. Monitoring provides qualitative and

quantitative information pertaining to the possible impacts of the development on the

environment, and enables the measurement of the effectiveness of environmental

management measures. The implementation of a monitoring plan is necessary to ensure

compliance with the NEMA, MPRDA and NWA environmental authorisations which must be

obtained before any of the proposed activities may commence.

The key to the success of environmental management lies in the effective implementation of

the proposed mitigation and management measures. Monitoring provides qualitative and

quantitative information pertaining to the possible impacts of the development on the

environment, and enables the measurement of the effectiveness of environmental

management measures. Compliance monitoring is therefore crucial. Monitoring ensures that

the environmental requirements stipulated in the EMP are being complied with. It also allows

for ongoing impacts to be tracked so that the effectiveness of the mitigation can be measured.

This monitoring programme will allow the mine to monitor its compliance with the approved

EMP for the proposed mining and related activities. The monitoring programme will

incorporate the following impacts and environmental components:

Hydrological (surface water and biomonitoring);

Geohydrological (groundwater);

Terrestrial ecology (fauna and flora); and

Air quality (dust);

Mine environmental audits are also required to ensure that all proposed management and

mitigation measures together with monitoring programmes are being implemented. These

audits must be undertaken annually unless specified otherwise by the relevant authorities.

This section of the report is compiled in accordance to the National Environmental

Management Act, 1998 (Act No. 107 of 1998) Environmental Impact Assessment Regulation 543

of 2010, Section 31 (2) (b), and Section 33 (e), (g), (h) and (i).



Ongoing monitoring of the bio-physical and socio-economic environments will continue

throughout the life of the project as per the approved EMP and the accepted monitoring

programmes. Khumani will monitor and assess the performance of the EMP on an ongoing basis.

Monitoring of different environmental aspects/impacts takes place by means of quantitative

and qualitative evaluation techniques in order to determine whether the requirements of the

environmental management programme are being complied with.

Monitoring is a continuous data-gathering and control procedure. It may range from routine

visual inspections to in-depth investigative monitoring.

There is already an established monitoring programme on the mine. The approved surface and

groundwater monitoring programme as well as the dust monitoring programme will form part

of this project and will be utilised for the new plant.

All monitoring will be undertaken in terms of the approved EMP for the mine as well as the

barrier Pillar EMP. The EMP draft that corresponds with this EIAR includes the monitoring

provisions relevant to the activities addressed in this report.

Based on the location of the project, the focus of monitoring will be based on the requirements

of the terrestrial and aquatic impacts of the mine.

8.1 Water Monitoring

8.1.1 Surface Water Monitoring

The purpose of establishing the monitoring program is to provide timely and accurate water

quality data to the DWS and to manage impacts caused by mining activities. These data are

used for a variety of purposes which may be summarized in broad terms as the determination

of status and trends in river water quality.

Specific objectives of the water quality monitoring program are as follows:

Determine whether water quality at sampling sites exceeds water quality standards;

Assess the status of water quality in the surrounding areas;

Provide analytical water quality information that describes present conditions and

changes (trends); and

Provide timely data for other users.



8.1.1.1 Locality of Surface Water Sampling Points:

The area in which Khumani is located is known for its scarcity of water. There are no perennial

rivers in the near vicinity to the mine. The Gamagara River, which flows through the mining

property, is dry for most of the year. The various drainage channels present on the property

only flow (low flow) during storm events.

Due to the above there are no rivers in the vicinity of Khumani monitor. The mine has however

adopted a no-discharge policy, which will ensure that all dirty water on the mine property will

remain within the mining area. Due to the scarceness of water in the area, the mine will reuse

dirty water contained within the dirty water systems (i.e. containment dams).

Due to the fact that all dirty water contained will be utilized in the mine process it is

recommended that all dirty water systems be monitored monthly.

Monitoring points (Figure 8.1) which have been included and should be continued to be

monitored in the monitoring process, are:

All containment dams and clean water systems; and

All river courses (in the event that they contain water).

No new monitoring points are suggested as the current monitoring programme will be sufficient

to continue monitoring on Khumani in an effective manner.

8.1.1.2 Variables

The following variables are recommended. (All variables shall be in milligrams per litre except

for pH, which is in pH units and electrical conductivity in mS/m):

pH;

Total Suspended Solids and Turbidity;

Total Dissolved Solids;

Electrical Conductivity;

Chloride;

Sulphate;

Nitrate (as Nitrogen);

Nitrite (as Nitrate);

Sodium;

Manganese;

Iron; and



Fluoride.

Please note that variables to be monitored must be according to the approved Water Use

License (WULA).

8.1.1.3 Frequency

It must be noted that due to the hydrological characteristic of the Vaal Gamagara Catchment,

the streams only flow after a significant storm event. During the investigation period, no flow

was observed at the nearby water resources. During the wet season, samples must be collected

monthly.

8.1.1.4 Operational, Inspection and Maintenance Requirements

The following principles should form part of the monitoring programme:

Design capacities of dirty water containment facilities should be maintained;

Clean and dirty water separation systems should be maintained i.e. control of

blockages, overflows, erosion and pollution;

Emergency procedures should be developed for the site and these should be clearly

defined and documented;

Should an emergency occur, it should be thoroughly investigated, the magnitude

should be quantified (volume and discharge rate and quality), impact determined (on

downstream receiving water bodies), and the circumstances which caused them;

Regular inspections should be undertaken of the facilities in order to monitor the

condition of each facility. This includes the undertaking of pro-active maintenance

and replacement;

Inspections should be undertaken by an appropriate qualified and experienced person

(engineer) in liaison with operators;

Facilities must be maintained as to operate at design capacity and with the efficiency

and effectiveness initially intended and required to meet objectives. Maintenance

include desilting of the dams, clearance of vegetation and de-scaling of pipes;

Erosion, damage to pipelines, build-up of sediment should be visually inspected.

Inspections should be used to alert mine personnel as to prevent emergencies and

ensure that corrective response measures are taken timeously;

Operational monitoring should include flow monitoring (as part of the water balance),

assessment of hydraulic integrity of all pipelines, monitoring of water levels and

quality, rainfall measurements and assessment or monitoring of silt build-up; and



Personnel at the mine need to be allocated the responsibility of managing the

different components of the SWMP and its associated infrastructure.


Figure 8.1: Surface water and Groundwater Monitoring Points



8.1.2 Groundwater Monitoring Programme

A monitoring programme has been implemented. Water samples are taken around the mining

area as well as in the paste disposal facility and other pollution control facilities on a

quarterly basis. Water levels of boreholes are also determined on a quarterly basis when the

sampling is done. Samples are analysed for chemical and physical constituents normally

associated with iron ore mining and expected impacts at specific areas as determined during

risk assessments. The monitoring schedule is summarised in Table 8.1 and water quality

parameters in Table 8.2.

The boreholes that have been included in the monitoring program are monitoring boreholes

and fall within the proposed mining area (Figure 8.1). New monitoring boreholes will be

drilled outside the mining area if it becomes necessary.

Table 8.1: Groundwater monitoring points and schedules

a) Summary of Monitoring Boreholes in the Mining Area

BOREHOLE LOCATION

FARM OWNER PARAMETER FREQUENCY X Y

40.PBE01 22.9836 -27.8513 Assmang Water Levels

Chemistry Quarterly

41.PBW01 22.9617 -27.843 Assmang Water Levels

Chemistry Quarterly


Chemistry Quarterly


Chemistry Quarterly


Chemistry Quarterly

45.BKM1 23.0146 -27.7731 Assmang Water Levels

Chemistry Quarterly


Chemistry Quarterly

47.BKM3D 22.9793 -27.8777 Assmang Water Levels

Chemistry Quarterly


Chemistry Quarterly



b) Groundwater Level Monitoring Boreholes

BOREHOLE LOCATION

FARM FARM OWNER PARAMETER FREQUENCY X Y

1.Wright 3 22.92230 -27.79459 Wright Stephanie

Cornellisen Water Levels Quarterly

2.SEK 0023 23.0705 -27.7235 Sekagame Khumba Water Levels Quarterly

3.BEST 2 23.09101 -27.68138 Bestwood Fred Viljoen Water Levels Quarterly

4.MOK 2 23.04974 -27.91066 Mokaning Nic Steyn Water Levels Quarterly

5.Mashwenin 23.0485 -27.88725 - Assmang Water Levels Quarterly

6.Mashwenin 23.0566 -27.89595 - Assmang Water Levels Quarterly

7.Mokaning 1 23.0296 -27.88651 - Assmang Water Levels Quarterly

8.Mokaning 2 23.0351 -27.89274 - Assmang Water Levels Quarterly

9.King 3 23.9954 -27.8496 - Assmang Water Levels Quarterly

10 King 2 23.0012 -27.85562 - Assmang Water Levels Quarterly

11.King 1 22.9881 -27.87321 - Assmang Water Levels Quarterly

12.BKM 1 23.0146 -27.77299 - Assmang Water Levels Quarterly

13.BKM 3D 22.991 -27.88483 - Assmang Water Levels Quarterly

14.PBW 01 22.9693 -27.84925 - Assmang Water Levels Quarterly

15.Parson 1 22.9848 -27.85842 - Assmang Water Levels Quarterly



18.AGK2/87 22.9868 -27.8875 - Assmang Water Levels Quarterly

19.AIK1/45 23.0011 -27.8858 - Assmang Water Levels Quarterly

20.VK2/81 22.9837 -27.8695 - Assmang Water Levels Quarterly

21.VK1/49 22.9827 -27.8677 - Assmang Water Levels Quarterly

22.WK2/35 22.9959 -27.8672 - Assmang Water Levels Quarterly

23.QK4/55 22.9959 -27.8636 - Assmang Water Levels Quarterly



26.ZR3/24 23.0208 -27.808 - Assmang Water Levels Quarterly

27.ABK2/24 22.9944 -27.8767 - Assmang Water Levels Quarterly

28.ZR3/2 23.0198 -27.8072 - Assmang Water Levels Quarterly

29.AMK1/47 22.9923 -27.8943 - Assmang Water Levels Quarterly

30.AGK1/89 22.9832 -27.8871 - Assmang Water Levels Quarterly

31.AAK2/45 22.9862 -27.8763 - Assmang Water Levels Quarterly

32.WK4/70 22.999 -27.8728 - Assmang Water Levels Quarterly

33.VK3/67A 22.9822 -27.8727 - Assmang Water Levels Quarterly

34.KM3/24 23.0005 -27.8893 - Assmang Water Levels Quarterly

35.ALK3/22 22.9796 -27.8979 - Assmang Water Levels Quarterly

36.AKK4/26 22.9761 -27.8984 - Assmang Water Levels Quarterly

37.ABK2/46 22.9964 -27.8767 - Assmang Water Levels Quarterly



BOREHOLE LOCATION

FARM FARM OWNER PARAMETER FREQUENCY X Y

38.AAK3/27 22.9817 -27.8803 - Assmang Water Levels Quarterly

39.ALK2/49 22.9878 -27.8948 - Assmang Water Levels Quarterly

Table 8.2 Groundwater Quality Parameters

SUBSTANCE/PARAMETER KHUMANI WATER QUALITY LIMITS

pH 7- 8.5

Electrical conductivity (Ec) in mS/m 115.6

Chlorides (Cl) in mg/l 140.5

Sulphate (SO4) in mg/l 80.6

Sodium (Na) in mg/l 60

Calcium (Ca) in mg/l 93.8

Magnesium (Mg) in mg/l 70.4

Nitrate and Nitrite (NO3 and NO2) in mg/l 14.8

Fluoride (mg/l) 0.5

Total Alkalinity (CaCO3) mg/l 364.8

Khumani and Kumba Iron Ore Mine have established a co-operative monitoring programme,

in order to establish an integrated groundwater model. Monitoring boreholes will be drilled

down gradient of the opencast mine to monitor any contaminant migration. The positions of

the boreholes are shown in Figure 8.1.

It is recommended that water level measurements be conducted in the same boreholes as for

the chemical and physical monitoring, but also in additional boreholes as may be required to

accurately describe the extent of the cone-of-depression caused by mine dewatering or water

supply from boreholes. Such monitoring program will have to be designed in conjunction

with a geohydrologist and with the approval of the regional director of DWA

The quarterly report will be an update of the database with time-series graphs, statistical

analysis (average, maximum, minimum, 5 -, 50 –and 95%ile values as well as linear

performance). Data will also be presented in a map format to present a clear picture of the

water quality and water level situation. Laboratory results will be analysed against the target

water quality guidelines for domestic use, livestock watering and irrigation (according to the

South African Water Quality Guidelines, 1996: DWAF). The strictest value between the target

water quality objectives or objectives through a reserve determination will be used.

In terms of flow, all water uses and discharges will be measured on an ongoing basis. The

flows include:

Make-up water.

Volumes of groundwater pumped out for mine dewatering purposes.

Volumes of water pumped from the plant as part of tailings.



Volumes of contaminated water that is recovered and used in the plant or for dust

suppression.

An annual detailed water quality audit report on the surface and groundwater quality is

prepared that analyses the water quality situation in detail to investigate trends and non-

compliance. The report is submitted annually to the relevant authorities. Should the

monitoring data indicate that the groundwater conditions are adversely affected, additional

studies will be undertaken if it is deemed necessary.

Data Management

Monitoring results are entered into an electronic database as soon as results are available,

and at no less than one monthly interval, allowing:

Data presentation in tabular format,

Time-series graphs with comparison abilities,

Statistical analysis (minimum, maximum, average, percentile values) in tabular

format,

Graphical presentation of statistics,

Linear trend determination,

Performance analysis in tabular format,

Presentation of data, statistics and performance on diagrams and maps, and

Comparison and compliance to South African Water Quality Guidelines and any other

given objectives.

As far as possible, the same monitoring points will be used from the construction phase

through the operational and decommissioning phases to after mine closure to develop a long

term data record and enable trend analysis and recognition of progressive impacts with time.



8.2 Dust Monitoring

Khumani currently has an ambient air and weather monitoring programme that includes

dusfall monitoring, Particulate Matter 10 microns (PM10) and meteorological monitoring. Dust

fallout is measured at:

Eight (8) unique locations using single dust monitoring units (all situated within mine

premises).

Four (4) directional dust monitoring units (DustWatch), that are located at different

locations in order to provide sampling data from four (4) different wind directions,

with the aim of indicating the predominant direction of dust loading in the area.

PM10 monitoring is conducted at:

Seven (7) PM10 monitoring locations (E-Samplers manufactured by Met One

Instruments, Inc.) that are located at strategic locations to capture ambient

concentration of particulate matter on mine premises [five (5) instruments are co-

located with dust monitoring points, while two (2) are independent, stand-alone

sites].

Three (3) monitoring locations with handheld instrument (SKC Deployable Particulate

Sampler System with Portable Air Kit for 24-hour sampling) once a month for 24 hours.

A meteorological Station (EM-02-WXT weather station with Vaisala all-weather sensor)

measures temperature, relative humidity, rainfall, hail, barometric pressure, as well as wind

direction, wind speed, and wind gusts via ultrasonic anemometer. The station is located in

the Salvage Yard on the Parsons Farm (coordinates: 27°51'23.05"S; 22°58'34.59"E), east of the

Dingleton Road.

The dust fallout network can serve to meet various objectives, such as:

Compliance monitoring;

Validate dispersion model results;

Use as input for health risk assessment;

Assist in source apportionment;

Temporal trend analysis;

Spatial trend analysis;

Source quantification; and,

Tracking progress made by control measures.

The current program and Dust Management Plan should be maintained and extended to

include the new infrastructure areas, refer to Table 8.3.



Table 8.3 Khumani Dust Management Plan

IDENTIFICATION OF SUITABLE POLLUTION ABATEMENT MEASURES

IMPACTING SOURCE RECOMMENDED CONTROL

EFFICIENCY

CONTROL MEASURES

Wind erosion from

the overburden

dump, the topsoil

storage piles, the

discard stockpile,

low-grade ROM

storage piles and the

paste disposal facility

Reduction by at least 80%,

specifically from the

overburden dump and topsoil

storage piles and the paste

residue facility.

Walls of the discard stockpiles, topsoil

piles, overburden dump, and paste

disposal facility to be vegetated or

covered up to 1 m from the top throughout

the life of mine.

The vegetation cover should be such to

ensure at least 80% control efficiency for

the walls. This should be an on-going

process. As an alternative option (due to

the dry nature of the region), waste rock

could be used to form the side slopes of

the paste disposal facility. In addition,

waste rock can also be used to cover the

slopes of the large overburden dump and

topsoil piles.

Vehicle entrained

dust from unpaved

road surfaces

It is recommended that 85%

control efficiency should be

achieved on the unpaved

roads. It is highly likely that

this might not prove feasible

due to the semi-arid

environment of the mine.

Chemical surfactants such as

Dust-a-Side should therefore

be considered for all the

main unpaved roads.

Chemical suppressants could

achieve control efficiencies

of 80% to 90% through

effective application.

If a water truck will be operational at the

mine, it was estimated that water sprays

resulting in at least 75% control efficiency

would be a requirement to result in a

significant reduction in ground level

concentrations from these roads. The

amounts of water needed to ensure 75%

control efficiency on the various haul

roads and the water consumption for 85%

control efficiency is depicted.





EFFICIENCY

CONTROL MEASURES

Materials handling

operations including

primary crushing and

screening and tipping

of material

It is recommended that

control efficiencies of

between 80% and 90% be

achieved at all tipping

points, and crushing and

screening facilities to ensure

a significant reduction in off-

site impacts.

By doubling the moisture content of the

material at all the tipping points a 62%

reduction in emissions would result. The

Australian EPA indicated that a telescopic

chute with water sprays would ensure 75%

control efficiency and enclosure of storage

piles where tipping occurs would reduce

the emissions by 99%. Emissions from train

loading would reduce by 75% if enclosed

and by a further 24% if fabric filters were

added.

In addition chemical suppressants or water

sprays on the primary crusher and dry dust

extraction units with wet scrubbers on the

secondary and tertiary crushers and

screens will assist in the reduction of the

cumulative dust impacts from Khumani.

According to the Australian EPA, water

sprays can have up to 50% control

efficiency and hoods with scrubbers up to

75%. If in addition, the scrubbers and

screens are enclosed; up to 100% control

efficiency can be achieved. With these

control measures in place, the impacts

would reduce to negligible levels. It is

important that this control equipment be

maintained and inspected on a regular

basis to ensure that the expected control

efficiencies are met.

It is further recommended that a Business

Unit manager in terms of the Mine Health

and Safety Act be employed to manage

these sources and to ensure that the

proposed mitigation measures are applied

on a continuous basis.

Performance Indicators

Indicator for Indicator should include

Source based

performance

indicators for the

overburden dump and

topsoil storage piles

and paste residue

facility

Vegetation cover density to be 80% on the entire slope up to 1 m from

crest, and dustfall immediately downwind to be <1 200 mg/m2/day.

Similarly, should waste rock be used to cover the sidewalls, it should be up

to 1 m from the top.





EFFICIENCY

CONTROL MEASURES

Source based

performance

indicators for the

unpaved haul roads

Dustfall in the immediate vicinity of mining perimeter be less than1 200

mg/m2/day.

All tipping points and

outside the primary

crusher during

crushing operations

The absence of visible dust plume at all tipping points and outside the

primary crusher during crushing operations would be the best indicator of

effective control equipment in place. In addition the dustfall in the

immediate vicinity of various sources should be less than 1 200

mg/m2/day.

From all activities

associated with

Khumani

Dustfall in close proximity to sensitive receptors (i.e. Dingleton, Kathu and

Mooihoek, Vlakwater and Weltevreden) should not exceed 600

mg/m2/day.

Receptor based Performance Indicators

Aim Methodology

Indication of what

the increase in

fugitive dust levels

are once mining

operations commence

In addition, a dust fallout network can serve to meet various objectives,

such as Compliance monitoring; Validate dispersion model results; Use as

input for health risk assessment; Assist in source apportionment; Temporal

trend analysis; Spatial trend analysis; Source quantification; and Tracking

progress made by control measures

With Dingleton and Mooihoek identified as the main sensitive areas

potentially negatively impacted upon by the proposed Khumani mining

operations, it is recommended that a PM10 monitor be implemented to

monitor respirable dust. With the plan to relocate the residents of

Dingleton, and with a PM10 sampler operated by Sishen mine near this

residential area, it is recommended that a PM10 sampler be implemented

at Mooihoek. It is further suggested that a data sharing agreement be

formed with Sishen mine to share information recorded by their dust

fallout and ambient monitoring network.

The analysis of the four directional dust fallout buckets should preferably

be linked to the frequency of the wind direction (from the four sectors)

and the two weekly results be presented as total daily dustfall over a

month (28 to 32 days) as set out by the DEAT dust fallout categories. The

ambient PM10 monitor at Dingleton records PM10 concentrations over a 14

day period. If this is to be used for compliance assessment it is

recommended that the filters be changed and analysed on a 24-hour

interval.

Record-keeping, Environmental Reporting and Community Liaison

Activity Methodology





EFFICIENCY

CONTROL MEASURES

Periodic Inspections

and Audits

Periodic inspections and external audits are essential for progress

measurement, evaluation and reporting purposes. According to the

Guidelines of the Chamber of Mines (1996), every decommissioned residue

deposit should be inspected at yearly intervals by a suitably qualified

person and any alteration or deterioration of conditions at the deposit

reported to the responsible authority.

It is recommended that site inspections and progress reporting be

undertaken at regular intervals (at least quarterly) during operations, with

annual environmental audits being conducted. Annual environmental

audits forms part of an APCS and should be initiated at Khumani. Results

from site inspections and off-site monitoring efforts should be combined to

determine progress against source- and receptor-based performance

indicators. Progress should be reported to all interested and affected

parties, including authorities and persons affected by pollution.

Corrective action or the implementation of contingency measures must be

proposed to the stakeholder forum in the event that progress towards

targets is indicated by the quarterly/annual reviews to be unsatisfactory.

Liaison Strategy for

Communication with

I&APs

EMPs should stipulate specific intervals at which forums will be held, and

provide information on how people will be notified of such meetings. For

operations for which un-rehabilitated or party rehabilitated tailings

impoundments (in this case paste disposal facility) are located in close

proximity (within 3 km) from residential areas, it is recommended that

such meetings be scheduled to be held at least on a quarterly basis. This,

for example would be applicable to Dingleton, Kathu and the farming

residents.

Financial Provision

(Budget)

The budget should provide a clear indication of the capital and annual

maintenance costs associated with dust control measures and dust

monitoring plans. It may be necessary to make assumptions about the

duration of aftercare prior to obtaining closure. This assumption must be

made explicit so that the financial plan can be assessed within this

framework. Costs related to inspections, audits, environmental reporting

and I&AP liaison should also be indicated where applicable. Provision

should also be made for capital and running costs associated with dust

control contingency measures and for security measures.

The financial plan should be audited by an independent consultant, with

reviews conducted on an annual basis.

8.3 Noise monitoring

Ambient noise measurements are taken at two points on site (N1 and N2). The average daily

and night-time noise levels are monitored and recorded. In addition to these measurements,

personal noise monitoring takes place utilising portable noise monitors.



8.4 Soil and Vegetation Monitoring

Soil and vegetation monitoring takes place in a qualitative manner and is conducted by the

Environmental Supervisor and the Environmental Control Officer. All non-conformances are

recorded in an Incident Register.

8.5 Periodic Mine Environmental Audit

A register of environmental monitoring and auditing results will be available for inspection.

This will also include compliance with environmental legislation, e.g. Environment

Conservation Act, 1989 (Act No.73 of 1989), NEMA, NWA, etc.

In order to ensure compliance with the environmental management programme and to assess

the continued appropriateness and adequacy of the environmental management programme,

Khumani commits to:

Conduct the monitoring on an ongoing basis.

Conducting monthly performance audits.

Conduct a performance assessment of the environmental management programme

every two years or as agreed by the Minister in writing.

Compile and submit the performance assessment report of the MPRDA environmental

management programme to the Director: Mineral Development.

Compile and submit the performance assessment report of the NEMA environmental

management programme to the NCDENC.

The mine further undertakes to:

Appoint a responsible person(s), in writing, who will monitor all environmental

aspects of the site on a regular basis.

The appointed person will communicate, on a regular basis, with the local interested

and affected parties identified with regards to the project and will report on the

progress made with regards to implementation of the mitigation measures. Any

complaints with regard to the mining activity will be reported to the appointed

person and be recorded in a complaint register.

Maintain records relating to compliance/non-compliance with the conditions of

authorisation. These records must be made available to the NCDENC, DMR and all

I&APs within 7 (seven) days of receipt of a written request.



9 ENVIRONMENTAL AWARENESS PLAN AND ENVIRONMENTAL EMERGENCY RESPONSE PLAN

This section of the report relates to Section 33 of the GNR543 published in Government Notice

R.543 in Government Gazette No.33306 of 18 June 2010, under Section 24(5) of the NEMA.

Regulation 33

j) An environmental awareness plan describing the manner in which-

i) The applicant intends to inform his or her employees of any environmental risk

which may result from their work; and

ii) Risks must be dealt with in order to avoid pollution or the degradation of the

environment

This chapter of the EIA/EMP Report also relates to sections of the MPRDA in order to ensure

that the reports are in line with one another.

REGULATION 51 (B)

7) Procedures for environmentally related emergencies and remediation (An environmental

emergency plan that includes all the items referred to in the concomitant section of the

guideline posted on the official website of the Department)

10) Environmental Awareness Plan (Section 39 (3) (c)) (Include all the items referred to in

the concomitant section of the guideline posted on the official website of the Department).

The purpose of this section of the EMP is to anticipate the occurrence of environmental

crises, which may occur due to unforeseen circumstances. Since these events can never be

predicted, a procedure has been prepared that must be followed in the event of such an

incident, which will assist in the mitigation, remediation and conservation of the environment

and contribute to the safety of workers and I&APs. It also sets out the procedure for inducting

employees and informing all mine employees and contractors of the various risks which may

results from the various activities on site and all required management and mitigation

measures which are in place and that must be complied with in order to avoid environmental

pollution and degradation.

9.1 Introduction

An Environmental Awareness Plan (EAP) and Environmental Emergency Response Plan (EERP)

has been implemented at Khumani Iron Ore Mine. The EAP and EERP have been implemented

to create environmental awareness and productivity in the management of potential impacts

associated with the mining and associated activities.



The material/source of information for the EAP and EERP is the approved Environmental

Management Programmes (EMP), as well as other relevant specialist reports. These

documents were utilised to compile a database, which is referred to in the EAP/EERP which

contains all medium to high significant environmental aspects and issues. The environmental

issues and aspects were entered into the database along with associated mitigation measures

and responses and includes specific legislation that governs such an impact or aspect.

9.2 Emergency Response Plan

9.2.1 Defining an Environmental Emergency Response Plan

An effective, comprehensive, well-considered and tested environmental emergency

preparedness and response plan has the potential to save lives, prevent uncessary damage to

the company and other property and to manage environmental risk in the event of a large

chemical spill, oil spill, fuel spill, explosives spill or sewerage spill.

Environmental emergencies occur over the short term and require an immediate response. A

mine, as part of its management tools, especially if it is ISO 9000 and ISO 14001 compliant,

should have an Environmental Emergency Response Plan. If one does not exist then one

should be compiled and disseminated to all employees and contractors and in the event of

an emergency, the emergency response plan should be consulted.

This plan should be placed around the mine where it can be viewed easily. The plan should

contain a list of procedures, evacuation routes and a list of emergency contact numbers. It

is advisable that the mine tests the emergency response plan in order to identify any areas

for improvement.

If the emergency has the potential to affect surrounding communities, they should be alerted

via alarm signals or contacted in person. The surrounding community must be informed, on

a continuous basis, of the potential dangers and emergencies that exist, and the actions to

be taken in such emergencies.

Communication is vital in an emergency and thus communication devices, such as mobile

phones, two-way radios, pagers or telephones, must be placed around the mine. A checklist

of emergency response units must be consulted and the relevant units notified.

The checklist includes:

Fire department;



Police;

Emergency health services such as ambulances, paramedic teams, poisons centres;

Hospitals, both local and further afield, for specialist care;

Public health authorities;

Environmental agencies, especially those responsible for air, water and waste issues;

Other industrial facilities in the vicinity with emergency response facilities;

Public works and highways departments, port and airport authorities; and

Public information authorities and media organisations.

9.3 Emergency Procedures

Below are the possible environmental related emergencies, procedures and responses to be

followed and incorporated into the Emergency Preparedness and Response Plan.



Table 8.4: Environmental Emergency Procedures and Responses POSSIBLE

ENVIRONMENTAL

RELATED EMERGENCY

ACTION PLANS/REMEDIATION TIME/PERIOD RESPONSIBLE

PERSON/PARTY

Spillage of oil, diesel by

vehicles, tankers,

storage tanks etc.

The spillage should be contained (bund earth walls) by all means. Depending on the

amount of spillage it could be remediated in situ or in the case of large amount of spillage

that is contained, could be removed, etc.

Leakage from the vehicle, tanker etc, that caused the emergency, should be stopped and

the vehicle removed to the workshop area for repairs.

In all cases of spillage, irrespective of the chemical, remove or extinguish any fire (naked

flame) to within at least 10 metres from the spill.

Cover the spills with absorbent material.

Immediately

Khumani

Sewerage Spills

The spillage should be contained (bund earth walls) by all means. Depending on the

amount of spillage it could be remediated in situ or in the case of large amount of spillage

that is contained, could be removed, etc.

The leakage must be stopped and reason for spill must be rectified.

The person who reported the spill must fill out an incident report and forward it to the

Environmental Department after a thorough investigation.

Immediately

Khumani

Fires All fires in the veld, buildings, diesel tanks, chemical fires, etc. should be extinguish and

prevented to spread to any other piece of land, building, etc. During the winter months

an adequate fire breaks should be put in place around the property. The necessary

equipment should be in place and ready to be used if an accidental fire is started.

There shall be an emergency preparedness plan is in place in order to fight accidental

fires and veld fires, should they occur. The adjacent land owners/users/managers should

also be informed and/or involved.

Immediately

Environmental

manager, Safety

officer, Local

Fire Brigade



The use of branches of trees and shrubs for fire making purposes must be strictly

prohibited.

No fires may be lit except at places approved by the ESM (private residences will be able

have lit fires but not for the purpose of waste disposal).

All businesses shall ensure that the basic fire-fighting equipment is to the satisfaction of

the Local Emergency Services.

All businesses must take precautions when working with welding or grinding equipment

near potential sources of combustion. Such precautions include having a suitable, tested

and approved fire extinguisher immediately at hand and the use of welding curtains.

The Atmospheric Pollution Prevention Act (No. 45 of 1965) states that burning is not

permitted as a means of disposal.



9.4 Environmental Awareness Plan

9.4.1 Communication Sectors

The environmental risks for each phase of the project will be communicated to Khumani’s

work force ie management, administration, plant and mine workers. Contractors will receive

the same communication.

9.4.2 Management Sector

A workshop will be conducted to inform all mine management of the risks associated with

the mining operation and/or developments. The risks for all aspects will be explained and

the appropriate management options discussed. The workshop will also elaborate on the

monitoring programmes that will be implemented to identify and monitor the mines level of

impact on the environment and discuss various remediation actions, should there be

deterioration.

The evaluation process is integral in the assurance that the mine reduces any possible

environmental risks associated with the operation.

The workshop will be conducted prior to the construction phase to ensure that all risks are

discussed before there is any chance of the impacts occurring. The workshop may be

repeated at certain stages during the life of the project, in the case of new employees.

9.4.3 Administrative Sector

The communication of the environmental risks to the administrative sector will occur through

a workshop / half day course. This workshop will seek to explain the following necessary

actions:

Firstly, each aspect will be described as shown in Table 8.5, Table 8.6 and Table

8.7. The risk associated with each aspect will be discussed to ensure that there is

an understanding of how each action of the project may impact on the environment.

The mitigation of the environmental risk will be elaborated on. It is important that

each person understand these management strategies as it ensures that the impact

on the environment is kept to a minimum. Data collection regarding each aspect will

also be explained to ensure that each aspect is monitored according to those

protocols specified by the mine and the DMR. Along with data collection the

reporting of findings will be discussed.



This workshop will take place before the construction phase begins, thus ensuring a

full understanding of the project and its associated environmental risks before any

construction activity is undertaken. The course will be repeated at the beginning of

the operational phase and the material will be integrated in the induction for new

personnel.

The following communication channels and media will / can be used to communicate

environmental issues within the operation:

o HOD Meetings: The Mine Manager communicates information to senior

management on environmental issues and the information is minuted.

o HSEC Meetings: ‘Environmental issues’ should be an agenda item on plant

and section monthly safety, health & environmental meeting agendas.

o Publications: Leaflets, posters etc are produced by the relevant department

or other designated persons, for use on notice boards, and distribution.

Quarterly newsletter will also be made available. Email notifications and or

relevant articles are also distributed.

o EMS Database (if established): Feedback from line management on

objectives, targets and actions.

o Daily / Weekly Safety Meeting: All meetings are scheduled to commence

with a discussion on safety, health & environmental topics.



Table 8.5: Environmental Awareness Plan for the Construction Phase at Khumani.

ENVIRONMENTAL

PARAMETER RISK

COMMUNICATION STRATEGY MITIGATION ACTIVITY

MANAGEMENT ADMINISTRATION MINE WORKERS CONTRACTORS

Soil

Increase in soil erosion Workshop Induction Induction Induction

Areas must not be stripped of vegetation before the area

will be needed for construction. Use phased approach in

clearance activities.

Reestablishment of vegetation will be encouraged after

construction. If area is exposed for longer than 18 months

and no self-succession has taken place, other options must

be investigated.

Effective dust management must be employed during the

construction phase.

Contamination of soil Workshop Induction Induction Induction

Employees and contractors will be educated by means of

training to make them aware of the necessity to prevent

spillages through the implementation n of good

housekeeping practices. The management of chemicals

and hydrocarbons should form part of the emergency

response programme. No activities associated with

hydrocarbons and or chemicals (i.e. wash bays etc.) may

be undertaken outside of an effectively designed

contained area.

Soil compaction Workshop Induction Induction Induction

Keep infrastructure localized to reduce footprint.

All areas not directly within the proposed infrastructure

footprint area where the soil has been compacted will

need to be ripped to break up the compacted soil surface.

This will aid infiltration and decrease run-off.

All ripped areas should be monitored to ensure successful

re establishment of natural vegetation and to prevent

invasion by alien species.



ENVIRONMENTAL

PARAMETER RISK



Removal and

stockpiling of soil Workshop Induction Induction Induction

Soil stripping and stockpiling should be undertaken as per

the approved EMP. The topsoil will be re-used during the

rehabilitation phase

Topsoil and subsoil stripping will be conducted up to a

suitable depth for construction purposes, at least 20cm.

Different soils must be stockpiled separately in designated

areas.

Topsoil and subsoil stockpiles must be vegetated. Should

it be found that self succession does not take place within

a reasonable period

The topsoil that is collected will be stockpiled in such a

way that dust and water erosion is limited. Stockpiles will

be constructed in such a way to ensure stability and

thereby preventing the possibility of wash down.

Fauna Disturbance to Fauna Workshop Induction Induction Induction

Ensure minimal footprint clearance; ensure minimal

human/animal conflict potential; implement awareness

programmes; control movement of personnel; limit

speeds of vehicles; and avoid open waste areas that could

be targeted by rodents and scavengers.

Flora Damage to Flora Workshop Induction Induction Induction

Vegetation clearing will be carried out in phases, only

areas requiring clearing at a specific point in time for

construction activities to take place.

Natural vegetation self succession will be encouraged. In

disturbed areas the main grass species will be

reintroduced after fertilisation has been added.

Construction activities to be limited to designated areas

Surface Water

Soil eroision and

sediment

transportation

Workshop Induction Induction Induction

The area is located in an already classified dirty water

area, they must constuct the dirty water management

infrastructure (swm dam) prior to the construction of the

plant expansion also all dirty water management

infrastructure where possible.



ENVIRONMENTAL

PARAMETER RISK



Contamination of

surface water Workshop Induction Induction Induction

Employees and contractors will be educated to necessity

to prevent spillages through the implementation of good

housekeeping practices.

The management of chemicals and hydrocarbons must

form part of the emergency preparedness and response

programme.

A dedicated area for the placement of waste skips must

be determined prior to construction activities, and the

area will to be cemented. Allowance for keeping clean

water run-off away from the skip area through the correct

bunding design

Measures should be in place to contain any spills and allow

safe collection and disposal of waste.Khumani has an

approved Waste disposal site and a Temporary Hazardous

storage facility. Waste generated on site will be stored in

Skips until it can be collected and transported to the

licensed area.

Groundwater Groundwater

Contamination Workshop Induction Induction Induction

The management of chemicals and hydrocarbons should

form part of the emergency preparedness and response

programme


be determined prior to construction activities. Waste will

be temporarily stored in the dedicated area until it is

collected and disposed off at the approved Khumani waste

disposal area.

Air Quality Generation of Dust Workshop Induction Induction Induction Recover exposed land promptly, where possible.

Dust suppression techniques will be implemented.



Table 8.6: Environmental Awareness Plan for the Operational Phase at Khumani.

ENVIRONMENTAL

PARAMETER RISK



Soil

Increase in soil erosion Workshop Induction Induction &

Monthly Meeting

Induction &

Monthly Meeting

Contamination of soil Workshop Induction Induction &

Monthly Meeting

Induction &

Monthly Meeting

Workshops must be constructed within the dirty water

area of the mine. Clean and dirty water separation

structures to be constructed around the workshop and

wash bay areas.

All heavy vehicles within the mining rights area will make

use of driptrays when parked.

Fauna Damage to Fauna Workshop Induction Induction &

Monthly Meeting

Induction &

Monthly Meeting

Develop dedicated waste handling areas; prevent the

spread of waste.

Develop dedicated waste handling areas; prevent access

to rodents and opportunistic species; prevent the spread

of waste.

Flora Damage to Flora Workshop Induction Induction &

Monthly Meeting

Induction &

Monthly Meeting

Develop dedicated waste handling areas; prevent the

spread of waste.

Develop dedicated waste handling areas; prevent access

to rodents and opportunistic species; prevent the spread

of waste.



ENVIRONMENTAL

PARAMETER RISK



Surface Water

Water Quality Workshop Induction Induction &

Monthly Meeting

Induction &

Monthly Meeting



structures to be constructed around the workshop and

wash bay areas.


use of driptrays when parked.

Suitable oil traps must be provided to trap and store

hydrocarbons for safe disposal off-site. Water associated

with stockpiles will be dirty water and therefore has to be

channelled and contained in a dirty water dam. Dirty

water areas must be kept as small as possible.

All contaminated surface water run contained within a

downstream lined pollution control dam. These structures

should be located well away from surface water resources

and drainage lines.


be determined prior to construction activities, and the

area will to be cemented. Allowance for keeping clean

water run-off away from the skip area through the correct

bunding design

Contaminated runoff Workshop Induction Induction &

Monthly Meeting

Induction &

Monthly Meeting

Clean and dirty water separation system to be constructed

uprstream from the stockpile area and divert clean water

around the stockpile area as to prevent it from entering

the area.


Contamination Workshop Induction

Induction &

Monthly Meeting

Induction &

Monthly Meeting



structures to be constructed around the workshop areas.


use of driptrays when parked



ENVIRONMENTAL

PARAMETER RISK



Air Quality Generation of Dust Workshop Induction Induction &

Monthly Meeting

Induction &

Monthly Meeting

Dust suppression methods must be implemented around

the stockpiling areas and transfer stations and it is

recommended that a dust monitoring network be

established to monitor levels of dust dispersion. Should it

be found that the stockpiles create excessive dust;

measures must be implemented to reduce this impact.

A dust monitoring network must be set up prior to the

construction phase so that any air quality or dust issues

can be addressed accordingly.



Table 8.7: Environmental Awareness Plan for the Decommissioning Phase at Khumani.

ENVIRONMENTAL

PARAMETER RISK



Soil Incorrect rehabilitation Workshop Workshop Induction Induction The correct placement of soil layers will be implemented.

Lack of soil fertility Workshop Workshop Induction Induction Fertilization programmes will be introduced.

Flora Alien Invader Species Workshop Workshop Induction Induction

Indigenous vegetation establishment will be encouraged;

and

A weed control programme will be implemented.

Surface Water Water Quality Workshop Workshop Induction Induction Detailed water monitoring programme to be

implemented.


Contamination Workshop Workshop Induction Induction Detailed water monitoring programme to be implemented

Air Quality Generation of Dust Workshop Workshop Induction Induction Dust suppression methods will be implemented.



9.4.4 Contractors

An environmental awareness section will be added to the contractors health and safety

induction programme. The environmental induction will focus on activities that carry an

environmental risk, actions to be taken to reduce these risks, and procedures to be followed

in the event of an incident.

9.5 Methods of Communication

The following methods of communitation will be used to inform employees of the EAP and

EERP to ensure safe and sustainable mining operations. Not all methods of communication

will be used for each group of employees as some may require more comprehensive

knowledge of the EAP and EERP depending on their job descriptions.

9.5.1 Induction

Comprehensive induction forms a critical component during the construction period and

operational period. This includes the following:

Ensure that all employees are aware of their individual and their job descriptions

potential impact on the environment; and

Employees are aware of any ecological sensitive, cultural sensitive sensitive sites.

The measure and procedures to follow should cover ecologically sensitive, culturally sensitive

or historically sensitive sites which have been detected.

The preventative measures and procedures to undertake in order to reduce the risk of a

potential impact.

9.5.2 Environmental Symposiums

Environmental symposiums are held with management, and selected groups of supervisors /

foremen and / or employee representatives. These take the form of an open discussion

between the environmental department and these individuals. The symposiums aid in

environmental awareness being generated at all levels, as well as assist the relevant

department in defining all, or identifying new environmental issues, concerns and pollution

sources. These are undertaken on a quarterly basis.



9.5.3 In-house Training

In-house training sessions are held with relevant employees. The training sessions are

planned by the environmental department, and allow for employees to participate in

determining what the environmental issues and concerns are with regard to their specific

occupation. Education with regard to environmental incident reporting is detailed at these

sessions.

9.5.4 On the Job Training

On the job training is an essential tool in environmental awareness. Employees are given

details of the expected environmental issues and concerns specifically related to their

occupation. Employees are trained on how to respond if an environmental problem or source

of environmental pollution arises. The training is on-going, and all new employees are

provided with the same standard of training as existing employees.

9.5.5 General Training and Skills Development

The current Khumani training schedule will be implemented for the proposed activities.

9.5.6 Environmental Open Days

If necessary (i.e. requested by the environmental forums), environmental open days can be

arranged by the operation’s environmental department. Open days will be utilised to discuss

environmental issues in a less formal manner, thereby allowing employees the opportunity

to participate in environmental management by educating them about environmental

pollution and waste management in areas beside the workplace (e.g. at home). The open

days do not necessarily have to be confined to employees only, but may be made open to

employee’s families and schools so as to ensure that the principles of environmental

management, pollution prevention, waste management and sustainable development are

communicated to the communities surrounding the operation.

9.5.7 Publications

Selected publications are produced and used to communicate environmental issues to outside

parties. Examples include newsletters and the ARM (African Rainbow Minerals Annual Report).

The quarterly distribution of the information newspapers at Khumani has been implemented

to ensure that all parties are aware of the status of environmental, safety and health issues

at the mine. The newspaper further provides information regarding specific environmental



issues (i.e. plant species which should be protected), which the employees can implement

and make them more knowledgeable in the working environment.

9.6 External and Internal Environmental Communication Strategies

Khumani’s management shall continue to establish and maintain procedures for the internal

communication between the various levels and functions of the organisation, and receiving,

documenting and responding to relevant communication from external interested and

affected parties. The communication of the environmental risks for each phase of the project

will take place for the management, administrative, plant and mine worker sectors of the

mine, as well as contractors. The organisation shall consider processes for external

communication on its significant environmental aspects and record its decision.

Communication is a management responsibility. All supervisors are responsible for effective

communication within their own sections. Environmental communication can be divided into

two categories: internal communication and external communication.

9.6.1 Internal Communication

Internal communication is done within the Administrative Sector. Please refer to Section

9.4.3 for details pertaining to internal communication within the administrative sector.

9.6.2 External Communication Strategies

The following communication channels and media will / can be used to communicate

environmental issues to individuals who are not employed by the mine:

Environmental Committee: An Environmental Committee will be established and

used as a forum to keep interested and affected parties informed of the significant

environmental aspects identified through the Environmental Impact Assessments and

Management Plans. This will also be the forum where interested and affected parties

get the opportunity to raise environmental concerns. Records will be kept of all

decisions and concerns. The Environmental Committee will be chaired by the General

Manager, or another appropriately appointed competent individual. All issues and

concerns raised will be addressed within a specific timeframe as approved by the

relevant stakeholders and authorities. The Environmental Committee will be chaired

by the Environmental Manager, or another appropriately appointed individual. Bi-

annual forum meetings will be held at which time stakeholders will be presented with



the opportunity to raise issues and concerns. Should the stakeholders require more

meetings (i.e. quarterly) this will be undertaken

Communication from external parties and employees: A clear communication point

will be established within the company that will be responsible for liaison with the

media in respect of any crisis that may arise within the Mine. A complete procedure

for media liaison will be made available to all employees. Communication from

external interested and affected parties may be received by e-mail, fax,

telephonically or by mail. Where required, a written response will be sent, on

receiving such communication, by the appropriately appointed individual under

signature of the General Manager, to the respective interested and / or affected

party. All telephonic or facsimile correspondence received on the mine will be

forwarded to the relevant department for action. All events or concerns will be

captured and actioned on an existing and / or future database.

E-mail: E-mail communication received will be stored, with replies, in an appropriate

folder on a server. E-mail messages, relevant to environmental management, will be

kept for a minimum of two years before deletion.

Mail: Correspondence received by mail will be filed, along with the response (where

relevant), within the relevant department’s filing system for a minimum period of

two (2) years. Paper correspondence will be archived in this department.

Telephone: A register of telephonic environmental queries will be kept by the

relevant department detailing caller, contact details, date, query, action taken and

response. Furthermore, the person answering the call will be responsible for logging

their particulars against the call, as well as ensuring that all communication that

leads to an aspect or an impact, is entered on the database.

Storage of Correspondence: All original correspondence will be retained by the by

Khumai for a minimum period of two years.

Environmental Reports: Copies of relevant specialist study reports and

Environmental Impact Assessments will be available on request from an external

party by the General Manager.

Queries from Interested and Affected Parties: Response to queries about

environmental impacts and aspects will be addressed by the relevant department,

and approved by the General Manager.



9.7 Evaluation of the Environmental Awareness Plan

The evaluation of the environmental awareness plan will be conducted by the management

of the mine. This evaluation will entail the auditing of the operation in both the construction

and operation phase once activity has commenced.

The environmental awareness plan described above is sufficient to make all those involved

in the project aware of those risks that may occur as well as the necessary mitigation required

to minimize these risks. The awareness plan indicates that the applicant is serious about the

environments well being, empowerment of the local people and returning the land to the

appropriate use in the future. Environmental issue will be highlighted at monthly meetings

scheduled at the mine.



10 FINANCIAL PROVISION



Regulation 33

g) A description of the manner in which it intends to :

i) Comply with any applicable provisions of the act regarding closure, where

applicable;

ii) Comply with any provisions of the Act regarding financial provisions for

rehabilitation, where applicable.


The ‘Guideline document for the evaluation of financial provision made by the mining

industry’ has been developed by the Department of Minerals and Energy (DMR) to empower

the personnel at the Regional DMR offices to review the quantum determination for the

rehabilitation and closure of mining sites.

10.1 Overview of Legal Requirements

Section 41 and 45 of MPRDA:

Section 41(1): Requires that an applicant must before the Minister approves the EMP

in terms of section 39(4) make the prescribed “financial provision” for the

rehabilitation or management of negative environmental impacts.

Section 41(2): If a holder of a mining right fails to rehabilitate / manage, is unable

to undertake such rehabilitation or to manage any negative impact on the

environment, the Minister may upon written notice to such holder, use all or part of

the financial provision to rehabilitate or manage the negative environmental impact

in question.

Section 41(3): Require the holder to undertake an annual assessment of his or her

environmental liability and increase his or her financial provision to the satisfaction

of the Minister.

Section 45: Allows the Minister to recover cost in the event of urgent remedial

measures.

Regulation 53 and 54 of the MPRDA Regulation R527:



Regulation 53 sets out the methods for providing the financial provision required, i.e.

trust fund, financial guarantee by a bank or other financial institution, or direct

deposit into a bank account stipulated by the DMR Director General;

Regulation 54: Requires that the quantum of financial provision to be approved by

the Minister must be based on the requirements of the approved EMP and shall include

detailed itemization of all actual costs required for premature closure regarding:

o The rehabilitation of the surface of the area;

o The prevention and management of pollution of the atmosphere;

o The prevention and management of pollution of water and the soil; and

o The prevention of leakage of water and minerals between subsurface

formations and the surface.

o Decommissioning and final closure of the operation; and

o Post closure management or residual latent environmental impacts.

The Closure Cost will be updated during the annual closure cost reviews to include the

expansion of the existing stockpiles and also the additional stockpile areas.



11 ENVIRONMENTAL REHABILITATION PROGRAMME



REGULATION 33

b) Information on any proposed management or mitigation measures that will be taken to address the

environmental impacts that have been identified in a report contemplated by these regulations,

including environmental impacts or objects in respect of :

i) Planning and designing;

ii) Pre Construction and construction activities;

iii) Operation or undertaking of the activity;

iv) Rehabilitation of the Environment; and

v) Closure, where relevant

f) As far as is reasonably practical, measures to rehabilitate the environment affected by the

undertaking of any listed activity or specified activity to its natural or predetermined state or to a

land use which conforms to the generally accepted principal of sustainable development ,including

,where appropriate, concurrent or progressive rehabilitation measures

11.1 Background Information

The overall land use vision for the proposed Upgrades of the current operations is to ensure

the operations are safe, stable and non-polluting over the long-term.

If one is to consider an end of mine land use for the proposed project area there are certain

criteria that must be borne in mind, namely:

The nature of the mining operation;

The impacts of the mining operation; and

The land use of the surrounding areas.

11.1.1 Nature of the Mining Operation

Khumani is an existing mine and is currently managed in terms of the existing EMP.

11.1.2 Impacts of the Mining Operation

The main impacts associated with the mining actiivites are:

1. Loss of species of conservation activities, for which the mine has permits;



2. Loss of land for grazing potential, which should be re-esablished to an extent as part

of the closure objectives;

3. Due to the fact that the mine is not privileged to groundwater resources to

supplement water needs, the mine is purchasing water from the Sedibeng water

scheme, which places additional needs on the already strained system;

4. Increase in dust dispersion, although the mine is generally compliance with the dust

dispersion standards for a rural area;

5. Increase in the overall noise and vibrasions of the area; and

6. Permanent change in the geomorphology of the area.

Noting the above, the mine is also contributing positively towards the bio-phisical and socio-

economic environment. These activities are considered sustainable and long terms and

include:

1. Establishment of a long term and sustainable offset area in consultation with the

provincial authorities;

2. Ongoing establishment of endemic species on site;

3. Implimentaton of skill development programmes and training programmes, which will

benefit employees for their personal lives; and

4. Significant contribution to programmes and projects in line with the Integrated

Development Plan of the local municipalities as part of the mines; Social and Labour

Plan.

11.1.3 Land Use of the Surrounding Area

The main industries in the area include mining (mainly for manganese ore, iron ore and tiger’s

eye), agriculture (mainly for cattle, sheep, goat and game farming) and tourism. Surrounding

land use such as agriculture and tourism will not be affected. The mine is already in operation

and the proposed extensions are adjacent to the existing structures on property leased by

the mine. While no further impacts can be expected on these land uses during the

construction and operational phases, significant gains may be experienced post mining as the

land can be reused for agricultural or tourism purposes post rehabilitation efforts.

11.2 Aim of Rehabilitation Plan

The aim of the rehabilitation plan is to:

Return the disturbed areas to an acceptable post mining state;

Ensure all areas are stable, and there is not risk of erosion or subsistence;



Prevent alien plant invasion on the site until the site is in a stable state; and

Ensure that all areas are free-draining and non-polluting.

The rehabilitation plan will attempt to restore the area to an acceptable standard as required

by the economic planning reality (as per the Integrated Development Plan at the time) and a

viable end of mine land use.

11.3 Rehabilitation Objectives

The overall rehabilitation objectives for Khumani are the following:

Visual impacts of rehabilitated areas should be minimised by recreating natural

landforms and ensuring that reshaped areas are visually suited to surrounding

landscapes;

Natural landforms such as drainage lines, undulating areas and ridges, which have

been damaged during activities, must be restored where practically possible;

Soil integrity is the most important aspect of rehabilitation as it forms the base from

which rehabilitation proceeds. If soils are not correctly prepared, suitable conditions

for re-vegetation will not be achieved;

The mine is committed to backfilling, however due to the fact that residue material

will be reprocessed and reused, the possibility that open voids remain, is possible.

For this purpose, those open voids must be made safe; and

Alien floral invasion poses a threat both during and post-rehabilitation activities.

Adequate alien and invasive species control measures will contribute towards an

effective rehabilitation effort.

The closure involves the rehabilitation of all areas disturbed as a result of the operations

during all of the project phases.

11.4 Management Criteria for the Rehabilitation of Land

The following management measures are required:

The rehabilitated areas will be barricaded, and all animals kept off the area until the

vegetation is self-sustaining;

Newly seeded/planted areas will be protected against compaction and erosion;

Vegetation will be watered, if required, and weeded at least once in three months;

Ongoing monitoring for pests and diseases will be undertaken at least once in six

months and vegetation will be treated in accordance with identified accepted

procedures if necessary;



Unhealthy or dead plant material will be replaced if necessary;

A general application of potassium, nitrate and phosphorous fertilizer should be

applied, where self-succession does not establish. Small quantities should be applied

at regular intervals (to be determined at rehabilitation onset) across the site so as

not to affect the surface and groundwater environments;

Any damage caused by erosion will be rehabilitated and the necessary erosion control

measures will be maintained; and

Annual inspections of rehabilitated areas will be undertaken for the first three (3)

years after rehabilitation or until such time that the areas are self-sustaining.

11.4.1 Removal of Infrastructure

Following cessation of mining, it is customary that all infrastructures will be decommissioned

and removed from site in a systematic and regulated manner.

11.4.2 Active Rehabilitation - Landscaping

Landscaping activities involve the active rehabilitation of an area with the following activities

taking place:

Recovery of all saleable infrastructure;

Demolition and removal of all buildings and structures;

Ripping of all compacted areas, which will be followed with amelioration and

vegetation;

Ensure that all remaining piles and slopes are sufficiently shaped to blend in with the

surrounding environment;

Amelioration and vegetation of all disturbed areas;

Maintenance of all re-vegetated areas up until such areas initiate succession and

create a sustainable cover;

Monitoring of key environmental variables (i.e. soils, vegetation, groundwater and

surface water) in order to demonstrate stability of rehabilitated areas; and

Weed management after closure, limited to areas disturbed by mining or included as

infrastructure related to the mine.

11.4.3 Disposal of material

The disposal of material will include the following and will be completed within a period as

specified in the appropriate closure document:



Waste removal will be undertaken in accordance with the applicable Waste

Legislation of the time;

No building rubble or any other types of waste shall be dumped in the surrounding

environment. In cases where it has already happened the sites shall be cleaned up

and the waste and/or rubble removed to appropriate sites in consultation with the

Environmental Coordinator;

All types of waste (with the exclusion of residue stockpiles) shall be removed entirely

from the area and appropriately dealt with in respect of the general waste handling

procedure;

All foreign matter shall be removed from the site;

Inert ceramics such as bricks, concrete, gravel etc. will be disposed of in a licensed

waste disposal site; and

Inert ceramic and buried waste with a salvage value to individuals such as scrap

metal, building materials, etc. will be removed and disposed of at a licensed facility.

11.4.4 Water Pollution Control Structures

Water pollution control structures will remain until the completion of all demolition and

associated rehabilitation activities where after these will be rehabilitated.

11.4.5 Maintenance

The aim of the maintenance measures are to ensure that the area affected by the mining

operations is rehabilitated according to the closure plan and to apply for closure. The

objective is for the area to be rehabilitated sustainability, ensuring self-succession of plants

and the associated return of natural wildlife; as well as the improvement of the natural

watercourses and groundwater systems.

The following maintenance measures will be implemented as part of the post-closure process:

All natural physical, chemical and biological processes for which a closure condition

has been specified must be monitored for three (3) years after closure or as long as

deemed necessary at the time. Such processes include erosion of the rehabilitated

surfaces, surface water drainage, surface water quality, groundwater quality,

vegetative re-growth, weed encroachment and colonization by animals;

Measures must be implemented to curb environmental impacts and to ensure that

they do not worsen/cumulate over time;

The closure plan will be reviewed every five (5) years; and

All rehabilitated areas will be monitored and maintained until such time as required

to enable the mine to apply for closure of these different areas.



The following activities will be included during the maintenance phase:

The closure costs (demolition, removal, re-shaping and rehabilitation quotes per key

quantity) for the facility must be included in a database so that the total closure cost

can be determined;

Attention must be paid to the latest developments in mine rehabilitation sciences;

Rehabilitation should be done as soon as possible, to ensure that the rehabilitation

work required is kept to a minimum at the end of the life of the mine;

Ensure that the area is free draining;

Ensure that no subsidence will occur and the area is stable;

Ensure that self-succession has been implemented;

Ensure that all slopes are stable in the long term;

Submission of closure report and application for closure to the authorities; and

Environmental monitoring and maintenance for three years after closure, after which

the the effectiveness will be reassessed.

11.5 Submission of Information

The following applies to the submission of information:

All procedures (emergency, environmental awareness, rehabilitation strategies, etc.)

must be included into the mine’s Environmental Management System (EMS). The

mine’s EMS will monitor and assess the performance of the EMP on an ongoing basis.

Formal audits of the performance assessment of the EMP will take place every year

as stipulated by law, or at any other period if required by government;

All information as required by the various government departments should be

captured and be readily available for submission when required;

An bi-annual Performance Assessment Report (PAR) will be submitted to the DMR;

Groundwater monitoring occurs on a quarterly basis and is undertaken by outsourced

specialists. Annual groundwater reports will be submitted to the DWA;

The groundwater levels will be monitored on a quarterly basis and will be presented

in the form of piezometric maps, from which changes can be determined through

time. Annual groundwater reports will be submitted to the DWA;

Surface water monitoring will be undertaken monthly and annually reports will be

submitted to the DWA together with the groundwater reports;

The financial provision for closure (quantum and method) will be updated annually

as part of the Environmental Programme Performance Assessment; and

The closure plan must be reviewed every five (5) years, and must always keep pace

with the current best practices.



11.6 Rehabilitation Responsibilities

Table 11.1 indicates the various responsibilities and responsible parties for the rehabilitation

activities.

Table 11.1: Responsibilities and Responsible Parties for Rehabilitation Activities.

RESPONSIBLE PARTY RESPONSIBILITY

Khumani Environmental Manager

Planning of rehabilitation projects

Initiating rehabilitation projects

Compilation of closure plans with regard to rehabilitation

areas/sites

Khumani Environmental Manager

General monitoring/surveillance and reporting and

coordination

Implementation/coordination with regard to particular

environmental measure/action plans

Khumani Environmental

Coordinator

Audits (Environmental, EMP Performance Assessment, etc.) and

surveillance

General Manager and Excecutives Authorisation of all rehabilitation projects



12 INFORMATION GAPS AND FURTHER ASSESSMENTS REQUIRED



REGULATION 31 (2)

2 m) A description of the assumptions, uncertainties and gaps in knowledge

The following section describes the information gaps that presented during the compilation

of this EIA/EMP report, as well as the specialist studies undertaken.

Information contained in this EIA/EMP document is based on technical information received

from the applicant as well as the outcomes of the updated specialist studies undertaken. The

baseline description of this report is largely based on previous specialist studies undertaken

over time.

The area where the Bruce Low Grade ROM Stockpile and Overburden Dump Expansion is

located has only undergone a desktop assessment and the status of the ecology in that area

has not been verified by field visits.



13 MOTIVATION FOR THE PROJECT

The project should be seen as a continuation of Khumani’s commitment made in the mining

right application and subsequent EMPs, to reclaim all low grade material as far as practically




beneficiation and still meet its approved production allocation. The approved Khumani Mining

Right Application, submitted by the mine, stipulated the mine’s intention to reuse low grade

material by reclaiming same in the future. The proposed project ensures that the mine fulfils

this commitment, and ensures that Khumani continues mining in a manner optimally utilising

its resource.



14 LIST OF SPECIALIST STUDIES UNDERTAKEN

The following specialist studies have been undertaken with regards to the proposed Upgrades

in 2014:

Biodiversity and Wetland Impact Assessment (2014);

Geohydrological Impact Assessment –Hydrocensus and Consceptual Model (2014);

Hydrological Impact Assessment – Update to the Storm Water Management

Plan(2014);

All these studies are provided in Appendix C.

Khumani is an existing mine and various specialist studies were undertaken over the years

and thus deemed sufficient to use in this EMP. Below is a list of all specialist studies that

were undertaken previously and used in the last amendment of the EMP date? (Table 14.1).

Assmang Ltd: Khumani Iron Ore Mine EIA/EMP Khumani Proposed Infrastructure Expansion


Table 14.1: Previous Specialist Studies

YEAR CONSULTANT SPECIALIST STUDY CONDUCTED FOR PN

2004 Clean Stream Groundwater Services

Geohydrological inputs to fulfill the EMP requirements for the Bruce-King-Mokaning iron ore project of Associated Manganese

EIA - The expansion of capacity, railway diversion and establishment of a local railway siding at Khumani Iron Ore Mine

08-191/08-343

2004 -

2005 Knight Piésold (Pty) Ltd BKM Project : Surface Water Evaluation For EMPR


08-191/08-343

2005 GCS - Ian Jones Soil/Pedological, Land Capability And Land Use Assessment Study


08-191/08-343

2005 GCS - Ian Jones For BKM – Sishen Project EIA - The expansion of capacity, railway diversion and establishment of a local railway siding at Khumani Iron Ore Mine

08-191/08-344

2005 Airshed Planning Professionals (Pty) Ltd

Air Quality Impact Assessment And Management Plan For BKM Mine In The Kathu District, Northern Cape


08-191/08-343

2005 F le R Malherbe Pr Eng Noise Impact Study For The BKM Mine EIA - The expansion of capacity, railway diversion and establishment of a local railway siding at Khumani Iron Ore Mine

08-191/08-343

2005 David Morris Report on a Phase 1 Archaeological Assessment of proposed mining areas on the farms Bruce, King, Mokaning and Parson, between Postmasburg and Kathu, Northern Cape.


08-191/08-343

2005 Newtown Landscape Architects Visual Impact Assessment for BKN Mine EIA - The expansion of capacity, railway diversion and establishment of a local railway siding at Khumani Iron Ore Mine

08-191/08-343



YEAR CONSULTANT SPECIALIST STUDY CONDUCTED FOR PN

2006 McGREGOR MUSEUM (ZOOLOGY DEPARTMENT)

Ecological Impact Assessment (Vertebrates): Proposed BKM Mine

Bruce Barrier Pillar EMP Amendment 06-405

2006 Botanical Report: Khumani Mine Project Bruce Barrier Pillar EMP Amendment 06-405

2009 GCS Khumani Hydrological Assessment EIA - The expansion of capacity, railway diversion and establishment of a local railway siding at Khumani Iron Ore Mine

08-191/08-343

2010 GCS Storm Water Management Plan Section A, Section B and Section C

Khumani EIA/EMP Amendment 10-070/10-314

2010 Geo Pollution Technnologies (Pty) Ltd

Evaluation of the hydrogeological data at Khumani Mine and the Development of a Groundwater Management Plan

Khumani Iron Ore Mine

Kum-09-403


Geophysical Survey on the farm King Khumani Iron Ore Mine KHU/11/096

2012 GCS Khumani Bruce Storm Water Management 11-361

2012 Scientific Aquatic Services CC Biodiversity: Faunal And Floral Specialist Studies And Action Plan For The Assmang Iron Ore Khumani Mine

Off-grade 2 Plant 12-408


Leaching Potential of the Paste Material Khumani Iron Ore Mine

KHU-12-319


Khumani Hydrocensus Survey and and interpretation of of data in the Kathu Area

Khumani Iron Ore Mine KhuHy-13-656

2014 GCS Ecological Assessment associated with the Khumani Mine Dump Extension


13-843

2014 GCS Khumani Hydrology (Surface water and Storm Water Management Plan) update


13-843


Hydrogeological Assessment Khumani Iron Ore Mine



15 ENVIRONMENTAL IMPACT STATEMENT This section of the report relates to Section 31 (2) of the GNR543 published in Government


REGULATION 31 (2)

2 n) A reasoned opinion as to whether the activity should or should not be authorised, and if it should

be authorized any conditions that should be authorized, any conditions that should be made in respect

of that authorization.

2 o) An environmental impact statement which contains :

i. A summary of the key finding of the Environmental Impact Assessment ; and

ii. A comparative assessment of the positive and negative implications of the proposed activity

and identified alternatives.

The proposed project is going to form part of the existing mining operations currently being

undertaken in the area. Khumani is operated in an environmental and social responsible

manner. The applicant is committed in fulfilling their corporate responsibility, which includes

social and environmental responsible practices. Khumani has all environmental permits and

licences in place and implements these conditions in their daily operations. Ongoing

monitoring is undertaken and annual performance assessments are conducted by independent

environmental consultants.

The project applied for is founded in the operations need and desire to optimally mine and

process its resources and the commitment to reuse material as far as practically possible.

Allthough the project will result in impacts on the environment, these impacts are both of

positive and negative nature.

The main impacts associated with the overall mining activites are:

1. Loss of species of conservation activities, for which the mine do have permits;

2. Loss of land for grazing potential, which should be re-esablished to an extent as part

of the closure objectives;

3. Due to the fact that the mine is not privileged to groundwater resources to

supplement water needs, the mine is purchasing water from the Sedibeng water

scheme, which places additional needs on the already strained system;

4. Increase in dust dispersion, although the mine is generally compliance with the dust

dispersion standards for a rural area;

5. Increase in the overall noise and vibrasions of the area; and

6. Permanent change in the geomorphology of the area



Noting the above, the mine is also contributing positively towards the bio-physical and socio-

economic environment. These activities are considered sustainable over the long term and

include:

1. Establishment of a long term and sustainable offset area in consultation with the

provincial authorities;

2. Ongoing establishment of endemic species on site;

3. Implimentaton of skill development programmes and training programmes, which will

benefit employees for their personal lives; and

4. Significant contribution to programmes and projects in line with the Integrated

Development Plan of the local municipalities as part of the mines; Social and Labour

Plan.

The specific project may contribute to direct impacts during the following phases:

Construction;

Operational;

Closure and decommisoning;

Direct Impacts during Construction

Topography


topsoil stripping and stockpiling, infrastructure establishment.


Direct impact: loss of topsoil (soil stripping and compation) in preparation for the

construction phase;


hydrocarbon spillages and/or leaks.

Hydrology

Direct impact: vegetation and topsoil clearance could obstruct drainage, cause

waterlogging and pollute water resources.

Geohydrology

Direct impact: reduction in recharge footprints.

Biodiversity




topsoil removal and vegetation disturbance.

Air Quality

Direct impact: increase in dust fallout from topsoil removal and vegetation removal.

Direct Impacts during Operations

Topography

Direct impact: topographical changes due to the increase and decrease in the

stockpile sizes.

Geohydrology

Direct impact: reduction in recharge footprints.

Air Quality

Direct impact: increase in dust fallout from the stockpiles.

Direct impact: Wetland destruction

Direct Impacts during Decommissioning and Closure

Topography





rehabilitation activities contributing to vehicular movement on site;




Direct impact: change in land use after mining; and

Direct impact: change in land capability as agricultural land will be lost once mining

related activities cease.

Hydrology

• Direct impact: reinstating the natural runoff patterns of the site.



Geohydrology

• Direct impact: groundwater quality impacts due to potential spillages and

contamination.

Biodiversity

• Direct impact: disruption to faunal and floral communities that have established on

site during the operational phase; and.

• Direct impact: re-establishment of faunal and floral communities during the

rehabilitation process.

Air Quality

• Direct impact: fugitive dust emissions; and

• Direct impact: dust entrainment from vehicles on site as a result of driving on

exposed surfaces.

Visual

• Direct impact: landscaping of the entire site and berm removals.

• Direct impact: removal of infrastructure from site and re-establishment of vegetated

areas.

Noise

• Direct impact: increased noise due to rehabilitation activities; and.

• Direct impact: reduction in noise levels due to mining cessation.

Social

• Direct impact: out-migration of job seekers as the mining operations cease;

• Direct impact: job losses; and

• Direct impact: a reduction in economic activities due to job losses and mine closure.

From the assessment of impacts throughout all the phases it is clear that though the impacts

may occur directly as a result of the proposed infrastructure upgrades, the impacts are mostly

of medium significance before mitigation. According to the assessment carried out by the

EAP the majority of the impacts can be reduced to a low significance with the appropriate

mitigation measures in places.

Not reclaiming the low grade material, will result in the presence of extensive infrastructure


EMPs. Reusing material throughout the life of mine, can be regarded as ongoing



rehabilitation, whist also resulting in an economic benefit to both the mine and iron ore




The EAPs and environmental consultants responsible for the compilation of this document,

and the associated PPP are of the opinion based on the presented specialist assessments and

impact assessment that the Khumani infrastructure upgrades should be authorised. The

following mitigation measures are crucial and should form part of the environmental

authroisation to ensure that the applicant manages impacts adeaquatly:

• Adhere to the updated Stormwater Management Plan

• Adhere to the Existing Environmental Management Plan

• Ensure that all design drawings include effective erosion control measures

• Adhere to the Emergency procedures Report and implement spill clean-up procedures

• Apply for relevant permits with authorities for the removal of indigenous tree species

• Major spills should be reported within 24hr to the Department of Water and Sanitation

and the NCDENC.



16 CONCLUSION

Khumani is operated in an environmental and social responsible manner. The applicant is

committed in fulfilling their corporate responsibility, which includes social and

environmental responsible practices. Khumani has all environmental permits and licences in

place and implements these conditions in their daily operations. Ongoing monitoring is

undertaken and annual performance assessments are conducted by independent

environmental consultants.


within their existing mining boundary area. The proposed upgrades on the farm Bruce include:


















These additional activities on the farms Bruce, King and Parson will require approval under

NEMA, the NWA and an Amendment to the EMP in terms of the MPRDA. The activities will not

influence the production output or Mining Works Programme of the mine.

The project applied for is founded in the operation’s need and desire to optimally mine and

process its resources with the commitment to re-process material as far as practically



possible. Although the project will result in impacts on the environment, these impacts are

both of positive and negative nature. The impacts are mostly of medium significance before

mitigation. According to the assessment carried out by the EAP the majority of the impacts

can be reduced to a low significance with the appropriate mitigation measures in place.

Not reclaiming the low-grade material will result in the presence of extensive infrastructure


EMPs. Reusing material throughout the life of mine, can be regarded as ongoing rehabilitation

whist also resulting in an economic benefit to both the mine and iron ore markets. This in

return will lower the mine’s financial environmental liability in terms of rehabilitation. The

overall project as presented in this report is therefore presented with the view of reducing

long term rehabilitation requirements as well as optimising beneficiation of the iron ore

mined.

The EAPs and environmental consultants responsible for the compilation of this document,

and the associated PPP are of the opinion based on the presented specialist assessments and

impact assessment that the Khumani Infrastructure upgrades should be authorised. The

following mitigation measures are crucial and should form part of the environmental

authroisation to ensure that the applicant manages impacts adeaquatly:

• Adhere to the updated Stormwater Management Plan

• Adhere to the Existing Environmental Management Plan

• Ensure that all design drawings include effective erosion control measures

• Adhere to the Emergency procedures Report and implement spill clean-up procedures

• Apply for relevant permits with authorities for the removal of indigenous tree species

• Major Spill should be reported within 24hr to the Department of Water and Sanitation

and the NCDENC.


13-843 30 September 2015

APPENDIX A: A3 FIGURES

Figure 1.1: locality map.

Figure 1.2: khumani mining right boundary area

Figure 2.1: proposed new infrastructure on the farm parsons

Figure 2.2: proposed new stockpiles on the farm king

Figure 2.3: proposed stockpile expansion on the farm bruce

Figure 4.1: geological map of the khumani mine area.

Figure 4.2: topographical map of the khumani mine area.

Figure 4.7: soil types.

Figure 4.8: current land use within the khumani mine area.

Figure 4.9: nfepa’s of the study area

Figure 4.10: surface water management areas of the greater mining right area.

Figure 4.13: hydrocensus points

Figure 8.1: surface water and groundwater monitoring points


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APPENDIX B: PROOF OF PPP


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APPENDIX C: SPECIALIST ASSESSMENTS

C1: groundwater studies

C2: hydrology

C3: ecology


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Khumani Iron Ore Mine Infrastructure Expansion Project ...€¦ · DRAFT REPORT FOR SUBMISSION...

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