licence number: mp 30/5/1/2/2/10115mr july 2020

TUMELO COAL MINES (PTY) LTD

PART 2: AMENDMENT REPORT

Application for Amendment of the Environmental

Authorisation and Environmental Management Plan Report

to include the partial pillar extraction of the No.2 Seam

LICENCE NUMBER: MP 30/5/1/2/2/10115MR

July 2020

FINAL FOR SUBMISSION

i

Prepared For Prepared by Independent EAP

Applicant Tumelo Coal Mines (Pty) Ltd Company Cabanga Environmental

Ref. No. MP 30/5/1/2/2/10115MR Author Jane Barrett

Contact Rowan Karstel Review Michelle Venter

Registered EAP (Reg. No. 2019/456)

Cert. Sci. Nat. (Reg. No. 114447)

Telephone 066 221 3596 Telephone 011 794 7534

E-Mail [email protected] E-Mail [email protected]

DISCLAIMER

This report has been prepared by Cabanga with all reasonable skill, care and diligence within the

terms of the contract with the client and taking into account of the resources devoted to it by

agreement with the client. We disclaim any responsibility to the client and any other in respect of

any matters outside the scope of the project.

This report is confidential to the client and we accept no responsibility of whatsoever nature to third

parties to whom this report, or any part thereof, is made known. Any such parties rely on the report

at their own risk.

DOCUMENT CONTROL

Version Date Reason for Change

Version 1 February 2020 Draft for Review and Comment

Version 2 July 2020 Final for Submission

mailto:[email protected]


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TABLE OF CONTENTS

1. INTRODUCTION ......................................................................................................................................... 10

1.1. Structure of this Report ......................................................................................................................... 10

1.2. Details of the Report Authors .............................................................................................................. 13

2. PROJECT DETAILS ...................................................................................................................................... 14

2.1. Project Location ................................................................................................................................... 15

2.2. Project Background ............................................................................................................................. 15

2.3. Project Scope ....................................................................................................................................... 16

2.4. Project Description ............................................................................................................................... 21

2.4.1. Mineral Reserve, Life of Mine and Mine Plan ............................................................................... 21

2.4.2. Coal Handling and Processing ...................................................................................................... 26

2.4.3. Mine Residue .................................................................................................................................... 26

2.4.4. Existing Services and Supporting Infrastructure ........................................................................... 27

2.4.4.1. Power Supply ............................................................................................................................... 27

2.4.4.2. Potable Water .............................................................................................................................. 27

2.4.4.3. Process Water .............................................................................................................................. 27

2.4.4.4. Sewage ......................................................................................................................................... 27

2.4.4.5. Waste Management ................................................................................................................... 28

2.4.4.6. Stormwater Management.......................................................................................................... 28

2.4.4.7. Roads and Transport ................................................................................................................... 28

2.4.4.8. Access Control ............................................................................................................................. 29

2.4.4.9. Administration, Workshop and Other Buildings ........................................................................ 29

2.4.4.10. Storage of Hazardous Goods .................................................................................................... 29

2.4.5. Emissions ........................................................................................................................................... 29

2.4.6. Operating Hours .............................................................................................................................. 29

2.4.7. Employment ..................................................................................................................................... 29

3. POLICY AND LEGISLATIVE CONTEXT ....................................................................................................... 30

3.1. Legislation Specific to Mining .............................................................................................................. 30

3.2. National Environmental Management Legislation .......................................................................... 32

3.2.1. The NEMA and EIA Regulations ..................................................................................................... 32

3.2.2. National Environmental Management Waste Act ..................................................................... 32

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3.2.3. National Water Act ......................................................................................................................... 33

3.2.4. National Environmental Management Air Quality Act .............................................................. 33

3.2.5. National Environmental Management Protected Areas Act .................................................... 34

3.2.6. National Environmental Management Biodiversity Act ............................................................. 34

3.2.7. Conservation of Agricultural Resources ....................................................................................... 34

3.2.8. National Heritage Resources Act .................................................................................................. 35

3.2.9. Other Relevant Legislation ............................................................................................................. 35

4. PUBLIC PARTICIPATION PROCESS............................................................................................................ 37

4.1. Identification of Stakeholders ............................................................................................................. 37

4.2. Notification of Stakeholders ................................................................................................................ 38

4.3. Document Review ................................................................................................................................ 38

4.4. Outstanding PPP ................................................................................................................................... 39

4.5. Summary of Issues Raised by I&APs .................................................................................................... 39

5. ENVIRONMENTAL ATTRIBUTES .................................................................................................................. 49

5.1. Climate and Meteorology .................................................................................................................. 49

5.2. Geology, Physiography and Topography ......................................................................................... 53

5.3. Soils, Land Use and Land Capability .................................................................................................. 55

5.4. Hydrology (Surface water) .................................................................................................................. 59

5.5. Geohydrology (Groundwater) ........................................................................................................... 64

5.6. Terrestrial Ecology ................................................................................................................................. 70

5.7. Freshwater Ecology .............................................................................................................................. 72

5.8. Air Quality and Noise ........................................................................................................................... 74

5.9. Sites of Archaeological and Cultural Significance .......................................................................... 76

5.10. Socio-Cultural Environment ............................................................................................................ 77

5.11. Environmental Sensitivity Map ....................................................................................................... 78

6. IMPACT ASSESSMENT ................................................................................................................................ 79

6.1. Impact Assessment Methodology ...................................................................................................... 79

6.2. Impact Identification ........................................................................................................................... 81

6.2.1. Geology Physiography and Topography ..................................................................................... 89

6.2.2. Soils, Land Use and Land Capability ............................................................................................. 90

6.2.3. Hydrology (Surface water) ............................................................................................................. 91

6.2.4. Geohydrology (Groundwater) ...................................................................................................... 91

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6.2.5. Terrestrial Ecology ............................................................................................................................ 95

6.2.6. Freshwater Ecology ......................................................................................................................... 95

6.2.7. Air Quality and Noise ...................................................................................................................... 95

6.2.8. Sites of Archeological and Cultural Significance ........................................................................ 98

6.2.9. Socio-Cultural Environment ............................................................................................................ 99

6.3. Impact Assessment .............................................................................................................................. 99

7. IMPACT MANAGEMENT ......................................................................................................................... 104

7.1. Impact Management Outcomes .................................................................................................... 104

7.2. Impact Management Actions .......................................................................................................... 107

7.3. Monitoring and Reporting Requirements ........................................................................................ 116

7.4. Environmental Awareness Plan ......................................................................................................... 118

7.5. Emergency Response ........................................................................................................................ 119

8. CLOSURE, REHABILITATION AND FINANCIAL PROVISION ................................................................... 124

8.1. Closure Objectives ............................................................................................................................. 124

8.2. Actions to Attain Closure Objectives ............................................................................................... 124

8.3. Financial Provision .............................................................................................................................. 125

9. ASSUMPTIONS, UNCERTAINTIES AND GAPS IN KNOWLEDGE ............................................................. 127

10. CONCLUSION AND RECOMMENDATIONS ....................................................................................... 127

10.1. Concluding Statement / Impact Statement ............................................................................. 128

10.2. Specific Conditions to be Included in the Amended Environmental Authorisation ............. 128

11. REFERENCES ......................................................................................................................................... 129

LIST OF TABLES

Table 1: Structure of this Report ..................................................................................................................... 11

Table 2: Structure of the EMP Report ............................................................................................................ 12

Table 3: Qualifications and Experience of the EAP ..................................................................................... 13

Table 4: Contact Details of the Applicant ................................................................................................... 14

Table 5: Properties included in the MRA (see Plan 2) ................................................................................. 17

Table 6: Summary details of project.............................................................................................................. 21

Table 7: Other Relevant legislation and guidelines ..................................................................................... 35

Table 8: Issues and Response Table .............................................................................................................. 40

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Table 9: Description of Soils (Digby Wells and Associates, 2006) ............................................................... 55

Table 10: Summary flood (peak flows and flood volume) calculations (Letsolo Environmental and

Water Services, 2020) ...................................................................................................................................... 60

Table 11: Water quality of surface water surveyed on 23 October 2019 (Shangoni Aquiscience, 2020)

........................................................................................................................................................................... 62

Table 12: Water quality of hydrocensus boreholes surveyed on 23 October 2019 (Shangoni

Aquiscience, 2020) .......................................................................................................................................... 66

Table 13: Water quality of groundwater monitoring boreholes (June 2019) ......................................... 68

Table 14: Summary of results of the field assessment ................................................................................ 73

Table 15: Matrix used to determine likelihood ............................................................................................. 79

Table 16: Matrix used to rate duration .......................................................................................................... 79

Table 17: Matrix used to rate scale ............................................................................................................... 80

Table 18: Matrix used to rate Intensity .......................................................................................................... 80

Table 19: Impact Identification ................................................................................................................... 82

Table 20: Impact Assessment ...................................................................................................................... 100

Table 21: Impact Management Outcomes ............................................................................................. 104

Table 22: Impact Management Actions .................................................................................................. 108

Table 23: Monitoring, Auditing and Reporting Summary ....................................................................... 116

Table 24: Emergency Response .................................................................................................................. 119

Table 25: Quantum for Financial Provision ................................................................................................. 126

Table 26: Advantage and disadvantages associated with the proposed project changes ............. 127

LIST OF FIGURES

Figure 1: Illustration of Bord-and-pillar mining (Metallurgical Resources Consulting, 2019) ................... 22

Figure 2: LoM Production (Metallurgical Resources Consulting, 2019) ..................................................... 22

Figure 3: Plant and stockpile area ................................................................................................................. 26

Figure 4: Overburden stockpile...................................................................................................................... 26

Figure 5: Lined PCD ......................................................................................................................................... 27

Figure 6 & 7: Package sewage treatment plant (10m3/day capacity) ................................................... 28

Figure 8: Overview of the workshop and administrative complex (as taken from the overburden

stockpile) .......................................................................................................................................................... 29

Figure 9: Diesel storage facilities at the workshop area ............................................................................. 29

Figure 10: Rainfall and Evaporation Data (Letsolo Environmental and Water Services, 2020) .............. 50

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Figure 11: Temperature and Relative Humidity (Rayten Environmental and Engineering Consultants,

2020) .................................................................................................................................................................. 50

Figure 12: Period Wind Rose Plot, January 2016 to December 2019 (Rayten Environmental and

Engineering Consultants, 2020) ..................................................................................................................... 51

Figure 13: Morning (AM) (00:00 - 12:00) and Evening (PM) (12:00 - 23:00) Period Wind Rose Plots for

January 2016 - December 2018 (Rayten Environmental and Engineering Consultants, 2020) ............. 52

Figure 14: Seasonal Variation of Winds for the Period January 2016 - December 2018 (Rayten

Environmental and Engineering Consultants, 2020) ................................................................................... 52

Figure 15: Dust Fallout Results (January 2018 – September 2019) (Rayten Environmental and

Engineering Consultants, 2020) ..................................................................................................................... 75

Figure 16: Examples of the various Subsidence Classes (G-Ro Geotechnical Services) ........................ 90

Figure 17: Model simulated drawdown cone in 2021 (Shangoni Aquiscience, 2020) ............................ 93

Figure 18: Model simulated drawdown cone in 2023 (Shangoni Aquiscience, 2020) ............................ 94

Figure 19: Model simulated groundwater pollution plume 2022 (Shangoni Aquiscience, 2020) .......... 94

Figure 20: Predicted Dust-Fall Rates associated with Tumelo Colliery (Rayten, 2020) ............................ 96

Figure 21: Predicted Daily Average PM2.5 Concentrations associated with Tumelo Colliery (Rayten,

2020) .................................................................................................................................................................. 97

Figure 22: Predicted Daily Average PM10 Concentrations associated with Tumelo Colliery (Rayten,

2020) .................................................................................................................................................................. 97

Figure 23: Predicted Annual Average PM2.5 Concentrations associated with Tumelo Colliery (Rayten,

2020) .................................................................................................................................................................. 98

Figure 24: Predicted Annual Average PM10 Concentrations associated with Tumelo Colliery (Rayten,

2020) .................................................................................................................................................................. 98

LIST OF ANNEXURES

Annexure 1: Curriculum Vitae of EAP.......................................................................................................... 131

Annexure 2: Public Participation Report..................................................................................................... 132

Annexure 3: Groundwater Report ............................................................................................................... 133

Annexure 4: Surface Water Report ............................................................................................................. 134

Annexure 5: Freshwater Ecological Assessment ........................................................................................ 135

Annexure 6: Air Quality Impact Assessment............................................................................................... 136

Annexure 7: Archaeological Impact Assessment ..................................................................................... 137

Annexure 8: Desktop Palaeontological Assessment ................................................................................. 138

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ACRONYMS AND ABBREVIATIONS

ACRONYM: DESCRIPTION:

AEL Atmospheric Emissions License

AIA Archaeological Impact Assessment

AMD Acid Mine Drainage

AQIA Air Quality Impact Assessment

BID Background Information Document

Ca Calcium

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

CBA Critical Biodiversity Area

CITES Convention on International Trade in Endangered Species of Wild Fauna and Flora

CM Continuous Miner

CSIR Council for Scientific and Industrial Research

CVB Channelled Valley Bottom Wetland

DARDLEA Department of Agriculture, Rural Development Land and Environmental Affairs

DEA Department of Environmental Affairs

DFA Development Facilitation Act, 1995 (Act No. 67 of 1995)

DMR Department of Mineral Resources

DHSWS Department of Human Settlements, Water and Sanitation

DWAF Department of Water Affairs and Forestry

DWS Department of Water and Sanitation

EA Environmental Authorisation

EAP Environmental Assessment Practitioner

EC Electrical Conductivity

EIA Environmental Impact Assessment

EMP Environmental Management Plan

ESA Ecological Support Area

F Fluoride

Fe Iron

GN Government Notice

GN704 Regulations on the use of water for mining and related activities aimed at the protection of

water resources

Ha Hectares

I&APs Interested and Affected Parties

IDP Integrated Development Plan`

viii


IHAS Integrated Habitat Assessment System

IUCN International Union for Conservation of Nature

kV Kilovolt

IWUL Integrated Water Use License

IWULA Integrated Water Use License Application

IWWMP Integrated Water and Waste Management Plan

km Kilometre

LED Local Economic Development

LoM Life of Mine

m Metres

mamsl metres above mean sea level

MBSP Mpumalanga Biodiversity Sector Plan

mbgl meters below ground level

mg/l Milligrams per litre

mm Millimetres

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

MPRDAA Mineral and Petroleum Resources Development Amendment Act, 2008 (Act No. 49 of 2008)

MRA Mining Right Area

mS/m Millisiemens per metre

MTPA Mpumalanga Tourism and Parks Agency Act, 2005 (Act 5 of 2005)

MVA Mega Volt Amp

Na Sodium

NAAQS National Ambient Air Quality Standards

NAEIS National Atmospheric Emissions Inventory System

NEMBA National Environmental Biodiversity Act, 2004 (Act 10 of 2004)

NEMAQA National Environmental Management: Air Quality Act, 2004 (Act No 39 of 2004)

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

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

NEMPAA National Environmental Management: Protected Areas Act (Act No. 57 of 2003)

NFEPA National Freshwater Ecosystem Priority Area

NHRA National Heritage Resources Act, (1999 Act 25 of 1999)

NLTA National Land Transport Act, 2008 (Act No. 5 of 2008)

NO3 Nitrate

NRTA National Road Traffic Act, 1996 (Act No. 93 of 1996)

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

PCD Pollution Control Dam

PIA Palaeontological Impact Assessment

PO3 Phosphate

PPb Parts per billion

PPP Public Participation Process

Reg. No. Registration Number

RoD Record of Decision

RoM Run of Mine

SAHRA South African Heritage Resources Agency

SAHRIS South African Heritage Information System

SANBI South African National Biodiversity

SAPAD South African Protected Areas Database

SCC Species of Conservation Concern

SDF Spatial Development Framework

SLP Social and Labour Plan

SO4 Sulphate

SPLUMA Spatial Land Use and Management Act, 2013 (Act No. 16 of 2013

STLM Steve Tshwete Local Municipality

TDS Total Dissolved Solids

WMA Water Management Area

WML Waste Management License

WRC Water Research Commission

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1. INTRODUCTION

Tumelo Colliery is an existing, operational mine located within the Nkangala District

Municipality and Steve Tshwete Local Municipality. The Mine has an approved Mining Right

(MP30/5/1/2/2/10115MR) and Environmental Management Plan (EMP) in terms of the Mineral

and Petroleum Resources Development Act, Act 28 of 2002 (MPRDA).

Further to this, Tumelo has Environmental Authorisation (EA) issued in terms of Section 24G of

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

17/2/10/24G NK03/2014, for auxiliary activities associated with the mining operations, including

the construction and operation of a package sewage plant.

The approved EMP addressed the underground mining (bord-and-pillar) of the reserves

associated with the No.2 Seam. Upon further assessment of the resource, Tumelo Coal Mines

(Pty) Ltd (“Tumelo”) now wish to amend the mine plan to include the partial pillar extraction

of the No.2 Seam (checkerboard layout).

No additional infrastructure is associated with the proposed project change and thus, no new

Listed Activities in terms of the NEMA; the Environmental Impact Assessment (EIA) Regulations,

2014 (as amended); and/or the National Environmental Management: Waste Act, Act No 59

of 2008 (NEMWA) will be triggered. However, as the partial pillar extraction of the No.2 Seam

will result in a change of Scope and possibly the nature of the environmental impacts, the

existing authorisation will need to be amended as per Regulation 31 of the EIA Regulations,

2014 (as amended) which states:

“An environmental authorisation may be amended by following the process

prescribed in this Part if the amendment will result in a change to the scope of a valid

environmental authorisation where such change will result in an increased level or

change in the nature of impact where such level or change in nature of impact was

not - (a) assessed and included in the initial application for environmental

authorisation; or (b) taking into consideration in the initial environmental

authorisation; and the change does not, on its own, constitute a listed or specified

activity.”

In light of the above, Tumelo submitted an application in terms of Regulation 31 of the EIA

Regulations, 2014 (as amended) to the Department of Mineral Resources (DMR) for a Part 2

Amendment on 11 December 2019.

1.1. Structure of this Report

This report has been compiled as per the requirements of Regulation 32 of the EIA

Regulations, 2014 (as amended) and aims to assess the impacts associated with the

proposed project changes.

11

Table 1: Structure of this Report

Requirement, as per the EIA Regulations 2014, as amended Section of this report

32(1) The applicant must within 90 days of receipt by the competent authority of the application made

in terms of Regulation 31, submit to the competent authority -

(a) a report, reflecting (i) an assessment of all impacts related to the

proposed change;

Section 6

(ii) advantages and disadvantages

associated with the proposed change; and

Table 26

(iii) measures to ensure avoidance,

management and mitigation of impacts

associated with such proposed change; and

Section 7

(iv) any changes to the EMPr; which report:

(aa) had been subjected to a public

participation process, which had been

agreed to by the competent authority, and

which was appropriate to bring the proposed

change to the attention of potential and

registered interested and affected parties,

including organs of state, which have

jurisdiction in respect of any aspect of the

relevant activity, and the competent

authority, and

(bb) reflects the incorporation of comments

received, including any comments of the

competent authority; or

Section 7

This report was

submitted to Interested

and Affected Parties

(I&APs) for review and

comment for an initial

period of 30 days (2

March – 1 April 2020),

this was however

suspended on 27

March 2020 due to the

COVID-19 lockdown.

These timeframes were

resumed on 5 June

2020, and extended by

an additional 21 days

(ending 2 July 2020) as

per the Directions

issued by the Minister

of Forestry, Fisheries

and the Environment1.

All comments received

during the review

period have been

included in Section 4.5.

(b) A notification in writing that the report will be submitted within 140 days

of receipt of the application by the competent authority, as significant

changes have been made or significant new information has been added

n/a

1 Directions regarding measures to address, prevent and combat the spread of COVID-19 relating to

permitting and licensing in terms of the National Environmental Management Act as issued by the

Minister of Forestry, Fisheries and the Environment on 5 June 2020 (Gazette No. 43412).

12

Requirement, as per the EIA Regulations 2014, as amended Section of this report

to the report, which changes or information was not contained in the

reported consulted on during the public participation process

contemplated in sub regulation (1)a and that the revised report will be

subjected to another public participation process of at least 30 days.

(2) In the event where sub regulation (1)b applies, the report, which reflects

the incorporation of comments received, including any comments of the

competent authority, must be submitted to the competent authority within

140 days of receipt of the application by the competent authority.

n/a

The required content of an EMP is provided in Appendix 4 of the EIA Regulations, 2014 (as

amended), and shown in Table 2 with cross-references to the relevant section(s) of this report.

Table 2: Structure of the EMP Report

No Requirement Section of this report

1 An EMP must comply with section 24N of the Act and include─

(a) details of–

(i) the EAP who prepared the EMP; and

(ii) the expertise of that EAP to prepare an EMP, including a

curriculum vitae;

Section 1.2 and

Annexure 1

(b) a detailed description of the aspects of the activity that are covered

by the EMP as identified by the project description;

Section 2

(c) a map at an appropriate scale which superimposes the proposed

activity, its associated structures, and infrastructure on the

environmental sensitivities of the preferred site, indicating any areas

that should be avoided, including buffers;

Plan 24

(d) a description of the impact management outcomes, including

management statements, identifying the impacts and risks that need

to be avoided, managed and mitigated as identified through the

environmental impact assessment process for all phases of the

development including —

(i) planning and design;

(ii) pre-construction activities;

(iii) construction activities;

(iv) rehabilitation of the environment after construction and where

applicable post closure; and

(v) where relevant, operation activities;

Section 7.1

(e) - (repealed) -

(f) a description of proposed impact management actions, identifying

the manner in which the impact management outcomes

contemplated in paragraph (d) will be achieved, and must, where

applicable, include actions to —

(i) avoid, modify, remedy, control or stop any action, activity or

process which causes pollution or environmental degradation;

Section 7.2

13

No Requirement Section of this report

(ii) comply with any prescribed environmental management

standards or practices;

(iii) comply with any applicable provisions of the Act regarding

closure, where applicable; and

(iv) comply with any provisions of the Act regarding financial

provision for rehabilitation, where applicable;

(g) the method of monitoring the implementation of the impact

management actions contemplated in paragraph (f);

Section 7.3

(h) the frequency of monitoring the implementation of the impact


Section 7.3

(i) an indication of the persons who will be responsible for the

implementation of the impact management actions;

Section 7.3

(j) the time periods within which the impact management actions

contemplated in paragraph (f) must be implemented;

Section 7.2

(k) the mechanism for monitoring compliance with the impact


Section 7.3

(l) a program for reporting on compliance, taking into account the

requirements as prescribed by the Regulations;

Section 7.3

(m) 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; and

Section 7.4

(n) any specific information that may be required by the competent

authority.

Section 0

1.2. Details of the Report Authors

Tumelo appointed Cabanga Environmental to act as the Independent Environmental

Assessment Practitioner (EAP) in respect of the application for Amendment. The details of the

persons who prepared this report are provided in Table 3. For details on the EAP’s past

experience, please refer to Annexure 1 for copies of the relevant Curriculum Vitae.

Table 3: Qualifications and Experience of the EAP

Author Jane Barrett

Highest qualification BSc Environmental Management: Botany Stream

Years’ experience 10+ years

Public Participation &

Document Review Michelle Venter

Highest qualification BSc Honours Geography

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Professional registration 8+ years

Years’ experience Registered EAP with the Environmental Assessment Practitioner’s

Association of South Africa (EAPASA) (Reg. No.: 2019/456)

Cert. Sci. Nat (Reg. No.: 114447)

GIS Lelani Claassen

Highest qualification BSc Honours Environmental Management

Professional registration Registered EAP (Reg. No.: 2018/153)

Pr.Sci.Nat. (Reg. No.: 121645)


Approval Ken van Rooyen

Highest qualification MSc Geography


Professional registration Pr.Sci.Nat. (Reg. No.: 121/93)

2. PROJECT DETAILS

The purpose of this section of the report is to provide details of the Location and Nature of the

Project and the proposed changes. Details of the Project Applicant are provided in Table 4

below.

Table 4: Contact Details of the Applicant

Applicant Tumelo Coal Mines (Pty) Ltd)

Registration No. 2003/003924/07

Primary Contact Rowan Karstel

Alternative Contact Kobie Badenhorst

Head Office Address 6 Dwars Street Krugersdorp

Mine Address Farm Boschmanskop 154 IS, Pullenshope

Central Coordinate of the Mine 26° 4'16.29"S

29°37'7.96"E

Postal Address P.O.Box 158, Krugersdorp, 1740

Telephone 066 221 3596

E-mail [email protected]

[email protected]



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2.1. Project Location

Tumelo Colliery is situated near the town of Pullens Hope within the Mpumalanga Province. The

mine falls within the Steve Tshwete Local Municipality (MP313) of the Nkangala District

Municipality (DC31), see Plan 1.

The approved Mining Right Area (MRA) includes various portions of the farm Boschmanskop

154 IS and extends over an area of 462.2117 Ha, refer to Table 5 and Plan 2 overleaf for details

of the directly affected properties. Mine infrastructure is largely limited to Portions 6 and 10 (RE),

with the exception of the access road which traverses Portions 1 and 14(RE).

The mine is located south-east of the Hendrina Power Station and shares a boundary with

Optimum Colliery. The East Woes-Alleenspruit River traverses the western boundary of the MRA,

discharging into the Boschmanskop Dam.

2.2. Project Background

Tumelo Colliery is an existing underground coal mine with an approved Mining Right (MP

30/5/1/2/2/10115MR) and associated EMP (Digby Wells and Associates, 2006). It is understood

that construction of the operations commenced in 2008 prior to commencement of

production in 2010 (GCS Water and Environmental (Pty) Ltd, 2014).

Underground mining of the No.2 Seam is currently undertaken using mechanised bord-and-

pillar methods. The No.2 seam is accessed via a box-cut decline positioned slightly upslope of

the Boschmanskop Dam. Coal is conveyed to surface where it is crushed and screened on site

before being trucked to market. Supporting infrastructure on site (Plan 3), includes:

• Access and haul roads;

• Workshop area incl. stores, fuel storage, washbay and waste management areas;

• Administrative complex incl. offices, change house, laundry and lamproom;

• Sewage treatment plant (modular package plant);

• Crushing and screening plant;

• Coal stockpile area;

• Weighbridge;

• Clean and dirty water diversion drains;

• Pollution control dam (PCD);

• Overburden stockpile;

• Erikson dam;

• Pump station;

• Substation; and associated power lines.

Tumelo Colliery was placed under care and maintenance at the end of February 2014 after

contract renewal terms could not be agreed between Tumelo and the mining contractor.

Activities recently resumed in the first quarter of 2019.

16

2.3. Project Scope

This Application relates to the following interrelated aspects:

• Application for Amendment of the EA and associated EMP in terms of Regulation 31

and 32 of the EIA Regulations, as amended; and

• Application for Amendment of the approved EMP and Mine Works Programme, in

terms of Section 102 of the Mineral and Petroleum Resources Development Act, Act

No. 28 of 2002 (MPRDA).

There are no new Listed Activities associated with changes in mine plan. This report will focus

on the impacts associated with the partial pillar extraction, while the impacts from the current

and past mining activities of the No.2 Seam will be informative of the baseline conditions of

the site and the cumulative nature of some of the potential impacts associated with the


17

Table 5: Properties included in the MRA (see Plan 2)

Farm Name Portion Surface Right Owner SG Code Property Extent

(Ha)

Extent incl. in MR

(Ha)

Boschmanskop 154 IS 10 (RE) Tumelo Exploration

(Pty) Ltd

T0IS00000000015400010 135.0015 135.0015

Boschmanskop 154 IS 6 Tumelo Coal Mines

(Pty) Ltd

T0IS00000000015400006 161.6182 145.5447

Boschmanskop 154 IS Portion 21 (of

Portion 6)

Optimum Coal Mine

(Pty) Ltd

T0IS00000000015400021 29.3884 0.2857

Boschmanskop 154 IS 14 (RE) Tumelo Coal Mines

(Pty) Ltd

T0IS00000000015400014 150.0259 150.0259


Portion 14)

Optimum Coal Mine

(Pty) Ltd

T0IS00000000015400023 30.4911 30.4911


Portion 14)

Jan Hedrik Uys T0IS00000000015400026 257.8224 0.8628

Total Extent of Mining Right Area 462.2117 Ha

18

Plan 1: Locality Map

19

Plan 2: Mining right Area (Regulation 2(2) Plan) showing affected properties

20

Plan 3: Existing Infrastructure

21

2.4. Project Description

The purpose of this section is to provide the public with sufficiently detailed information

regarding the proposed project changes to facilitate meaningful public participation; and to

provide the relevant decision-making authorities with sufficiently detailed information to

enable informed consideration of the application, and decision-making.

Table 6: Summary details of project

Item Detail

Type of mineral Coal

Mining method Underground bord-and-pillar using continuous miners,

with partial pillar extraction

Depth of the mineral

below surface

The average depth of the 2 Seam to surface is

approximately 50 metres.

Geological formation

Tumelo is situated to the north of the Smithfield ridge on

the north-eastern edge of the Springs–Witbank Coal

field. The area is part of the Karoo basin.

Life of mine 4 Years (this includes the proposed pillar extraction)

Production rate 35 000 to 44,000 Run-of-Mine (RoM) tons / month

Market Domestic (Eskom) and Export .

2.4.1. Mineral Reserve, Life of Mine and Mine Plan

Plan 4 indicates the mining right area outlined in pink. The remaining No.2 seam reserves, which

are currently being mined are indicated in purple, whilst the previously mined out areas are

indicated in yellow.

Currently mining is undertaken via mechanised bord-and-pillar method using continuous

miners. In mechanised bord-and-pillar mining, extraction is achieved by developing a series of

roadways (bords) in the coal seam and connecting them by splits (cut-through) to form pillars

(Figure 1). These pillars are left behind as part of a primary roof support system. Later in the life

of mine these pillars will be partially extracted to optimize the reserve. The pillar extraction will

be undertaken on a checkerboard layout on retreat.

The proposed change in mine plan to include partial pillar extraction will maximise the

exploitation of the reserve extending the life of mine (LoM) by an additional one year.

Geotechnical Investigations were completed for the proposed pillar extraction in 2013 and

2019. These reports concluded that no pillar extraction should be undertaken at a depth of

less than 40m; within a horizontal distance of D/2.7 of any surface infrastructure or in areas

where the Safety Factor or width-to height ratio is below 1.6 or 2.2, as such pillar extraction in

these areas has been excluded from the final mine plan. Plan 5 shows the proposed pillar

extraction areas in red.

22

Figure 1: Illustration of Bord-and-pillar mining (Metallurgical Resources Consulting, 2019)

The mine is operational and requires no new development to maintain the current production.

The total production for the year 2020 will be 44 000 tons with two sections. The production will

decrease to 35 000 in 2021 with one continuous miner (CM) section. Partial pillar extraction will

commence once approvals are in place. The forecast for partial pillar extraction is during the

third quarter of 2022 (Metallurgical Resources Consulting, 2019). Plan 6 depicts the final mine

plan.

The mine is operational and Figure 2 below reflects the production expected. No build up or

ramp up of production is required.

Figure 2: LoM Production (Metallurgical Resources Consulting, 2019)

23

Plan 4: No.2 Seam Reserve as per the approved EMP and Mine Works Programme

24

Plan 5: Proposed Pillar Extraction

25

Plan 6: Mine Plan showing the proposed pillar extraction in relation to the 2 Seam Mine Plan

26

2.4.2. Coal Handling and Processing

The continuous miners cut the coal and load it onto shuttle cars which tram the coal to a

feeder breaker, from here the coal is crushed and loaded onto a conveyor belt system which

takes it to surface. On surface the coal is temporarily stockpiled before being crushed and

screened at the plant (80 000 tonnes per month capacity).

The RoM material is loaded into a hopper. A belt feeder extracts the material onto a conveyor

feeding a vibrating screen where the material is sized to -50mm before reporting to the product

conveyor. Oversized material (+50mm) is crushed before reporting to the same product

conveyor (Metallurgical Resources Consulting, 2019).

No changes to the coal handling and processing facilities are anticipated.

Figure 3: Plant and stockpile area

2.4.3. Mine Residue

Overburden from the construction of the existing boxcut has been stockpiled on site for reuse

during decommissioning and closure.

As outlined above, processing activities are limited to crushing and screening thus no

additional mine residue facilities are anticipated.

Figure 4: Overburden stockpile

27

2.4.4. Existing Services and Supporting Infrastructure

Existing services and infrastructure will continue to be utilized on site, these are briefly discussed

below.

2.4.4.1. Power Supply

Eskom supplies power to the Tumelo Colliery. Electricity is distributed to the mine via a

substation, mini-substation and 11 kV overhead powerlines.

The mine has an allocation of 4 MVA from Eskom, the total power requirement is 2 MVA. Thus,

no upgrades are required for the project.

2.4.4.2. Potable Water

Water for domestic and potable purposes is abstracted from a borehole, as per the

approved water use license. The proposed project changes will not result in an increase in

the number of employees and it is anticipated that the existing borehole will meet the

capacity requirements.

2.4.4.3. Process Water

Process water requirements are limited to that of dust suppression and for use in underground

mining processes.

Water found in the underground workings is pumped to the existing pollution control dam

(PCD) on surface which has a capacity of 3,200 m3, excluding freeboard. Once settled the

water within the PCD is pumped to the Erikson Dam (140 m3) for use underground (GCS Water

and Environmental Services (Pty) Ltd, 2018).

Water for dust suppression purposes is abstracted directly from the PCD.

Figure 5: Lined PCD

2.4.4.4. Sewage

Sewage from the administrative complex and change houses are managed via a system of

septic tanks. From here the water is pumped to a self-contained sewage treatment plant,

with a capacity of 10m3/day. Treated effluent from the sewage treatment plant is disposed

into the PCD for re-use (GCS Water and Environmental Services (Pty) Ltd, 2018).

28

The proposed project changes will not result in an increase in the number of employees and

it is anticipated that the existing sewage treatment plant will meet the capacity

requirements.

Figure 6 & 7: Package sewage treatment plant (10m3/day capacity)

2.4.4.5. Waste Management

Waste streams generated at Tumelo Colliery include sewage waste, general domestic

waste, hazardous waste and mineral waste. Sewage waste and mineral waste are discussed

in the preceding sections.

General domestic waste and hazardous waste bins are provided throughout the site to

ensure separation of general and hazardous waste at source. Bins are emptied into skips on

site (still separated as either general or hazardous waste). Skips are removed from site by

contractors for disposal to relevant recyclers / landfill (as the case may be).

No landfill sites have/will be constructed on site.

2.4.4.6. Stormwater Management

Clean and dirty stormwater on site is separated in terms of GN704 (Regulations on Use of

Water for Mining and Related Activities Aimed at the Protection of Water Resources). A

diversion berm has been constructed upslope of the mine infrastructure area to divert clean

water around the dirty footprint area. Water falling within the dirty footprint area is

channelled via a system of berms and trenches to the existing PCD. The existing PCD has

been designed to cater for a 1:50 year storm event and maintain a 0.8m freeboard (GCS

Water and Environmental Services (Pty) Ltd, 2018).

2.4.4.7. Roads and Transport

Tumelo Colliery is accessed via the D2539 just south of the Hendrina Power Station. The access

road is approximately 3km in length, tarred and in fair condition.

Internal vehicle movement at Tumelo Colliery is via a series of paved and unpaved roads. No

additional haul or access roads are associated with the project.

Product coal will continue to be transported off-site by truck to nearby power stations (local

market) and/or the Forzando North Colliery (international market).

29

2.4.4.8. Access Control

The mine surface infrastructure area is fenced off and access controlled via a security

checkpoint.

2.4.4.9. Administration, Workshop and Other Buildings

Ancillary infrastructure on site includes the administrative complex, change houses, parking

area, workshop, stores, weighbridge, wash bay and water reticulation for potable water

supply (jojo tanks). These will continue to be utilised for the life of mine.

2.4.4.10. Storage of Hazardous Goods

Diesel storage facilities (1 x 23m3 tank) are located at the workshop, and are appropriately

bunded.

Chemicals used in the workshop are stored in designated areas, the appropriate Material

Safety Data Sheets (MSDS) are kept on file.

Figure 8: Overview of the workshop and

administrative complex (as taken from the

overburden stockpile)

Figure 9: Diesel storage facilities at the

workshop area

2.4.5. Emissions

No scheduled gaseous emissions will take place on site. Vehicles and machinery emit fumes

but these will continue to be serviced and maintained regularly to keep these emissions

within the relevant vehicle/machine’s specifications.

Dust is and will continue to be monitored and managed on site to ensure these are within

the standards set by the Department of Environmental Affairs (DEA) as well as that of the

Mine Health and Safety Act, 1996.

2.4.6. Operating Hours

Tumelo Colliery operates two, ten-hour shifts per day, 5 days a week

2.4.7. Employment

Currently one hundred and twenty-five (125) people are employed at Tumelo Colliery. The

proposed project changes will not contribute to job creation but rather focus on the

retention of jobs by prolonging the LoM (MTS Holdings (Pty) Ltd, 2019).

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3. POLICY AND LEGISLATIVE CONTEXT

Section 24 of the Constitution of the Republic of South Africa states that:

Everyone has the right to (a) an environment that is not harmful to their health or well-

being; and (b) to have the environment protected, for the benefit of present and future

generations, through reasonable legislative and other measures that –

• Prevent pollution and ecological degradation;

• Promote conservation; and

• Secure ecologically sustainable development and use of natural resources

while promoting justifiable economic and social development.

To give effect to Section 24 of the Constitution, several laws have been promulgated towards

realisation of these rights, which broadly speaking relates to:

• Development and Use of Resources (in this case, mining);

• Environmental Management; and

• Conservation and Protected Areas.

The following environmental legislation and guidelines were considered and integrated into

the EMP to ensure compliance and best practice:

3.1. Legislation Specific to Mining

This section refers to the MPRDA and its Regulations (GNR527, 23 April 2004 as amended by:

GN R.1288 dated 29 October 2004; GN R.1203 dated 30 November 2006; and GN R.349 dated

18 April 2011), as well as the Mineral and Petroleum Resources Development Amendment Act,

2008 (Act No. 49 of 2008) (MPRDAA).

The MPRDA is the predominant piece of legislation dealing with the acquisition of rights to

search for, extract and process mineral resources in South Africa. The MPRDA came into effect

on 1 May 2004. The MPRDA holds that mineral resources in South Africa belong to the nation

and that the State is the custodian thereof.

Any person may apply for a mining right by following the application procedure set out in the

MPRDA and administrated by the DMR. Applications for rights must be accepted if the

application requirements are met, and if no other person holds a prospecting right, mining

right, mining permit or retention permit for the same mineral on the same land. Once the DMR

accepts an application, the DMR will notify the applicant to conduct an EIA, and submit an

EMP to the DMR for consideration. The DMR will further instruct the applicant to consult with

I&APs.

In general terms, the Minister must grant a mining right if—

a. the mineral can be mined optimally in accordance with the mining work

programme;

b. the applicant has access to financial resources and has the technical ability to

conduct the proposed mining operation optimally;

c. the financing plan is compatible with the intended mining operation and the

duration thereof;

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

damage to the environment;

e. the applicant has provided financially and otherwise for the prescribed social

and labour plan;

f. the applicant has the ability to comply with the relevant provisions of the Mine

Health and Safety Act, 1996 (Act No. 29 of 1996);

g. the applicant is not in contravention of any provision of this Act; and

h. the granting of such right will further the objects referred to in section 2(d) and

(f)2 and in accordance with the charter contemplated in section 100 and the

prescribed social and labour plan.

Tumelo holds a valid Mining Right for its operations, Reference: MP 30/5/1/2/2/10115MR,

comprising of 462.2117 Ha over various portions of the farm Boschmanskop 154 IS.

Section 102 of the MPRDA states that:

A reconnaissance permission, prospecting right, mining right, mining permit, retention

permit, technical corporation permit, reconnaissance permit, exploration right and

production right work programme; mining work programme, environmental

management programme, and environmental management plan may not be

amended or varied (including by extension of the area covered by it or by the addition

of minerals or a share or shares or seams, mineralised bodies, or strata, which are not

at the time the subject thereof) without the written consent of the Minister.

The existing and approved EMP report (Digby Wells and Associates, 2006) pertains to

underground mining of the No.2 seam via bord-and-pillar methods. Upon further assessment

of the resource, Tumelo now wish to amend the mine plan to include the partial pillar

extraction of the No.2 Seam.

This constitutes a change in the approved EMP and Mine Works Programme, Tumelo must

therefore obtain the Minister’s consent in terms of Section 102 of the MPRDA prior to effecting

the change.

This report will be submitted to the DMR in respect of the application for amendment of the

approved EMP, to allow for the partial pillar extraction at Tumelo Colliery.

There are several other pieces of legislation which deal with such issues such as royalties (the

Mineral and Petroleum Resources Royalty Act, 2008), title registration (the Mining Titles

Registration Act, 1967), and health and safety (the Mine Health and Safety Act, 1996). These

issues constitute specialist fields on their own and will not be discussed in further detail.

The Mineral and Petroleum Resources Development Amendment Act, 2008 (Act No. 49 of

2008) (MPRDAA) amended certain sections of the MPRDA to make the Minister of Mineral

Resources the competent authority for implementing environmental matters in terms of the

NEMA as it relates to mining and prospecting operations and incidental activities, and to align

the MPRDA with NEMA.

2 Section 2(d)”and (f): The objects of this Act are to— (d) substantially and meaningfully expand

opportunities for historically disadvantaged persons, including women, to enter the mineral and

petroleum industries and to benefit from the exploitation of the nation’s mineral and petroleum resources;

(f) promote employment and advance the social and economic welfare of all South Africans.

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3.2. National Environmental Management Legislation

The most prominent legislation dealing with environmental management and impact

assessment are discussed below.

3.2.1. The NEMA and EIA Regulations

The NEMA, as amended, was set in place in accordance with Section 24 of the Constitution of

the Republic of South Africa. Certain environmental principles under NEMA have to be

adhered to, to inform decision making for issues affecting the environment. Section 24 (1)(a)

and (b) of NEMA state that the potential impact on the environment and socio-economic

conditions of activities that require authorisation or permission by law and which may

significantly affect the environment, must be considered, investigated and assessed prior to

their implementation and reported to the organ of state charged by law with authorizing,

permitting, or otherwise allowing the implementation of an activity.

The Minister of Environmental Affairs published new EIA Regulations in 2014 and amendments

to the Regulations and Listed Activities in 2017. The undertaking of Listed Activities in terms of

the EIA Regulations requires Environmental Authorisation to be obtained prior to

commencement.

On the 2nd September 2014, the One Environmental System for mining came into effect

making the NEMA the overarching National environmental legislation. In terms of Section 12(4)

of the NEMA Amendment Act, 2008 (Act No. 62 of 2008) an EMP approved in terms of the

MPRDA, prior to the One Environmental System coming into effect, is regarded as having been

approved in terms of NEMA. The existing operations at Tumelo Colliery are therefore deemed

to have been approved in terms of NEMA, by virtue of alignment with the activities described

in the approved EMP.

Further to this, Tumelo has an EA issued in terms of Section 24G of NEMA (Ref. 17/2/10/24G

NK03/2014) for auxiliary activities associated with the mining operations, including the

construction and operation of a sewage treatment plant.

Changes to the approved activities (e.g. change in mine plan to include partial pillar

extraction) will be subject to an Amendment in terms NEMA and the EIA Regulations, 2014 (as

amended).

There are no new Listed Activities associated with the proposed project changes.

A Part 2 Amendment as per Regulation 31 of the EIA Regulations, 2014 (as amended) is

therefore relevant to the application. Regulation 32 further set out the requirements for

Reporting, Timeframes, and Public Participation.

3.2.2. National Environmental Management Waste Act

The National Environmental Management Waste Act, Act 59 of 2008 (NEMWA) provides for

national norms and standards for regulating the management of waste, and the licensing and

control of waste management activities.

Regulations to the NEMWA identifies a number of activities which require a Waste

Management License (WML) prior to being undertaken, this includes the establishment of a

residue stockpiles and/or deposits resulting from activities which require a mining right in terms

of the MPRDA. It is noted, however that Tumelo already has an approved Mining Right and

33

EMP and that an EMP approved in terms of the MPRDA shall be deemed to have been

approved and issued in terms of the NEMWA (according to the transitional provisions of GN

R.633 – Amendments to the list of waste management activities that have or are likely to have

a detrimental effect on the environment). The existing stockpiles at Tumelo Colliery are

therefore deemed to have been approved in terms of NEMWA, by virtue of alignment with the

activities described in the approved EMP.

3.2.3. National Water Act

The National Water Act, Act 36 of 1998 (NWA) provides for the sustainable and equitable use

and protection of water resources. It is founded on the principle that the National Government

has overall responsibility for and authority over water resource management, including the

equitable allocation and beneficial use of water in the public interest, and that a person is only

entitled to use water, without a license, if the use is permissible in terms of Section 22 of the

NWA.

The competent authority in respect of water use is the Department of Human Settlements,

Water and Sanitation (DHSWS, previously the Department of Water and Sanitation, DWS, and

the Department of Water Affairs and Forestry, DWAF).

Tumelo was issued with an Integrated Water Use License (IWUL) (Licence No.24090831) by the

Department of Water and Sanitation (DWS 3 ) on 1 October 2010. This was subsequently

amended on 4 September 2017. The IWUL was issued for a period of ten (10) years, expiring on

1 October 2020, as such an application to review and amend the IWUL will be compiled for

the operations.

Specific regulations made in terms of Section 26(1) of the NWA pertain to the use of water for

mining and related activities were published on 4 June 1999 (GNR 704). The provisions of GN704

have been incorporated into the EMP and surface water management plan where possible.

Where the implementation of provisions of GN704 is not possible, the Integrated Water Use

License Application (IWULA) must include application for exemption from the relevant

provisions, as per Regulation 3 of GN704.

Regulation 2 of GN704 stipulates the Mine’s obligations in terms of notifications to the DHSWS,

if changes take place at the Mine, or if incidents occur.

There are existing activities at Tumelo Colliery that require exemption from GN704, which are

not currently included in the approved WUL. These mainly relate to the existing infrastructure

area, which marginally encroaches on the 100m regulated zone of a Channelled Valley

Bottom wetland. The application to review and amend the WUL should therefore include

application for exemption of the relevant provisions of GN704, where necessary.

3.2.4. National Environmental Management Air Quality Act

The DEA, the provincial environmental departments and local authorities (district and local

municipalities) are separately and jointly responsible for the implementation and enforcement

of various aspects of National Environmental Management Air Quality Act, Act 39 of 2004

(NEMAQA). A fundamental aspect of the new approach to the air quality regulation, is the

establishment of National Ambient Air Quality Standards (NAAQS) (GN R.1210 of 2009). These

3 Currently the Department and Human Settlements, Water and Sanitation, DHSWS, and formerly the

Department of Water Affairs and Forestry, DWAF.

34

standards provide the goals for air quality management plans and also provide the

benchmarks by which the effectiveness of these management plans are measured.

Further to this, Activities that are identified in GN R.983 require an Atmospheric Emissions License

(AEL) to be issued in terms of NEMAQA. It is noted that the activities being undertaken at

Tumelo Colliery do not constitute a Listed Activity and the mine does not require an AEL in

terms of the NEMAQA. However, the site does fall within the Highveld Air Quality Priority Area,

and as such an Air Quality Impact Assessment (AQIA) has been completed for the operations

(refer to Annexure 6).

GN R.701 declared greenhouse gasses as priority air pollutants. The greenhouse gas reporting

regulations (GN R.275) identifies Mining and Quarrying as one of the industries who must report

their greenhouse gas emissions to the competent authority should they exceed the stipulated

threshold.

The National Atmospheric Emission Reporting Regulations, 2015 identifies all mines as a Group

C Emission Source, and requires the Mine to report to the National Atmospheric Emissions

Information System (NAEIS) on an annual basis.

3.2.5. National Environmental Management Protected Areas Act

The National Environmental Management Protected Areas Act, Act 57 of 2003 (NEMPAA) (as

amended) provides for the protection and conservation of ecologically viable areas of South

Africa’s biological diversity, natural landscapes and seascapes. It further provides for the

establishment of a register of protected areas (SAPAD), the management of those areas and

for intergovernmental co-operation and public consultation in matters concerning protected

areas.

There are no formally protected areas in the immediate vicinity of Tumelo Colliery. The closest

protected area is the Heyns Private Nature Reserve, located approximately 23km north-west

of the operations.

3.2.6. National Environmental Management Biodiversity Act

The National Environmental Biodiversity Act, Act 10 of 2004 (NEMBA) provides for the

management and conservation of South Africa’s biodiversity within the framework of the

NEMA. The Act relates to the protection of species and ecosystems that warrant national

protection, among others.

Certain Fauna and Flora Species of Conservation Concern (SCC) are known to occur in the

general vicinity of the site however, none were encountered during the vegetation surveys

completed prior to construction of the mine (Digby Wells and Associates, 2006). No new

infrastructure is proposed, and thus the footprint of disturbance will remain unchanged.

3.2.7. Conservation of Agricultural Resources

Conservation of Agricultural Resources Act, Act 43 of 1983 (CARA) provides for control over

the utilization of the natural agricultural resources of the Republic to promote the conservation

of soil, water sources and vegetation, and the combating of weeds and invader plants.

Measures for conservation have been included in the EMP where relevant.

35

3.2.8. National Heritage Resources Act

The National Heritage Resources Act, Act 25 of 1999 (NHRA) aims to promote good

management and preservation of the country’s Heritage Resources. Section 38 of the NHRA

sets out guidelines for heritage resource management and outlines the circumstances under

which a heritage impact assessment is required.

According to the approved EMP (Digby Wells and Associates, 2006) a site survey was

undertaken on 29 October 2002. More recently an Archaeological Impact Assessment (AIA)

was undertaken by Archaetnos Culture and Cultural Resources Consultants in April 2020. The

findings and recommendations of the AIA have been included in this report.

3.2.9. Other Relevant Legislation

In addition to the Laws and Guidelines discussed above, Table 7 summarises some of the

other key legislation and guidelines relevant to Tumelo.

Table 7: Other Relevant legislation and guidelines

APPLICABLE LEGISLATION AND GUIDELINES

USED TO COMPILE THE REPORT

HOW THIS DEVELOPMENT COMPLIES WITH THE

LEGISLATION AND GUIDELINES

NEMA: Public Participation Guidelines

(GNR807).

Guidelines have been and will be followed during the

Public Participation Process (PPP).

Department of Environmental Affairs (2017),

Public Participation guideline in terms of

NEMA EIA Regulations, Department of

Environmental Affairs, Pretoria, South Africa.

Department of Environmental Affairs,

Department of Mineral Resources,

Chamber of Mines, South African Mining

and Biodiversity Forum, and South African

National Biodiversity Institute. 2013. Mining

and Biodiversity Guideline: Mainstreaming

biodiversity into the mining sector. Pretoria.

The Mining and Biodiversity Guideline was considered

and acknowledged in the compilation of the EMP.

This Application relates to a Part 2 Amendment, mining

activities will be limited to the existing MRA. No new

infrastructure is proposed, and thus the footprint of

disturbance will remain unchanged.

Spatial Land Use and Management Act,

2013 (Act No. 16 of 2013) (SPLUMA)

SPLUMA aims to develop a framework to govern

planning permissions and the lawful use of land. In terms

of SPLUMA Tumelo should ensure that the surface right

areas where mining activities are undertaken is

approved as such.

Restitution of Land Rights Act, 1994; the

Restitution of Land Rights Amendment Act,

2014; the Land Reform (Labour Tenants)

Act, 1996; and the Extension of Security of

Tenure Act, 1997.

The Restitution of Land Rights Act, Act No. 22 of

1994 provided that all claims had to be lodged by 31

December 1998. The Amendment Act (Restitution of

Land Rights Amendment Act, Act No. 15 of 2014)

effectively sought to re-open submissions until 30 June

2019. The Validity of the Amendment Act was however

challenged in the Constitutional Court and

subsequently repealed on 28 July 2016.

36





The Constitutional Court ordered that claims lodged

between 01 July 2014 – 27 July 2016 are validly lodged

but prohibited the Commission from processing these

claims until such time that it has finalised all claims

lodged on or before 31 December 1998 (“old claims”);

or until Parliament passes a new law providing for the re-

opening of lodgement of land claims.

Consultation with the Commission has confirmed that a

“new claim” was lodged over the MRA in terms of the

Amendment Act but has not been processed as yet.

Local Government Municipal Systems Act,

2000 (Act No. 32 of 2000) as amended

The Act requires local government to compile spatial

development framework (SDF) which must include the

provision of basic guidelines for a land use

management system for the municipality. The

objectives of an SDF are to promote sustainable

functional and integrated human settlements, maximise

resource efficiency, and enhance regional identity and

unique character of a place. In addition, Municipalities

are required to develop Integrated Development Plans

(IDPs) which is a government co-ordinated approach to

planning that seeks to ensure the economic and social

enhancement of all within their jurisdiction. It provides a

land use framework, considers infrastructure

development, and the protection of the environment.

This application pertains to the continuation of activities

at the existing Tumelo Colliery. The projects will result in

an extended LoM and continuation of employment at

the mine.

Development Facilitation Act, 1995 (Act

No. 67 of 1995) (DFA)

The Act promotes the integration of the social,

economic, institutional & physical aspects of land

development and also promotes integrated land

development in rural and urban areas in support of

each other.

The Act encourages the availability of residential &

employment opportunities in close proximity to or

integrated with each other, while optimising the use of

existing resources including such resources relating to

agriculture, land, minerals, bulk infrastructure, roads,

transportation and social facilities.


at the existing Tumelo Colliery. The projects will result in

an extended LoM and continuation of employment at

the mine.

37





NEMA Regulations pertaining to the

financial provision for prospecting,

exploration, mining or production activities

(GNR1147 –20 November 2015) (as

amended).

Financial Provision has been calculated for the year

ending February 2020 and is discussed in Section 8.

National Road Traffic Act, Act No. 93 of

1996 (NRTA) and National Land Transport

Act, Act No. 5 of 2008 (NLTA)

These Acts relate specifically to the planning and

development of transport systems and the safe use of

roads.


at the existing Tumelo Colliery. No changes are

proposed to the infrastructure or operational activities

on surface and thus no additional impacts are

associated with regards to the traffic.

Mpumalanga Tourism and Parks Agency

Act, Act 5 of 2005 (MTPA Act) and

Mpumalanga Nature Conservation Act,

Act 10 of 1998

The Mpumalanga Nature Conservation Act was

considered, management measures to protect the

natural fauna and flora in line with the Act have been

included in the EMP, where relevant.

Nkangala District Municipality: Air Quality

Management By-law (Provincial Gazette

No. 2701 of 10 June 2016)

The by-law states that any person who is responsible for

causing air pollution or creating a risk of air pollution

within the municipality must take reasonable measures

to:

• Prevent any potential air pollution from

occurring; or

• Where the causing of any air pollution is

permitted, not prohibited, or cannot be

reasonably avoided or stopped, to minimise

that pollution.

Relevant mitigation measures have been included in

the EMP.

4. PUBLIC PARTICIPATION PROCESS

The public participation process (PPP) that has been undertaken to date is detailed in

Annexure 2. The PPP aims to involve the authorities and Interested and Affected Parties (I&APs)

in the Amendment process; and determine their needs, expectations and perceptions. An

open and transparent process was and will be followed at all times and is based on the

reciprocal dissemination of information. The following steps comprise the PPP undertaken for

the Amendment application:

4.1. Identification of Stakeholders

The DMR has been identified as the competent authority in this application as it relates to

NEMA and the MPRDA. The DHSWS is the lead authority with regards to the water use license

38

application. Other Local and Regional authorities were identified and included in the I&AP

register, and notified of the proposed project changes by means of the Background

Information Document (BID).

Landowners of the directly affected and adjacent land portions were identified through deeds

office searches, previous I&AP databases and on-site consultations. Community

representatives, including the local Ward Councillors, community forums and resident

associations were identified and included in the I&AP register.

The Land Claims Commissioner was contacted to determine whether any land claims have

been registered over the MRA. The response from the Commission has been included in the

issues and response table overleaf, Table 8.

4.2. Notification of Stakeholders

BIDs were compiled in English, Afrikaans and Zulu and were distributed via e-mail and post to

all the identified stakeholders for whom contact information could be obtained.

Hard Copies were hand delivered on 07 February 2020 to affected parties (land owners and

users) where possible. In some cases, no one could be located on the property; in such a case

the BID was attached to the property gate or left in a post box (when available).

A Newspaper advertisement (in Zulu and English) was published in the Witbank News on 07

February 2020, conveying the same information as the BID (albeit abbreviated). The Witbank

News circulates 26,000 copies to areas including Arnot, Belfast, Bronkhorstspruit, Groblersdal,

Hendrina, Kriel, Loskop, Marble Hall, Middelburg, Ogies, Pullens Hope, Rietspruit, Stoffberg, Van

Dyksdrift, Witbank, Phola and Wonderfontein.

A2 posters, written in Zulu and English were placed on the site boundary fence and at other

public locations, including:

• Pullens Hope Public Library; and

• Nkangala District Municipality.

The purpose of the announcement documentation mentioned above was to:

• Invite members of the public to register as I&APs;

• Inform them of the proposed amendment application and associated regulatory

processes; and

• Initiate a process of public consultation to record perceptions and issues.

A public meeting, in the form of an open-day was held on the 04 March 2020 at the Eskom

Community Hall in Pullens Hope. All registered I&APs were invited to attend, the purpose of the

meeting was to discuss the impacts associated with the partial pillar extraction and the

proposed mitigation measures as outlined in this report. Refer to Annexure 2 for minutes of the

meeting.

4.3. Document Review

This report was made available to &APs for review and comment for an initial period of 30 days

(2 March – 1 April 2020), this was however suspended on 27 March 2020 due to the COVID-19

39

lockdown. These timeframes were resumed on 5 June 2020, and extended by an additional

21 days (ending 2 July 2020) as per the Directions issued by the Minister of Forestry, Fisheries

and the Environment4.

The report was made available online at www.cabangaenvironmental.co.za and at the

Pullens Hope Public Library. All registered I&APs were informed of the reports availability via e-

mail, fax and SMS. Further to this, electronic copies (Adobe PDF and CD) were made available

to I&APs upon request.

In addition, copies of the draft report were circulated to the following authorities for review

and comment:

• DMR;

• DHSWS;

• Mpumalanga Department of Economic Development, Environment and Tourism;

• Steve Tshwete Local Municipality;

• Nkangala District Municipality; and

• South African Heritage Resources Agency (SAHRA).

All comments and/or issues raised by I&APs to date have been included in the issues and

response table overleaf (Table 8).

4.4. Outstanding PPP

Notification of the record of decision (RoD) will be completed in terms of the NEMA EIA

Regulations as soon as a decision is received from the competent authority (the DMR). This will

include a note describing the outcome of the application and the appeal process that can

be followed.

4.5. Summary of Issues Raised by I&APs

Table 8 below summarises the issues and responses received from the various authorities,

organs of state and I&APs to date. Copies of all correspondence is included in the PPP report

attached as Annexure 2.

4 Directions regarding measures to address, prevent and combat the spread of COVID-19 relating to

permitting and licensing in terms of the National Environmental Management Act as issued by the Minister

of Forestry, Fisheries and the Environment on 5 June 2020 (Gazette No. 43412).

http://www.cabangaenvironmental.co.za/

40

Table 8: Issues and Response Table

AFFECTED PARTY DATE

RECEIVED

ISSUE RAISED INITIAL RESPONSE FINAL STATUS AND REFERENCE TO THE

EIA/EMP

Justice Ramagoma

Environmental Manager for

Hendrina Power Station, Eskom

18-02-2020

BID

Questionnaire

Completed the PPP Questionnaire and

registered as an I&AP. Requested that

farmers and residents in the area be

notified of the project.

Notices were placed in the Witbank

News, on site and at the local library.

In addition, BIDs were delivered to

immediately affected landowners /

users.

Section 4 summarises the PPP

undertaken for the Amendment

application.

Please refer to Annexure 2 for a copy of

the PPP report and I&AP register.

Mr.E.S.Nkosi

Chief Director

Office of the Regional Land

Claims Commissioner

20-02-2020

Letter

No claims were lodged before the 1998

re-lodgement period in terms of the

Restitution of Land Rights Act, Act No. 22

of 1994 however, a new claim was

lodged terms of the Restitution of Land

Rights Amendment Act, Act No. 15 of

2014. As per the ruling of the

Constitutional Court this claim will not be

processed until such time that the

Commission has finalised all claims

lodged on or before 31 December 1998;

or until Parliament passes a new law

providing for the re-opening of

lodgement of land claims.

Noted. No change.

A copy of the correspondence is

included in the PPP report, attached as

Annexure 2.

Jan Uys

Farm Boschmanskop

04-03-2020

Public

Meeting

Concern for the groundwater quality

and quantity. Will any privately owned

boreholes be impacted on?

Dewatering activities will result in a

maximum drawdown cone of between

1 and 4 m in the shallow, weathered

aquifer. No privately owned boreholes

fall within the drawdown zone of

influence.

Two potential sources of pollution were

identified on surface in the Groundwater

study, being the overburden and coal

stockpiles. Modelling indicates that a

pollution plume could develop during

the operational phase however, the

Section 6.2.4 summarises the possible

impacts on the groundwater resource.

Please refer to Annexure 3 for a copy of

the specialist groundwater report.

41

AFFECTED PARTY DATE

RECEIVED


EIA/EMP

pollution plume is expected to be

localised and no boreholes will be

impacted on. These stockpiles will be

removed on decommissioning and

closure.

Decant is expected after approximately

40 years post-operation. Although the

risk of acid formation is low, the decant

water quality is expected to contain high

total dissolved salts, with Sulphates being

the greatest contributor. Likely decant

points are the incline shaft, the ring dyke

structure west of the Boschmanskop

Dam as well as cracks or fractures

created by subsidence . Installation of

passive treatment systems will be

considered.

Requested a copy of the posters from

the Open Day.

Noted, copies of the posters from the

Open Day will be circulated along with

the minutes.

A copy of the meeting minutes and

posters were circulated to all registered

I&APs. Copies are included in the PPP

report, attached as Annexure 2.

What is the proposed end land-use

following closure, and is there a

possibility of renting or purchasing these

properties for agricultural use?

It is proposed to return the mine area to

that of grazing with some arable lands.

Was referred to Mr.R.Karstel of Tumelo to

discuss future surface rights.

Section 8 outlines the Closure,

Rehabilitation and Financial Provision.

Jan Venter

The Department of Agriculture,

Rural Development Land and

Environmental Affairs

(DARDLEA)

04-03-2020

Public

Meeting

When was the original soil study

undertaken, and what grid was this

completed on?

The original study was undertaken by

Digby Wells and Associates in 2006, on a

grid of 200m x 200m.

Section 5.3 summarises the baseline soils,

land use and land capability.

Requested copies of the shapefiles (soil

types, land use and capability).

The relevant shapefiles will be e-mailed. Shapefiles were submitted to DARDLEA

via e-mail on 09-03-2020.

42

AFFECTED PARTY DATE

RECEIVED


EIA/EMP

N.Sikhosana and P.Ndzulo

Onele Construction

04-03-2020

Public

Meeting

When did mining initially commence,

and when will the pillars be extracted?

Will all the pillars be extracted?

Construction of the operations

commenced in 2008 prior to

commencement of production in 2010.

Mining continued until 2014, at which

time the operation was put onto care

and maintenance. Mining recently

resumed in 2019. The proposed pillar

extraction will commence in 2022 once

the existing underground reserves are

depleted. Only partial pillar extraction

will be undertaken, this means that some

pillars will be left behind as support. Pillar

extraction will be in a checkerboard

layout.

Refer to Section 2.4 for the Project

Description, Plan 5 and Plan 6 indicate

the layout of the proposed pillar

extraction.

Are change houses provided on site? There are change houses and ablution

facilities on site. These will continue to be

utilised for the remainder of the life of

mine.

The existing infrastructure is indicated in

Plan 3.

Will there be a change in land use? Is

any additional surface infrastructure

proposed?

There will be no change in land use.

Existing surface infrastructure will

continue to be utilised for the remaining

life of mine, no additional infrastructure is

required for the change in mine plan.

Section 5.3 summarises the baseline soils,

land use and land capability.

Will any new jobs or contracts be

awarded as part of the project?

No new jobs are associated with the

proposed project changes however, the

pillar extraction will allow for the

continued employment of the current

workforce for an additional 1 year.

Currently 125 people are employed at

the mine.

Section 2.4.7 details the employment.

43

AFFECTED PARTY DATE

RECEIVED


EIA/EMP

Clearance Mbatha

Councillor (Ward 5)

04-03-2020

Public

Meeting

Is water quality monitored on site, and

does this include drinking water?

Yes, water monitoring is undertaken by

Aquatico Services. The monitoring

programme includes drinking water,

which is obtained from a borehole on

site.

The monitoring and reporting

requirements are outlined in Section 7.4.

What is the life of mine? The remaining LoM, including the

proposed pillar extraction, is four years.

Table 6 summarises the details of the

project, refer to Section 2.4 for the

detailed project description.

Requested a copy of the posters from

the Open Day and queried the possibility

of conducting a site visit.

Noted, copies of the posters from the

Open Day will be circulated along with

the minutes.

The possibility of a site visit meeting can

be discussed with the mine’s

representative.

A copy of the meeting minutes and

posters were circulated to all registered

I&APs. Copies are included in the PPP

report, attached as Annexure 2.

Lily Sekuba

Pullens Hope Forum

04-03-2020

Public

Meeting

What are the timeframes of the

extraction, and overall life of mine?

The proposed pillar extraction will extend

the life of mine by one (1) year. It is

expected that mining of the current

reserves will be complete by September

2022.




Z. Mahlangu

New Direction

04-03-2020

Public

Meeting

Will the mine supply Pullens Hope with

water?

The mine is not a water service provider,

and as such does not provide water to

the town or any other providers. The

water use license application is relevant

to the water uses at the mine.

No change.

What is the remaining life of mine? The remaining life of mine, including the

proposed pillar extraction, is four years.




44

AFFECTED PARTY DATE

RECEIVED


EIA/EMP

I&AP stated that they are often left in the

dark of the life of mine and employment

at the mines.

Noted. The purpose of the Open Day

meeting was to facilitate

communication between I&APs and the

mine.

The mine attends forums in both Pullens

Hope and Hendrina. Employment and

procurement opportunities will be

undertaken as per the approved S&LP.

A. Siyale

Resident of Pullens Hope

04-03-2020

Public

Meeting

Concerned about the future of Pullens

Hope, with Optimum on business rescue

and the proposed mothballing of power

plants in future. Will the proposed project

changes results in any new jobs?

The mine currently provides employment

for 125 people. The proposed project

changes to include pillar extraction, will

ensure continued employment of these

people for an additional 1 year. The

mine is involved with various forums in

the area, and is implementing the LED

projects as per the approved social and

labour plan

Phillip Hine and Nokukhanya

Khumalo

SAHRA

10-03-2020

Letter: Interim

comments

Please submit the original heritage

reports that were undertaken for the

original EIA. If there were no heritage

studies undertaken for the development,

then an assessment of the impacts to

heritage resources must be undertaken

as the proposed activity may cause

subsidence which is an indirect impact

to heritage resource.

As the proposed development area is

currently being mined, a letter of

recommendation for exemption may be

submitted if the specialist deems it

appropriate. The exemption letter should

include a map of the development,

photos and a track log.

A survey for heritage resources was

undertaken by Digby Wells and

Associates as part of the original EIA (

(Digby Wells and Associates, 2006).

Section 4.3, Page 70 of the approved

EIA/EMP states that no archaeological

artefacts or graves were identified in the

vicinity of the boxcut/infrastructure area.

It was noted however that a graveyard

containing approx. twenty (20) graves

was identified at the Spies family

farmstead, located west of the

Boschmanskop Dam. No underground

mining is proposed on the

aforementioned farm as this falls outside

the MRA. Subsidence from the proposed

mining and partial pillar extraction will

therefore not impact, directly or

indirectly, the aforementioned graves.

An Archaeological Impact Assessment

(AIA) has been completed for the

proposed project changes to include

partial pillar extraction. Refer to Section

5.9 for a summary of the findings, the full

report is attached as Annexure 7.

45

AFFECTED PARTY DATE

RECEIVED


EIA/EMP

Mines are only obligated to identify

heritage resources that their activities

may impact upon. As the identified

heritage resources are not located

within the MRA, or in proximity to where

the partial pillar extraction is proposed,

no further heritage assessments are

considered warranted at this stage.

Furthermore, the development area is of

very high palaeontological sensitivity as

per the SAHRIS Palaeo-Sensitivity map,

therefore a field based

palaeontological study must be done.

A desktop palaeontological study was

undertaken by a professional

Palaeontologist Invalid source

specified.. Based on the findings of the

assessment there is no need for a field-

based assessment at this stage.

Refer to Section 5.9 for a summary of the

specialist findings, the full report is

attached as Annexure 8. As per the

recommendations of the specialist a

chance find protocol has been included

in the Emergency Response Plan, refer to

Section 7.5.

SAHRA will only comment on the case

once the environmental and heritage

documents have been submitted.

Noted. The original EIA/EMP has been

uploaded to the South African Heritage

Information System (SAHRIS), along with

the desktop Palaeontological study.

The relevant documents have been

uploaded to SAHRIS. Final comments

have since been received from SAHRA.


Khumalo

SAHRA

02-04-2020

Letter: Interim

comments

The SAHRA Archaeology, Palaeontology

and Meteorites (APM) unit notes the

desktop PIA report along with the

recommendations provided therein.

Noted. Refer to Section 5.9 for a summary of the

specialist findings, the full report is

attached as Annexure 8. As per the

recommendations of the specialist a

chance find protocol has been included

in the Emergency Response Plan, refer to

Section 7.5.

It is also noted that a survey that assesses

heritage resources was undertaken in

2006, but the full document has not been

attached to the case on SAHRIS. Please

note that the SAHRA cannot make any

further comments on the case if the

A survey for heritage resources was

undertaken by Digby Wells and

Associates in 2006 as part of the original

EIA. The findings of the survey were

included in the 2006 EIA / EMP report

however, the original report cannot be

Section 5.9 summarises the findings of

the AIA. Plan 23 indicates the position of

the farmyard in relation to the

underground workings. Please refer to

Annexure 7 for a copy of the specialist

report.

46

AFFECTED PARTY DATE

RECEIVED


EIA/EMP

original heritage assessment document

is not submitted to the case. It should

also be noted that SAHRA only considers

recent heritage impact assessment's or

within the last 5 years. An addendum or

a letter of exemption must accompany

the 2006 report

The heritage impact assessment

document and a letter of exemption

must be submitted to the case on

SAHRIS before further comments can be

made.

located. As such, and in response to your

comments, Professor A.C.van

Vollenhoven of Archaetnos Culture and

Cultural Resources Consultants was

contracted to undertake a AIA with

regards to the Amendment application.

The findings of the AIA indicate that no

graves occur within the MRA, one farm

yard older than sixty years was identified.

It is noted that the cultural significance

of the farm yard is Low with a field rating

of Local Grade IIIC, in addition the farm

yard falls outside the area earmarked for

pillar extraction.

Mr.W.A.de Klerk

Farm Boschmanskop

13-05-2020

E-mail

Currently rents the surface of Portion 6,

10(RE) and 14(RE) from Tumelo. Asked

whether he would be offered first right of

refusal to purchase the properties on

closure, and requested contact details

for the correct contact person in this

regard.

Contact details for Mr.R.Karstel of

Tumelo were forwarded via e-mail.

No change.


Khumalo

SAHRA

19-05-2020

Letter: Final

comments

The SAHRA APM unit has no objections to

the proposed development.

The recommendations of the specialists

are supported and must be adhered to.

Additional further specific conditions are

provided for the development as

follows:

• The draft Amendment Report

must be revised to include the

results of the 2020 AIA;

Noted. Section 5.9 summarises the findings of

the AIA. Plan 23 indicates the position of

the farmyard in relation to the

underground workings. It is noted that

the farmyard will not be mined, and thus

no permit applications are necessary at

this stage.

47

AFFECTED PARTY DATE

RECEIVED


EIA/EMP

• If it is not possible to avoid the

identified historical structures,

and these resources are older

than 60 years but younger than

100, permits in terms of section

34(1) of the NHRA; and Chapter

II and III of the NHRA regulations

must be applied for from the

Mpumalanga Provincial

Heritage Authority (MPHRA).

If any evidence of archaeological sites

or remains (e.g. remnants of stone-made

structures, indigenous ceramics, bones,

stone artefacts, ostrich eggshell

fragments, charcoal and ash

concentrations), fossils or other

categories of heritage resources are

found during the proposed

development, SAHRA APM Unit

(Nokukhanya Khumalo/Phillip Hine 021

202 8654) must be alerted as per section

35(3) of the NHRA.

Non-compliance with section of the

NHRA is an offense in terms of section

51(1)e of the NHRA and item 5 of the

Schedule.

See section 51 of the NHRA for details on

Offences and Penalties.

Noted. A chance find protocol has been

included in the Emergency Response

Plan, refer to Section 7.5.

This has been updated to include the

contact details for SAHRA’s APM unit.

If unmarked human burials are

uncovered, the SAHRA Burial Grounds

and Graves Unit (Thingahangwi

Tshivhase/Mimi Seetelo 012 320 8490),




48

AFFECTED PARTY DATE

RECEIVED


EIA/EMP

must be alerted immediately as per

section 36(6) of the NHRA. Non-

compliance with section of the NHRA is

an offense in terms of section 51(1)e of

the NHRA and item 5 of the Schedule.

This has been updated to include the

contact details for SAHRA’s Burial

Grounds and Graves unit.

The following conditions apply with

regards to the appointment of

specialists:

• If heritage resources are

uncovered during the course of

the development, a

professional archaeologist or

palaeontologist, depending on

the nature of the finds, must be

contracted as soon as possible

to inspect the heritage

resource.

• If the newly discovered heritage

resources prove to be of

archaeological or

palaeontological significance,

a Phase 2 rescue operation may

be required subject to permits

issued by SAHRA.




The revised Amendment Report must be

submitted to SAHRA for record purposes.

Noted. A copy of the final Report, as submitted

to DMR, will be uploaded to SAHRIS for

record purposes.

The decision regarding the EA

Application must be communicated to

SAHRA and uploaded to the SAHRIS

Case application.

Noted. As per the requirements of NEMA and

the EIA Regulations, 2014 (as amended)

all registered I&APs will be notified of the

RoD (see Section 4.4).

49

5. ENVIRONMENTAL ATTRIBUTES

Just as a project is associated with certain impacts on the environment where it is undertaken,

the existing environment can also influence a development in terms of design, location,

technology and layout. It is therefore important to define the environmental baseline

conditions (status quo) of the project area.

The information presented in this section was extracted from the relevant specialist reports,

and the approved EMP (Digby Wells and Associates, 2006) completed for the operations and

is referenced where possible.

5.1. Climate and Meteorology

Tumelo Colliery is located in the Eastern Plateau Highveld climate zone of the Mpumalanga

Province. The region generally experiences a sub-tropical climate with warm, rainy summers

and cold winters. The mean annual precipitation (MAP) for the project area is +700mm and

annual evaporation is 1,552mm/a (A-Pan) (Letsolo Environmental and Water Services, 2020).

Average monthly temperatures range from 8.4 – 20.2 ⁰C, with the highest temperatures

observed over spring and summer (September – February). Minimum temperatures are

observed during winter (July). Relative humidity is lowest during the spring and summer months

(Rayten Environmental and Engineering Consultants, 2020).

The predominant wind directions at Tumelo Colliery, as observed from January 2016 to

December 2018, are from the east (~12% of the time), east-north-east (~11% of the time) and

north-west (~10.3% of the time). Wind speeds for the three-year period were generally

moderate to fast with calm conditions, defined as wind speeds less than 1 m/s, observed for

10.25% of the time (Rayten Environmental and Engineering Consultants, 2020).

The morning (AM) and evening (PM) period wind rose plots, for the period January 2016 to

December 2018, show diurnal variation in the wind field data. During the morning (AM) period,

high frequency winds are observed from the east, east-north-east and north-north-west; as

opposed to the evening (PM) period, where winds are predominantly observed from the north-

west, east and east-north-east. During summer, prevailing east-north-easterly and easterly

winds are observed. In autumn, stronger easterly winds occur. During winter, easterly winds

continue to be observed, with prevailing winds originating from the easterly, east-south-

easterly and north-westerly directions. In spring, strong winds are observed from the north-

westerly directions. Wind speeds were generally higher during the winter and spring seasons

(Rayten Environmental and Engineering Consultants, 2020).

50

Figure 10: Rainfall and Evaporation Data (Letsolo Environmental and Water Services, 2020)5

Figure 11: Temperature and Relative Humidity (Rayten Environmental and Engineering

Consultants, 2020)

5 The DWS rainfall station used is B1E003 and the SAWB rainfall station used is 0479369 (Hendrina). Data

dating back from May 1979 and ending on May 2019 was used.

0

20

40

60

80

100

120

140

160

180

200

JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC

Rainfall & Evaporation 1979 - 2018

Rainfall (mm) Evaporation (mm)

51

January 2016 – December 2018

2016

2017

2018

Figure 12: Period Wind Rose Plot, January 2016 to December 2019 (Rayten Environmental and

Engineering Consultants, 2020)

52

Morning (AM) (00:00 – 12:00)

Evening

(PM) (12:00 – 23:00)

Figure 13: Morning (AM) (00:00 - 12:00) and Evening (PM) (12:00 - 23:00) Period Wind Rose Plots

for January 2016 - December 2018 (Rayten Environmental and Engineering Consultants, 2020)

Summer

Autumn

Winter

Spring

Figure 14: Seasonal Variation of Winds for the Period January 2016 - December 2018 (Rayten

Environmental and Engineering Consultants, 2020)

53

5.2. Geology, Physiography and Topography

The topography in the MRA ranges from 1,605 metres above mean sea level (mamsl) on the

western border, to 1,650 mamsl on the south-eastern border (Shangoni Aquiscience, 2020).

Based on the surface contours in Plan 7 below, Tumelo is located on a slight North-South water

divide, and flow which will follow the contours perpendicularly from high to low, will be towards

the Boschmanskop Dam and the drainage lines located to the immediate west and east of

the MRA (Shangoni Aquiscience, 2020).

The surrounding landscape is associated with other surface water features such as wetlands

and pans (Scientific Aquatic Services, 2019). Several man-made features are also of

significance, the most obvious being the ash disposal dams associated with the Hendrina

Power Station, immediately west of the MRA.

The site is underlain by rocks of the Vryheid Formation, belonging to the Ecca Group of the

lower Karoo Supergroup. This comprises mainly of a sedimentary succession of sandstone,

siltstone, shale, mudstone, coal, diamictite and tillite (Shangoni Aquiscience, 2020).

The MRA is situated in the north eastern extremity of the Highveld Coal field separated by the

pre-Karoo Smithfield ridge from the Witbank Coal field to the north (Metallurgical Resources

Consulting, 2019). At places, sediments of the Vryheid Formation overlie the uneven Dwyka

floor, which is controlled by the topography of the pre-Karoo platform upon which the Karoo

sediments were deposited (Shangoni Aquiscience, 2020). The Vryheid Formation, which is

present throughout the Witbank area, attains some 140 m at the thickest point and contains

five major coal seams, named from bottom upwards, namely:

• No. 1, No. 2, No. 3, No. 4 and No. 5. Seam splitting occurs of three of the seams due to

breaks in the plant formation process.

o No. 2 Seam may be split into the No. 2 Lower Seam and the No. 2 Upper Seam,

o No. 4 Seam into the No. 4 Lower Seam, No. 4 Upper Seam and the No. 4A Seam.

o No. 5 Seam into the No. 5 Lower Seam and the No. 5 Seam.

o The thickest and most consistent coals are contained in the No. 2 and No. 4

Seam zones. The No. 1 Seam is restricted to the palaeo-valley. The No. 3 seam

is not laterally consistent. The No. 5 seam is only present in topographically high

areas; elsewhere it has been removed by erosion.

Of the seams mentioned above, the No. 4 Lower and No. 2 Lower seams have been identified

as being potentially economically viable (Metallurgical Resources Consulting, 2019). However,

currently only the No. 2 seam is targeted.

The No. 2 Seam ranges in thickness from 0.45m to 5.31m, developed mainly in the palaeo-

valley. A uniform seam, the No. 2 is either thin or absent over the adjacent palaeo-ridges

(Metallurgical Resources Consulting, 2019). As a result, the thickest development of coal is

found along the flanks of the poloidally, that trends approximately north–south across the

eastern side of the property. The thinnest coals are associated with the palaeo- ridge found

along the western side of the property (Digby Wells, 2006 cited by Shangoni Aquiscience,

2020). Abundant dolerite intrusions are present in the Ecca sediments. These intrusions resulted

in the displacement of the seams and the devolatilisation (“burning”) of extensive areas of

coal (Metallurgical Resources Consulting, 2019).

54

Plan 7: Regional Topography and Drainage (Shangoni Aquiscience, 2020)

55

5.3. Soils, Land Use and Land Capability

The MRA falls within the Bb4 land type. Bb4 land type comprises of plinthic soils (with subsurface

accumulation of iron and manganese oxides due to fluctuating water table) with low to

intermediate base status. It is expected that the dominant soils will be of the Avalon and Ruston

forms.

A baseline assessment was completed for the MRA in 2006 (Digby Wells and Associates, 2006)

prior to commencement of the construction phase. The soils were augered on a 200m x 200m

grid, to a depth of 1.2m or shallower if a limiting layer was encountered. A total of 88 holes

were augered and positioned using a handheld GPS (Digby Wells and Associates, 2006).

Four soil forms were identified and mapped within the MRA namely Hutton, Clovelly, Avalon

and Longlands (Plan 9). Avalon soil forms were dominant, making up 84% of the soils in the

study area (Digby Wells and Associates, 2006). The soils are described below:

Table 9: Description of Soils (Digby Wells and Associates, 2006)

SOIL FORM DESCRIPTION AGRICULTURAL POTENTIAL

PROPERTIES IRRIGATION DRYLAND

Hutton

(Hu)

Reddish brown sandy

loam with gradually

increasing clay to red

sandy clay loam with

fairly frequent iron

nodules to 850mm.

Very

permeable,

deep soil with

no restricting

layers <850mm

Moderately

High

High (arable)

Clovelly

(Cv)

A brown sandy loam

overlies a yellowish

brown sandy clay loam.

Excellent

dryland

cropping soils.

Moderately

High

High (arable)

Avalon

(Av)

Dark brown sandy loam

overlies yellows brown

sandy clay loam

becoming mottled

reddish orange at about

600mm and very

frequent iron nodules at

800mm.

Under moist

climatic

conditions has

good potential,

however can

be fairly wet.

Moderately

High

Fairly Good

(arable)

Longlands

(Lo)

Dark greyish brown

sandy loam overlies

brown sandy loam

leached layer overlying

mottled reddish/orange

layer with high clay at

650mm.

Seasonally wet

soils.

Low Low

(wetland/grazing)

56

The majority of the pre-mining land capability was regarded as arable land (66%), with

remaining area identified as grazing land (34%), refer to Plan 10. The pre-mining land capability

to a large degree reflected the pre-mining land use, being grazing and maize cultivation

(Digby Wells and Associates, 2006).

The land use immediately surrounding Tumelo Colliery consists predominantly of grassland and

cultivated land to the east, west and south. Surface activities associated with the mining

operations are concentrated towards the north-west and north of the MRA (Rayten

Environmental and Engineering Consultants, 2020).

Hendrina Power Station is located approximately 3km north-west of Tumelo Colliery. Pullens

Hope is the nearest urban residential area to Tumelo Colliery and is located approximately

5km north-west of the MRA. The area surrounding Tumelo Colliery is classified as rural in nature,

with few informal residential areas located near the site (Rayten Environmental and

Engineering Consultants, 2020).

Plan 8: Surrounding Land Use (Rayten Environmental and Engineering Consultants, 2020)

57

Plan 9: Soil Types (as per the approved EMP)

58

Plan 10: Pre-Mining Land Capability (as per the approved EMP)

59

5.4. Hydrology (Surface water)

The MRA falls within quaternary catchment B12B in the Olifants Water Management Area 2

(WMA 2). Several river systems drain the catchment area, the most prominent being the Klein-

Olifants River, Woes-Alleenspruit and Rietkuilspruit. In the immediate vicinity of the study area,

two smaller drainage systems, East Woes-Alleenspruit and an unnamed tributary, are located

to the immediate east and west of the mine (Shangoni Aquiscience, 2020). Refer to Plan 11.

The East Woes-Alleenspruit River flows in an easterly direction and discharges into the

Boschmaskop Dam which is located north-west of the mine infrastructure area (Letsolo

Environmental and Water Services, 2020). This dam was constructed to divert clean water from

a neighbouring opencast operation. Another dam, situated on a neighbouring mine’s

property, is in the valley of the western river and forms the boundary on that side of the MRA.

Along the south eastern boundary there is a steep drop into a basin containing a pan with an

endorheic drainage system (Shangoni Aquiscience, 2020).

Plan 11: MRA in relation to the B12B Quaternary Catchment (Shangoni Aquiscience, 2020)

Site specific catchments were delineated to provide site specific storm water management

measures for the project, these were delineated based on hydrological characteristics and

flood calculation methods (Letsolo Environmental and Water Services, 2020). Table 10 below

summarises the peak flow and flood volumes for these catchment areas, (as depicted in Plan

12 and Plan 13).

60

Table 10: Summary flood (peak flows and flood volume) calculations (Letsolo Environmental

and Water Services, 2020)

Description 1:50 Volume 1:100 Volume

Clean Catchment 1 1,047 1,288

Clean Catchment 2 172 212

Overburden Stockpile 31 38

Ancillary Area 176 217

Decline Shaft 93 115

Plant and ROM 108 133

1,714 2,110

Plan 12: Clean water catchments (Letsolo Environmental and Water Services, 2020)

61

Plan 13: Dirty water catchments (Letsolo Environmental and Water Services, 2020)

Three surface water points were sampled for water quality analyses during the 2019

Hydrocensus. Two samples were taken from the Boschmanskop Dam, one north (SW02) and

the other south (SW03) of the dam wall. One sample was taken from a dam (SW01) located

approximately 4 km to the north-east of Tumelo Colliery (refer to Plan 14). The following can be

concluded based on the monitoring data presented in Table 11 (Shangoni Aquiscience, 2020):

• SW01 recorded a slightly alkaline pH of 9.14 while SW02 and SW03 recorded circum-

neutral pH levels of 7.95 and 8.07, respectively.

• Electrical Conductivity (EC) and TDS levels are relatively raised for the surface water

localities and based on the Stiff diagrams in Annexure 3, the chemistry is dominated by

the calcium (Ca) cation and the Sulphate (SO4)anion.

• SO4 in SW01 exceed SANS 241: 2015 drinking water quality standards with a

concentration of 555 mg/l.

• Trace metals recorded in parts per billion (ppb) or undetected concentrations while

Fluoride (F) levels recorded in undetected to medium levels. A relatively raised F

concentration of 1.11 mg/l was recorded for SW03.

• The water can be classified as hard to very hard (hard refers to high mineral content).

• The water profiles are typical of clean water that has mixed with mineralised water rich

in SO4, which is a typical profile of mine affected water.

62

Table 11: Water quality of surface water surveyed on 23 October 2019 (Shangoni Aquiscience,

2020)

LOCALITY / GUIDELINE UNIT SANS 241:2015 SW01 SW02 SW03

PARAMETER

pH - ≥ 5 and ≤ 9.7 9.14 7.95 8.07

EC mS/m ≤ 170 123 81.7 123

TDS mg/l ≤ 1200 838 530 762

Calcium (Ca) mg/l - 75.4 45.6 75.0

Magnesium (Mg) mg/l - 82.6 39.1 78.4

Sodium (Na) mg/l ≤ 200 54.7 56.5 57.7

Potassium (K) mg/l - 13.1 14.9 12.5

Alkalinity mg/l - 54.6 78.8 110

Chloride (Cl) mg/l ≤ 300 24.5 46.1 45.6

Sulphate (SO4) mg/l ≤ 500 555 280 426

Nitrate as N (NO3-N) mg/l ≤ 11 <0.35 <0.35 <0.35

Ammonium as N (NH4-N) mg/l ≤ 1.5 <0.45 <0.45 <0.45

Phosphate as P (PO4) mg/l - <0.03 <0.03 <0.03

Fluoride (F) mg/l ≤ 1.5 <0.09 0.47 1.11

Aluminium (Al) mg/l ≤ 0.30 <0.01 <0.01 <0.01

Iron (Fe) mg/l ≤ 2 0.01 <0.01 0.01

Manganese (Mn) mg/l ≤ 0.4 <0.01 0.02 <0.01

Chromium (Cr) mg/l ≤ 0.05 <0.01 <0.01 <0.01

Copper (Cu) mg/l ≤ 2.0 <0.01 <0.01 <0.01

Nickel (Ni) mg/l ≤ 0.07 <0.01 <0.01 <0.01

Zinc (Zn) mg/l ≤ 5.0 <0.01 <0.01 <0.01

Total Hardness mg CaCO3/l - 528 275 510

Floodline modelling was undertaken as part of the surface water impact assessment

(attached as Annexure 4), where it was determined that the existing mine infrastructure falls

outside of the 1:100-year floodline.

The infrastructure area in relation to the delineated floodline is shown in Plan 15 overleaf.

63

Plan 14: Surface water monitoring points surveyed on 23 October 2019

Plan 15: Mine Infrastructure in relation to the 1:100 year floodline (Letsolo Environmental and

Water Services, 2020)

64

5.5. Geohydrology (Groundwater)

A geohydrological assessment was completed by Shangoni Aquiscience (2020), the full report

is attached as Annexure 3 .

According to the 1:25,000 hydrogeological map (DHSWS Hydrogeological map series 2426

Johannesburg) the study area is predominantly located in a d2 aquifer class region. The

groundwater yield potential is classed as low, on the basis that most of the boreholes on record

in vicinity of the study area produce between 0.1 and 0.5 l/s (Shangoni Aquiscience, 2020).

Three aquifers were identified in the study area, and include:

1. Perched aquifer, mostly associated within wetlands;

2. Weathered aquifer; and

3. Fractured aquifer.

Mining of the coal seams has also resulted in the creation of an artificial aquifer system in the

underground workings (Shangoni Aquiscience, 2020).

Groundwater flow directions largely correlate with surface flow, and tends to follow relatively

similar gradients and flow patterns compared to surface topography. Groundwater flow is

largely towards the major drainage systems and the Boschmanskop Dam. Groundwater leaves

the aquifer as discharge contributing to flow within the bases of these systems (groundwater

contribution baseflow) (Shangoni Aquiscience, 2020).

Ferricrete underlies the study area at certain places and acts as a confining aquiclude or

aquitard that separates the weathered aquifer from the fractured aquifer resulting in

piezometric heads to form, some of which may be artesian. A dolerite sill ranging in thickness

from 5 to 13 m underlies the study area. The sill is generally confined to specific horizons and

will also act as a largely impermeable barrier for groundwater movement (Shangoni

Aquiscience, 2020).

A good correlation of 0.99 was achieved between static hydraulic heads and surface

elevation. Groundwater elevations therefore mimic surface topography. Nineteen (19)

boreholes and three (3) dams were surveyed during the field hydrocensus. The results of the

hydrocensus show that the measured depth to groundwater level ranges between 2.70 and

45.53 metres below surface (mbs). Hydraulic head elevations range between 1,540 and 1,634

mamsl. Of the boreholes recorded, the majority are used for farming purposes i.e. livestock

watering (Shangoni Aquiscience, 2020).

During the 2019 hydrocensus, samples were taken from nine groundwater points. The following

can be concluded based on the monitoring data presented in Table 12 (Shangoni

Aquiscience, 2020):

• A circum-neutral pH to slightly alkaline levels and non-saline groundwater were

measured.

• EC and TDS are in the low ranges and mineralisation of major cations and anions are

also low, although Ca is relatively raised in H-BH7 to H-BH10 and Na in HB-H01, H-BH02

H-BH03, HBH05 and HBH06. These slightly raised levels are geology related and/or

difference in borehole depths and remain well within domestic guidelines.

• Nutrients, including nitrate (NO3), ammonium (NH4) and phosphate (PO4) are low to

undetected and well within relevant use guidelines.

65

• A relatively raised iron (Fe) concentration of 0.53 mg/l was recorded for HBH01 but is

well within health-based domestic guidelines. It is not uncommon for Fe to be slightly

raised in groundwater due to reducing or low oxygen levels. All other trace metals

recorded in low to undetected levels.

A water monitoring programme, consisting of surface and groundwater quality, is currently

implemented at Tumelo Colliery. Monthly surface and quarterly groundwater monitoring are

conducted by Aquatico Scientific (Pty) Ltd. Groundwater monitoring data for June 2019 was

reviewed and is displayed in Table 13. Based on the data, the following can be concluded

(Shangoni Aquiscience, 2020):

• The pH levels are circum-neutral but substantial salinity (TDS & EC) variances exist. TDS

range between 150 and 639 mg/l and EC between 19 and 84 mS/m. The greatest

salinity was recorded for TC01, a monitoring borehole located downstream from the

PCD (referenced as BMKSW06 in the Aquatico monitoring reports), while a relatively

similar salinity concentration was recorded for DS3.

• Based on the Stiff diagrams and the Expanded Durov diagram in Annexure 3, both TC01

and DS3 are typical of affected groundwater displaying Ca-SO4 and Ca (Na)-SO4

water types, respectively.

• Nitrate (NO3) is raised in borehole BMKGW03 (deep borehole adjacent to pan) with a

concentration of 9.33 mg N/l.

• DS04 recorded relatively high Sodium (Na) concentrations. The profile is typical of

groundwater that has been in contact with a source rich in Na or old stagnant NaCl

dominated water that resides in Na rich host rock/material.

• All other groundwater profiles are typical of fresh, recently recharged water that has

undergone Mg or Na ion exchange.

66

Table 12: Water quality of hydrocensus boreholes surveyed on 23 October 2019 (Shangoni Aquiscience, 2020)

LOCALITY / GUIDELINE UNIT SANS 241:2015 HBH01 HBH02 HBH03 HBH05 HBH06 HBH07 HBH08 HBH09 HBH10

PARAMETER

pH - ≥ 5 and ≤ 9.7 7.04 7.29 7.60 7.78 8.86 7.51 7.74 8.00 7.76

EC mS/m ≤ 170 23.0 24.4 28.2 28.1 28.6 27.0 33.7 32.2 39.8

TDS mg/l ≤ 1200 117 130 139 143 153 140 169 178 198

Calcium (Ca) mg/l - 6.41 7.86 15.7 11.8 3.84 20.7 20.9 30.2 33.6

Magnesium (Mg) mg/l - 2.77 3.64 6.07 6.44 3.41 6.47 13.6 11.9 15.1

Sodium (Na) mg/l ≤ 200 33.7 35.9 28.6 32.5 48.3 19.7 22.7 21.1 20.2

Potassium (K) mg/l - 2.38 4.53 4.51 4.64 3.26 6.23 4.13 4.11 5.23

Alkalinity mg/l - 94.2 112 129 127 72.6 119 152 141 179

Chloride (Cl) mg/l ≤ 300 7.53 6.36 4.10 4.70 39.3 6.67 7.61 11.0 8.89

Sulphate (SO4) mg/l ≤ 500 0.55 2.56 1.97 6.16 8.59 8.81 6.27 12.8 7.43

Nitrate as N (NO3-N) mg/l ≤ 11 1.37 0.41 <0.35 <0.35 0.38 <0.35 0.43 0.51 <0.35

Ammonium as N (NH4-N) mg/l ≤ 1.5 <0.45 <0.45 <0.45 <0.45 <0.45 <0.45 <0.45 <0.45 <0.45

Phosphate as P (PO4) mg/l - 0.04 0.03 0.07 <0.03 <0.03 0.03 <0.03 <0.03 <0.03

Fluoride (F) mg/l ≤ 1.5 0.43 0.17 <0.09 0.12 0.56 0.26 0.36 0.11 0.25

Aluminium (Al) mg/l ≤ 0.30 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Iron (Fe) mg/l ≤ 2 0.53 <0.01 <0.01 <0.01 0.05 0.02 0.19 0.02 <0.01

Manganese (Mn) mg/l ≤ 0.4 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.02 <0.01 <0.01

Chromium (Cr) mg/l ≤ 0.05 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Copper (Cu) mg/l ≤ 2.0 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Nickel (Ni) mg/l ≤ 0.07 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Zinc (Zn) mg/l ≤ 5.0 0.03 0.24 <0.01 <0.01 <0.01 0.03 0.05 <0.01 <0.01

Total Hardness mg CaCO3/l - 27.4 34.6 64.2 56.0 23.6 78.3 108 124 146

67

Plan 16: Hydrocensus boreholes as surveyed on 23 October 2019

68

Table 13: Water quality of groundwater monitoring boreholes (June 2019)

LOCALITY / GUIDELINE UNIT SANS 241:2015 BKMGW3 BMKGW04 DS1 DS3 DS4 DS5 DS6 TC01

PARAMETER

pH - ≥ 5 and ≤ 9.7 7.34 8.35 8.33 7.78 8.09 8.45 8.5 8.27

EC mS/m ≤ 170 19 20.6 40.2 70.6 36.6 51.2 35 84.4

TDS mg/l ≤ 1200 150 191 294 507 277 371 248 639

Calcium (Ca) mg/l - 6.96 16.9 22.8 35.1 11.1 38.7 31.7 105

Magnesium (Mg) mg/l - 6.02 7.84 14.1 45.9 10.7 20.4 15.2 50.6

Sodium (Na) mg/l ≤ 200 8.88 13.6 52.2 59.9 46.2 47.2 26.2 28.9

Potassium (K) mg/l - 4.14 7.3 5.47 6.82 4.71 5.43 5.88 7.05

Alkalinity mg/l - 20.6 111 208 59.4 70.2 161 148 113

Chloride (Cl) mg/l ≤ 300 7.28 3.41 12.6 17.6 41.5 28.2 21.6 17.8

Sulphate (SO4) mg/l ≤ 500 5.94 3.46 28.7 294 45 97.5 23.5 346

Nitrate as N (NO3-N) mg/l ≤ 11 9.33 0.21 0.097 0.21 4.87 0.407 0.325 0.248

Ammonium as N (NH4-N) mg/l ≤ 1.5 0.76 0.20 <0.03 0.04 0.031 0.031 0.028 0.028

Phosphate as P (PO4) mg/l - 0.11 <0.003 <0.003 <0.003 <0.003 <0.003 0.006 <0.003

Fluoride (F) mg/l ≤ 1.5 0.13 0.53 0.27 0.13 0.60 0.33 0.48 0.56

Aluminium (Al) mg/l ≤ 0.30 0.022 <0.001 <0.001 <0.001 0.015 <0.001 <0.001 <0.001

Iron (Fe) mg/l ≤ 2 0.054 <0.002 <0.002 <0.002 <0.002 <0.002 <0.002 <0.002

Manganese (Mn) mg/l ≤ 0.4 0.02 0.116 0.006 0.015 <0.001 <0.001 <0.001 <0.001

Total Hardness mg CaCO3/l - 42 74 115 277 72 180 142 472

69

Plan 17: Groundwater monitoring boreholes

70

5.6. Terrestrial Ecology

The MRA is located within the Eastern Highveld Grassland national vegetation (Mucina and

Rutherford, 2006) of the Mesic Highveld Grassland Bioregion. The Eastern Highveld Grassland is

listed as Vulnerable on the National list of threatened ecosystems for South Africa and is

characterised by slightly to moderately undulating plains consisting of low hills and pan

depressions with scattered rocky outcrops (SANBI & DEAT, 2009).

Plan 18: Vegetation Type

According to the Mpumalanga Biodiversity Sector Plan (MBSP) the MRA consists largely of

heavily or moderately modified areas due to cultivation, and the existing mining operations.

As depicted in Plan 19 below, a portion of the MRA has been declared Critical Biodiversity

Area (CBA 2 Optimal) (terrestrial).

There are no formally protected areas in the immediate vicinity of Tumelo Colliery. The closest

protected area is the Heyns Private Nature Reserve, located approximately 23km north-west

of the operations.

According to the Mining and Biodiversity Guidelines Database the western portion of the MRA

is considered of Highest and Moderate Biodiversity Importance, while the majority of the MRA

is currently not ranked (Scientific Aquatic Services, 2019). Correlation is evident between the

highest biodiversity importance area and those demarcated as CBAs. No underground mining

or surface infrastructure activities are proposed in this area (refer to Plan 19 and Plan 20).

71

Plan 19: Terrestrial Critical Biodiversity Areas

Plan 20: National Mining and Biodiversity Guidelines

72

According to the approved EMP report (Digby Wells and Associates, 2006) the natural

vegetation in the MRA had largely been altered due to cultivation activities prior to the

commencement of the mining operations. Vegetation in the old cultivated lands consisted

mainly of weeds and annual forb species, dominated by Hpyarrhenia hirta, Hyparrhenia

tamba and Cynodon dactylon. Species such as Eragrostis gummiflua, Eragrostis cuvula and

Eragrostis plana were also prominent. The destruction of the natural vegetation and habitat

within the cultivated lands had in turn led to a decrease in available habitat for fauna. Only a

few mammals, birds, insects and butterflies were recorded during previous surveys. Please refer

to the original EMP for a detailed list of species identified during previous surveys (Digby Wells

and Associates, 2006).

Although no Species of Conservation Concern (SCC) were specifically identified during the

fauna and floral surveys completed by Digby Wells and Associates or on subsequent site visits;

the observation of an individual of Eulophia ovalis var. ovalis and Eucomis sp. indicates that

other unique floral species, including potential SCC, may be present within the overall MRA.

The depression wetland located to the east of the MRA may also provide suitable habitat for

protected fauna species such as the Pyxicephalus adspersus (Giant Bullfrog) (Scientific

Aquatic Services, 2019).

As there will be no change to the infrastructure area, and the proposed pillar extraction will be

limited to areas under cultivation no additional specialist studies were deemed necessary at

this time.

5.7. Freshwater Ecology

A freshwater resource assessment for the project was undertaken by Scientific Aquatic

Services, 2019 (Annexure 5). The freshwater resource assessment used a 500m “zone of

investigation” around the MRA to assess possible sensitivities of the receiving environment, the

results of which are briefly discussed below.

The MRA is located within a sub-WMA currently not considered important in terms of fish or

freshwater resource conservation.

Wetlands are defined in the NWA (Act 36 of 1998) as “land which is transitional between

terrestrial and aquatic systems where the water table is usually at or near the surface, or the

land is periodically covered with shallow water, and which land in normal circumstances

supports or would support vegetation typically adapted to life in saturated soil”.

“Watercourse” is defined in the Act as any river or spring, any natural channel in which water

flows regularly or intermittently, a wetland, lake or dam into which or from which water flows

and any other collection of water declared by the Minister to be a watercourse.

The National Freshwater Ecosystems Priority Areas (NFEPA) Project was a collaboration

between the Council for Scientific and Industrial Research (CSIR), South African National

Biodiversity (SANBI), the Water Research Commission (WRC), DHSWS and Department of

Environmental Affairs (DEA) and many other role-players and attempted to map the

freshwater ecosystem priority areas, including rivers and wetlands, throughout South Africa.

According to the NFEPA database, there are three natural unchanneled valley bottom

wetlands; one artificial unchanneled valley bottom wetland; one natural depression wetland;

and one artificial channelled valley bottom wetland situated within the MRA. The

73

aforementioned wetlands are classified as moderately modified (Class C) or heavily to

critically modified (Class Z1 – Z3) according to the NFEPA Database. None of the wetlands

associated with the MRA are classified as FEPA Wetlands. The field assessment however verified

that two of the ‘natural’ valley bottom wetlands indicated by NFEPA are areas of disturbance,

whilst one is a hillslope seep area associated with the valley bottom wetland identified on the

western boundary of the MRA (Scientific Aquatic Services, 2019).

Two wetland systems were groundtruthed and delineated within the MRA specifically, a

channelled valley bottom (CVB) wetland partially within and adjacent to the western

boundary of the MRA, and a depression wetland in the south-eastern corner of the MRA (Plan

21). The CVB wetland is deemed ‘largely modified’ whilst the depression wetland is considered

‘largely natural’, Table 14 below summarises the results of the field assessment (Scientific

Aquatic Services, 2019). Please refer to Annexure 5 for the detailed investigation.

Table 14: Summary of results of the field assessment

WETLAND PES6 ECOSERVICES EIS7 REC / RMO / BAS8

Channelled valley

bottom

D Intermediate Moderate D / C / C

Depression B Moderately low Moderate B / B / B

Plan 21: Wetland Delineation (Scientific Aquatic Services, 2019)

6 PES = Present Ecological Status 7 EIS = Environmental Importance and Sensitivity 8 REC = Recommended Ecological Category / RMO = Resource Management Objective / Best

Attainable State

74

The northern area of the existing mine infrastructure, specifically the overburden stockpile, coal

stockpile area, PCD and crusher and screening plant, encroaches marginally on the 100m

regulated zone in terms of GN704 as it relates to the NWA (Scientific Aquatic Services, 2019).

5.8. Air Quality and Noise

The MRA falls within the Highveld Air Quality Priority Area (HPA). Existing key sources of air

pollutants surrounding Tumelo Colliery include (Rayten Environmental and Engineering

Consultants, 2020):

• Neighbouring mining activities (north and north-west of the MRA);

• Vehicle dust entrainment on unpaved roads (surrounding areas);

• Commercial agricultural activities (surrounding areas); and

• Industrial activity, including the Hendrina and Komati coal fired power stations, and

associated activities (ash dams).

Air quality monitoring data was obtained from the South African Air Quality Information System

(SAAQIS) to determine background concentrations for PM10 and PM2.5 in the area. The closest

air quality monitoring station is located at the Kwazamokuhle High School in Hendrina (~14km

south-east of the MRA). Data for PM10 and PM2.5 concentrations was available for the period

01 February 2018 to 17 October 2019, based on this data the daily average PM10

concentrations ranged 1-111 μg/m3 and PM2.5 concentrations ranged 0-47 μg/m3. Several

exceedances (>4) of the South African National Standards for PM10 and PM2.5 daily

concentrations were recorded; which suggests that background ambient particulate matter

concentrations are relatively high in the area. This is however expected due to the existing

emission sources in the area, such as the Hendrina Power Station, coal mining activities, vehicle

dust entrainment on unpaved roads and commercial agricultural activities (Rayten

Environmental and Engineering Consultants, 2020).

Dust fallout monitoring is currently undertaken by Tumelo at four sites located within the MRA,

refer to Plan 22 overleaf. Based on available monitoring data (January 2018 to September

2019) dust fallout ranged between 52.60 – 1,751.00 mg/m2/day (Figure 15) compared to the

National Dust Control Regulations, 2013 (as amended) for non-residential sites of 1,200

mg/m2/day (Rayten Environmental and Engineering Consultants, 2020).

A total of two exceedances of the dust fallout limits are permissible in a year (not two

sequential months). In August 2018, the dust-fall rates at sites BMK 1 and BMK 2 exceeded the

non-residential limit of 1200 mg/m2/day, thus a total of two exceedances were recorded in

2018 but these occurred at two different dust bucket sites. For the period January – September

2019, there was one exceedance at site BMK 2 in August 2019 and two exceedances at site

BMK 4 which occurred over two sequential months (July – August 2019). Therefore, the dust-fall

rates at Tumelo Colliery are in non-compliance with the National Dust Control Regulations for

the period January 2019 – September 2019, specifically at site BMK 4 which is located south-

east of the boxcut (Rayten Environmental and Engineering Consultants, 2020). It is noted that

this dust bucket is adjacent to a farm road and agricultural field and thus dust fallout results

may also be influenced by agricultural activities in the area.

75

Plan 22: Dust Monitoring Points

Figure 15: Dust Fallout Results (January 2018 – September 2019) (Rayten Environmental and

Engineering Consultants, 2020)9

9 Site BMK1 was moved to a new location in July 2019. The co-ordinates for the previous location are 26o

04’ 41.2’’ S; 29 o 36’ 45.8’’ E. The dust fallout results at BMK1 for January 2018 to June 2018 are for the

previous location.

76

According to Digby Wells and Associates (2006) baseline ambient noise levels were well the

below the day and night time Rating Levels for Rural Districts, as stipulated by the South African

Bureau of Standards (SANS 10103). The main source of noise emanating from Tumelo Colliery

is associated with the existing crusher and screener; the proposed change in mine plan to

include partial pillar extraction is not expected to result in an increase in the ambient noise

levels.

Noise levels on site are currently managed in terms of the Occupational Health and Safety

Act. Considering the distance between Tumelo Colliery and surrounding land owners and

occupants, regular ambient noise monitoring is not considered necessary at this stage, though

the mine must maintain a complaints register and investigate any noise-related complaints.

5.9. Sites of Archaeological and Cultural Significance

According to the approved EMP (Digby Wells and Associates, 2006) a site survey was

undertaken on 29 October 2002. The survey indicated that no archaeological artefacts or

cultural sites were identified in the vicinity of the boxcut decline or infrastructure area. Two sets

of graves (twenty graves in total) were however identified at a neighbouring property, the

Spies family farmstead, located west of the Boschmanskop Dam (Digby Wells and Associates,

2006).

Following comments received from the SAHRA during the review period an AIA was

undertaken in April 2020 for the proposed project changes to include partial pillar extraction

(Annexure 7). The AIA identified one cultural heritage site, an old farmyard, within the MRA.

The farm yard is approximately 404m x 346m in size and contains several structures associated

with farming including two farmhouses. The one farmhouse is modern in design 31m x 40m,

and the other older house is 32m x 11m in size. The core of the older farmhouse could be older

than 60 years however modern alterations have been done. The cultural significance of the

site is Low and has a field rating of Local Grade IIIC (Archaetnos Culture and Cultural Resources

Consultants , 2020). Plan 23 depicts the position of the farmyard in relation to the underground

workings.

No graves were identified within the MRA.

The South African Heritage Resources Information System (SAHRIS) palaeo-sensitivity Map

(https://sahris.sahra.org.za/map/palaeo) identified areas of Insignificant and Very High

sensitivity within the MRA. As such, a desktop palaeontological impact assessment (PIA) was

completed as part of the feasibility assessment for the mining of the No. 4 seam and No. 2

seam partial pillar extraction (Annexure 7).

The findings of the PIA concluded that there is a small chance that fossil plants may be found

in the shales and mudstone associated with the coal seams. Their occurrence in the Vryheid

Formation (Ecca Group) is however sporadic and unpredictable. Fossil vertebrates are unlikely

to occur (Bamford, 2019).

https://sahris.sahra.org.za/map/palaeo

77

Plan 23: Cultural Heritage Sites

5.10. Socio-Cultural Environment

Steve Tshwete Local Municipality (STLM) is located in the Nkangala District Municipality of the

Mpumalanga Province. The municipal area covers approximately 3,993 km2 and includes the

towns of Middelburg, Mhluzi, Hendrina, Kwazamokuhle, Rietkuil, Pullens Hope, Komati,

Presidentsrus, Naledi, Lesedi, Kranspoort, Blinkpan, Koornfontein, Kwamakalane, and

Doornkop (https://www.stevetshwetelm.gov.za/index.html).

Manufacturing, mining, finance, energy generation and agriculture are the main drivers of the

economy in the STLM. These industries generate mass employment in the rural areas,

specifically within the mining and manufacturing industries (i.e. steel and metal) (Steve

Tshwete Local Municipality, 2019/2020).

The Community Survey 2016 from Statistics South Africa indicated that the population for STLM

was 278,750. Of which 52,41% were male and 47,59% were female; this gender distribution

may be attributed to the prevalent economic activities in the area, being mining,

manufacturing and agriculture (MTS Holdings (Pty) Ltd, 2019).

There are approximately 64 971 households in the STLM, with an average household size of 3,3

persons per household. 29,4% of households are headed by females

(http://www.statssa.gov.za/?page_id=993&id=steve-tshwete-municipality). Of the households

59.7% have access to piped water in their dwelling, and a further 21.01% have access to piped

water in their yard. Basic services infrastructure appears to be somewhat formalised with

https://www.stevetshwetelm.gov.za/index.html

http://www.statssa.gov.za/?page_id=993&id=steve-tshwete-municipality

78

almost 82% of households within the STLM having access to flushable toilets, either connected

to a public sewage or septic tank (MTS Holdings (Pty) Ltd, 2019).

On average, less than 30% of the population in the Mpumalanga have completed primary

education and a mere 5,61% are cited to have higher qualifications (post-Grade 12) in the

whole province. Overall statistics at a district and local level reflect poor educational profiles

indicating similar trends as the Province. However, a significant percentage of the population

in Pullens Hope and Hendrina have completed some secondary education as well as attained

Grade 12 qualifications. The employment profile of the population in Pullens Hope and

Hendrina complements the education profile with employment levels of 44,76% and 36,98%,

respectively (MTS Holdings (Pty) Ltd, 2019).

5.11. Environmental Sensitivity Map

Plan 24 below summarises the environmental sensitive areas in relation to the underground

mine workings, proposed pillar extraction and surface infrastructure area.

Plan 24: Overall Environmental Sensitivity Map

79

6. IMPACT ASSESSMENT

The purpose of the impact assessment is to determine the Significance of potential impacts

associated with the proposed project changes, so that those activities that are expected to

result in high impacts can be altered, or management measures imposed to lessen the impact

significance.

6.1. Impact Assessment Methodology

Impact Significance is calculated by the following formula:

Impact Significance = Consequence x Likelihood

Likelihood refers to the probability that an impact will occur at some time during the project.

The Matrix which is proposed to determine Likelihood is as follows:

Table 15: Matrix used to determine likelihood

Lik

elih

oo

d

Unlikely: Impact Could occur in extreme events. Less than 15% chance of the impact ever

occurring.

1

Possible: possibility of impact occurring is very low. 16% - 30% chance of the impact

occurring.

2

Probable There is a distinct possibility of the impact occurring. 31% to 60% chance. 3

Highly Probable: The impact is expected to occur. Between 61% and 85 % chance. 4

Definite: There are sound scientific reasons to expect that the impact will occur 5

Consequence is calculated by considering the duration, spatial scale and intensity of an

impact.

Duration relates to the time-frame that an aspect will be impacted upon. For example, any

impact to a heritage resource is considered permanent, while the impact of increased traffic

related to a construction activity will only last as long as the construction phase. Duration is

rated according to the following criteria:

Table 16: Matrix used to rate duration

Du

ratio

n

Short term: Less than 1 year and is reversible. 1

Short to medium term: 2 - 3 years 2

Medium term - 3 to 10 years 3

Long term: 11-20 years 4

Permanent: in excess of 20 years 5

Spatial Scale relates to the physical extent of the zone of influence of an impact. Where

groundwater or air quality impacts, for example, can extend far beyond the footprint of the

80

activity, it is not expected that the impact of vegetation removal should extend beyond the

footprint of the activity. Scale is rated according to Table 17:

Table 17: Matrix used to rate scale

Sc

ale

/ E

xte

nt

Isolated: Limited footprint within the site will be affected (less than 50% of the

site) 1

Site Specific: The Entire Site will be affected 2

Local: Will affect the site and surrounding areas 3

Regional: Will affect the entire region / catchment / province 4

National: Will affect the country, and possibly beyond the borders of the

country 5

The Intensity of an impact is calculated by considering the severity of the impact (how it will

change the aspect, will it be destroyed completely, or altered slightly?) and the sensitivity of

the aspect (is the aspect sensitive to change, and is the aspect important to ecosystem

processes or social dynamics?). For example, if the impact is anticipated to completely

destroy a local plant population, but the plant population is commonly found and protected

in nearby surroundings, the over-all intensity is lowered. If, however, the plant population in

question is unique or protected, the intensity increases proportionately.

The Matrix which is proposed to determine Intensity is as follows:

Table 18: Matrix used to rate Intensity

Inte

nsi

ty

2

Not

significant

Ma

gn

itu

de

Slight: Little effect, negligible disturbance / benefit 1

Slight to Moderate: Effects are observable but natural process

continue

2

3 Slight

Moderate: ecosystem processes / social dynamics are permanently

altered, but functioning.

3

4 Slight -

Moderate

Moderate - High: natural / social processes are altered to the point

where function is limited

4

5 Moderate

High: The aspect is affected so that its functioning is compromised

and this effect is irreversible

5

6

Moderate -

High

Se

nsi

tivity

The aspect is not sensitive to change (No irreplaceable loss of

resource)

1

7 High The aspect is of not of significant value but is sensitive to change 2

8 Very High

The affected aspect is of moderate value and is slightly resilient to

change

3

81

9

Extremely

High

The affected aspect is of significant value and only slightly resilient to

change

4

10 Fatal Flaw

The affected aspect is valued, irreplaceable and sensitive to

change. Irreplaceable loss of significant resource

5

Therefore, considering the formula:

Significance = Consequence x Likelihood

Where Consequence = Duration + Scale + Intensity

And Intensity = Severity of the Impact + Sensitivity of the Aspect

The over-all Significance rating can be calculated as a value between 4 and 100. The score is

then categorised as follows:

• 4 to 19 = Insignificant Impact, no mitigation is required beyond standard best practice;

• From 20 to 39 = Low Impact, specific mitigation should be included in the EMP and

monitoring should be undertaken;

• From 40 to 59 = Moderate Impact, specific mitigation with strict monitoring is required;

• From 60 to 79 = High Impact, mitigation should consider alteration of the design or

process to reduce the impact significance;

• >Higher than 80 (100 max) = The Impact is so Significant that the project design must

be reconsidered to avoid the impact.

Impacts will be rated as per the abovementioned methodology without consideration of

mitigation measures first, however there may be some mitigation already inherent in the design

of the Project.

Those impacts that are rated as having a moderate impact or above will be investigated

further and management measures identified to attempt to reduce the Consequence or

Likelihood of the impact. These impacts will then be rated again, while considering the

mitigation measures that have been imposed.

6.2. Impact Identification

Environmental and Social Impacts which may result from the project and the proposed

change in mine plan, to include partial pillar extraction, have been identified in Table 19. These

were identified from the approved EMP (Digby Wells and Associates, 2006) and subsequent

specialist studies completed for the mining operation.

It should be noted that since existing boxcut adit will be utilized and no further construction of

supporting infrastructure is required, activities and aspects relating to a construction phase

were not assessed. Each of the key impacts resulting from the proposed project activities are

discussed in the sections that follow.

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Table 19: Impact Identification

Activity Aspect Description of Impact Phase

Continued mining of the underground

workings, with partial pillar extraction on retreat. Geology Alteration of geological nature and sequence. Operational


workings, with partial pillar extraction on retreat. Groundwater

Potential contamination plume of groundwater.

Coal surfaces exposed to the atmosphere within

underground workings can potentially generate

acid mine drainage (AMD).

All Phases


workings, with partial pillar extraction on retreat.

Topography

Soils

Surface water

Groundwater

Sub-surface cracking, subsidence, roof collapse

and sinkhole formation. Subsidence of surface

layers will also alter surface water flow dynamics

and possible ponding.

All Phases


workings, with partial pillar extraction on retreat. Social

Although the project is not expected to result in

any new job opportunities, the extended LoM will

result in the continued employment of mine

personnel.

Operational


workings, with partial pillar extraction on retreat. Social

Influx of unsuccessful job seekers which may

informally settle in area. Operational

83


Dewatering of the underground workings for

the safe continuation of mining. Groundwater

During the operational phase the mining will be

active, this will require dewatering of the deep

aquifer(s). This could result in a cone of

depression and a decline in water levels with a

potential loss in resource for groundwater users.

Water level impacts are however, expected to

be localised and restricted to the site. No

privately owned boreholes were identified as

sensitive receptors as they are not overlying the

underground mining activities and are not

located within the predicted cone of depression.

Operational

Dewatering of the underground workings for

the safe continuation of mining. Wetlands

Potential creation of a cone of depression, which

may drain water from the adjacent CVB

wetland, thus resulting in desiccation of the

wetland. Water entering the underground

mining area as a result of ingress into

underground mine workings may necessitate

dewatering of the underground mining area,

which may result in the discharge of dirty water

into the adjacent wetland environment.

Operational

Stockpiling Activities (all material stockpiles) Groundwater

Seepages from the overburden and

RoM/product stockpiles could be highly

mineralised with mostly sulphate.

Operational

Stockpiling Activities (all material stockpiles)

Soils

Surface water

Biodiversity

Wetlands

Erosion via wind and water leading to

sedimentation and pollution of downstream

water resources.

Operational

Decommissioning

84


Operation and maintenance of the existing

stormwater management system associated

with the existing mining activities.

Groundwater

Surface water

Potential for poor quality water impacting on

groundwater and/or surface water and

wetlands if pipelines or dams/trenches burst, spill

or leak. Due to the close proximity of the

Boschmanskop Dam, pollution incidents may

directly result in the deterioration of water quality.

Operational




Surface water

Wetlands

Reduction in Catchment yield due to

containment of dirty water on site, ponding,

infiltration and evaporation.

Operational




Soils

Surface water

Increased runoff volumes and velocity and

associated potential erosion and silt-loading of

drainage lines and downstream water bodies

and wetlands. The site is already established.

However, the clean water diversion channels

and culverts still pose a risk for erosion. Culvert

outlets can directly impact on sediment

transport. Loose particles are erodible. Stockpile

areas can also contribute to erosion.

Operational

Continued operation of mine surface

infrastructure.

Soils

Surface water

Groundwater

Impacts on water quality due to potential

hydrocarbon and other chemical spills.

Operational

Decommissioning


infrastructure.

Wetlands

Biodiversity

Spread and/or establishment of alien invasive

plant species and resultant impacts on

surrounding natural vegetation.

All Phases

85



infrastructure.

Wetlands

Biodiversity

Potential leaks, discharges and pollutants from

mining activities leaching into the surrounding

environment.

Operational


infrastructure. Biodiversity

Continued displacement and fragmentation of

the faunal community (including threatened

species) due to ongoing anthropogenic

disturbances (noise, dust and vibrations) and

habitat degradation (litter, road mortalities

and/or poaching).

Operational

Decommissioning


infrastructure. Operation of machinery and

vehicle movement.

Soils Compaction and alteration of soil characteristics Operational

Decommissioning



vehicle movement.

Cultural Loss of and disturbance to archaeological /

heritage sites / fossils Operational


infrastructure. Stockpiling activities. Visual

The plant and stockpile area may be visible to

neighbouring land users. Operational



vehicle movement. Crushing and screening

plant.

Noise Increased ambient noise levels. Operational

Decommissioning

Operation of machinery and vehicle

movement. Air Quality Gaseous emissions from machinery and vehicles. Operational

Decommissioning

86


Operation of machinery and vehicle

movement.

Soils

Surface water

Groundwater

Wetlands

Potential hydrocarbon contamination as a result

of leaks / spills. All Phases

Crushing and screening, wind erosion on

exposed areas, material handling, loading and

offloading, and vehicle movement. Air Quality Dust generation and particulate matter.

Operational

Decommissioning

Hauling of coal. Traffic Deterioration of road conditions. Operational

Provision of Services: Abstraction of water Surface water

Groundwater Irresponsible use of water and waste of water. Operational

Domestic and industrial waste generation,

handling and disposal.

Surface water

Groundwater

Soil

Potential contamination through littering and/or

incorrect waste disposal. All Phases

Domestic and industrial waste generation,

handling and disposal. Visual Odours and visual impacts. All Phases

Decommissioning and Closure of the Mine and

associated infrastructure. Social Loss of job opportunities. Decommissioning

87


Sealing and closure of underground workings. Groundwater

Increased recharge. Generally, a management

measure for underground coal mines is to flood

the mine as quickly as possible. The benefit of

flooding is reduced oxygen ingress and the

subsequent formation of AMD. Recharge could

be up to 10 times greater if subsidence occurs.

The disadvantage of this is that decanting will be

likely to occur within a shorter time period. The

negative impact of decanting outweighs the

positive impact of mine flooding.

Decommissioning

Closure

Post Closure

Sealing and closure of underground workings. Groundwater




AMD. However, the water accumulating in the

underground voids are likely to be circumneutral

but saline with high to elevated SO4. It is

expected that Fe and Mn will also be in the

mobile phase and high F is also likely.

Decommissioning

Closure

Post Closure

88


Sealing and closure of underground workings. Surface water

Wetlands

Decant is expected for Tumelo Colliery after

approximately 40 years post-operation. Although

the risk of acid formation is low, the decant water

quality is expected to contain high total

dissolved salts, with SO4 the greatest contributor,

as well as Ca, F and Mn and possibly other metals

such as As, B and Fe in solution. Likely decant

points are the incline shaft, the ring dyke structure

west of the Boschmanskop Dam as well as cracks

or fractures created by subsidence at an

elevation of approximately 1610 mamsl. The

decant quality will likely be unacceptable for

release to the environment until the contrary can

be confirmed through

measurement. Subsequent negative impacts on

biota and vegetation; altered flow regimes

(increased hydroperiod); and habitat

degradation.

Post Closure

Backfilling of boxcut adit, removal of surface

infrastructure and overall rehabilitation. Visual Improved aesthetics.

Decommissioning

Closure


infrastructure and overall rehabilitation.

Topography

Soils

Surface water

Eradication of stockpiles and replacement of

material, profiling and restoration of free

drainage.

Decommissioning

Closure


infrastructure and overall rehabilitation.

Soils

Land Capability

Biodiversity

Soil replacement, amelioration and seeding.

Vegetative cover and plant community

succession. Influx of animals to the area once

vegetation re-establishes.

Decommissioning

Closure

89

6.2.1. Geology Physiography and Topography

The approved EMP (Digby Wells and Associates, 2006) states that the impact on geology is “an

acceptable, definite, negative, permanent, local severe impact, with a moderate

significance”, however, if the impact assessment methodology is applied, it is clear that the

Impact Significance is high (the impact will definitely occur, is permanent and comprises the

majority of the site, and will affect the geology to the point where it is permanently changed).

The very nature of mining projects will inevitably result in altered geology. Despite the impact

rating as high, there is no mitigation for this impact as it is an inherent effect of mining. The

cumulative effect is of moderate to high significance, as coal reserves in South Africa are

diminishing and are non-renewable.

When coal, rock and minerals are removed from an underground mine, the overlying earth

can sink, i.e. subsidence can occur. The extent of mine subsidence depends on the mining

method, local geology, depth of mining and amount of material extracted.

All of the panels mined in the past at Tumelo Colliery have been designed for primary

extraction with maximum extraction on advance, however due to the variability of the No. 2

Seam as well as the frequency of the dolerite intrusions within the reserve limit, optimal

extraction on the advance has been extremely difficult which has resulted in larger than ideal

pillars, from a reserve optimisation perspective. This in turn has resulted in a higher than required

Safety Factor, and the potential for pillar extraction in a checkerboard layout in these areas

(G-Ro Geotechnical Services). In future mine areas, where mining has not yet commenced,

the pillars will be designed to allow for pillar extraction on retreat (Geomech Consulting (Pty)

Ltd, 2019).

Pillar failure and/or roof failure may occur in some areas as mining progresses, and in other

areas pillars could fail over time. In the short to medium term it is unlikely that subsidence will

occur, due to the bridging effect of the massive sandstone layers in the overburden, however

in the long term this sandstone beam may fail resulting in surface subsidence. Sinkhole

formation is also deemed possible but unlikely (G-Ro Geotechnical Services).

Should surface subsidence occur this will create fractures and cracks that will not only increase

recharge into the underground workings, but also increase the risk of decant due to the

creation of preferential flow paths linking the deeper fractured aquifer to surface. Additional

consequences resulting from surface subsidence are disturbances of the flow drivers into the

wetlands and loss of post-closure land uses. The impact significance related to subsidence and

the formation of sinkholes is therefore rated as high (Shangoni Aquiscience, 2020).

The topography of the surrounding area is constantly changing due to the increase of mining

and industrial activities. Should subsidence occur, this will permanently change the

topographical nature of the affected area. According to the 2013 Geotechnical Investigation

(G-Ro Geotechnical Services) should surface subsidence occur this is expected to fall into

either a Class C or Class D Subsidence Class:

• Class C can be described as: “Noticeable in flat terrain, smooth, cracks 2 – 10cm wide,

compression ridges 1 – 5 cm high’’

90

• Class D can be described as: “Noticeable in most terrain, visible vertical displacements

across cracks, cracks 10 – 50cm wide, compression ridges 5 – 50cm high”.

The various possible Subsidence Classes, as well as the Surface Profile, which they can be

expected to be associated with are indicated in Figure 16. The cumulative impact is therefore

considered to be of Moderate significance, as the area can be rehabilitated to ensure the

area blends into the natural environment and to ensure that storm water flow is re-established

from the subsided area and returned to the catchment.

Figure 16: Examples of the various Subsidence Classes (G-Ro Geotechnical Services)

6.2.2. Soils, Land Use and Land Capability

The mine is already established, existing infrastructure will continue to be utilised and no new

surface areas will be disturbed. Soil stripped during the construction phase in 2008 has been

used to construct diversion berms around the mine property, these are vegetated and thus

the possibility of erosion occurring has been minimised. However, the probability of erosion

occurring during decommissioning and closure phase is highly probable.

The main impact associated with checkerboard pillar extraction, and possible subsidence, will

be associated with the change in surface water flow dynamics and potential ponding which

may result in the potential creation of new wetlands and/or the disruption of existing wetlands.

This will change soil forms and their location in the landscape.

The soils and land capability in the area have been affected by several activities including

power generation, mining and agricultural activities such as the ploughing of lands for crops.

91

Soils have therefore been impacted on quite heavily in the area, although impacts to soil in

this project will be indirect as a result of alterations in topography and associated water flow;

hence the cumulative impacts are considered to be Moderate.

The cumulative effect on land capability is Moderate to Low and other than changes in

hydromorphic characteristics in soil, land capability is not expected to change too severely.

6.2.3. Hydrology (Surface water)

Key impacts to surface water as a result of the project, during the operational phase, relates

primarily to the deterioration of water quality, erosion/sediment transportation and reduced

surface water availability.

During the operational phase, the PCD and the dirty water channels must be maintained in

line with the requirements of GN 704 of the NWA. Spillages from the dirty water systems may

impact negatively on the chemical and microbiological characteristics of the receiving water

resources. Due to the close proximity of the Boschmanskop Dam, the Magnitude and

Probability of occurrence were rated Moderate – High (Letsolo Environmental and Water

Services, 2020).

Water falling within the dirty footprint is channelled to the existing PCD whilst clean water is

diverted around the mine area by means of clean water diversion channels, this has resulted

in a change in water flow and ultimately a reduced catchment yield (Letsolo Environmental

and Water Services, 2020).

The change in mine plan to include partial pillar extraction will not involve the use of additional

water in addition to the existing water use requirements. The water balance should however

be updated on an annual basis. Amendment and update of the water balance must be

undertaken by mine personal that have an understanding of the mine water circuit.

Consultation with a hydrologist is only required when significant changes are implemented or

where the mine personnel experience uncertainty.

Surface subsidence may result in reduction of stormwater runoff yield. Affected areas must be

regraded to eliminate ponding of water and to ensure the area is free draining (Letsolo

Environmental and Water Services, 2020). Please refer to Annexure 4 for the Surface Water

Impact Assessment.

The cumulative impact could be of Moderate – High significance if areas are not shaped to

ensure that storm water flow is re-established from subsided areas and returned to the

catchment. With storm water runoff directed back into the catchment the cumulative impact

can be considered Low as water loss will only be limited to losses through additional infiltration.

6.2.4. Geohydrology (Groundwater)

Potential impacts associated with the existing mining operations and proposed pillar extraction

were evaluated in the Groundwater Study (Shangoni Aquiscience, 2020). The findings of the

study have been summarised here and adapted to the impact assessment methodology

described in Section 6.1, please refer to Annexure 3 for the detailed report.

Dewatering of the underground workings during the operational phase will result in a cone of

depression and a decline in water levels. Mining will take place below the groundwater level

hence it is likely that the groundwater levels will be impacted. The numerical model simulations

92

indicated a drawdown of between 1 and 4 m at the LoM (max drawdown) in the shallow,

weathered aquifer. From Figure 17 and Figure 18 it is evident that the drawdown zone of

influence is confined to the mining area. Groundwater boreholes are also indicated in the

figure and while limited drawdown may be expected in mine’s monitoring boreholes10, the

cone of depression does not extend to privately owned boreholes (Shangoni Aquiscience,

2020).

The localised dewatering of the deep aquifer cannot be prevented, the probability of the

impact occurring is Definite however, due to the confining nature of the aquifer at depth the

magnitude is rated as Slight to Moderate.

Coal material contains pyrite and exposure to atmospheric oxygen and rainwater ingress

could result in the formation of acidic, saline and metal rich water. However, during the

Operational Phase the underground workings will be dewatered to allow for safe working

conditions. This water will be pumped to surface and stored in the PCD for re-use. The residence

time underground will, therefore, be limited, and water quality is expected to be good to fair

(Shangoni Aquiscience, 2020).

Two potential sources of pollution were identified on surface, being the overburden and coal

stockpiles. Modelling of the sources revealed that a pollution plume could develop during the

operational phase. The pollution plume will be localised due to the low hydraulic conductivity

of the aquifer (Shangoni Aquiscience, 2020). Refer to Figure 17.

The probability of groundwater pollution occurring during the operational phase of mining is

Highly Probable, but the magnitude is expected to be Slight to Moderate due to the localised

nature of pollution. No receptor boreholes will be impacted on (Shangoni Aquiscience, 2020).

During the decommissioning and closure phase, the mine will no longer remove water from

the underground workings and dewatering will cease. Water from recharge will begin to the

fill the underground voids. Generally, a management measure for underground coal mines is

to flood the mine as quickly as possible. The benefit of flooding the workings is reduced

oxidation and subsequently the formation of AMD. It must be noted however, that the

recharge could be up to 10 times greater if surface subsidence occurs. The disadvantage of

this occurring is that decanting will be likely to occur within a shorter time period. The negative

impact of decanting outweighs the positive impact of mine flooding (Shangoni Aquiscience,

2020).

Decant is expected to occur approximately 40 years post-operation. Although the risk of acid

formation is low, the decant water quality is expected to contain high TDS, with SO4 as the

greatest contributor, including Ca, F and Mn and possibly other metals such as As, B and Fe in

solution. Likely decant points are the incline shaft, the ring dyke structure west of the

Boschmanskop Dam, as well as cracks or fractures created by subsidence at an elevation of

approximately 1,610 mamsl. The decant quality will likely be unacceptable for release to the

environment until the contrary can be confirmed through measurement. Facilities should be

constructed to contain or treat the decant. A decant rate of approximately 80 m3/d is

10 The groundwater model was based on a worst-case scenario and the presence of dolerite sills may

render certain boreholes isolated from effects of dewatering, but this would need to be confirmed with

monitoring.

93

expected. Note that this volume is based on a worst-case scenario as no evapotranspiration

was considered (Shangoni Aquiscience, 2020).

Cumulative impacts associated with the neighbouring mining and power generation activities

were not assessed in the groundwater study due to data limitations. However, given the nature

of the project activities, geological and geohydrological context, cumulative impacts are

anticipated with regards to water quality (Shangoni Aquiscience, 2020).

Figure 17: Model simulated drawdown cone in 2021 (Shangoni Aquiscience, 2020)

94

Figure 18: Model simulated drawdown cone in 2023 (Shangoni Aquiscience, 2020)

Figure 19: Model simulated groundwater pollution plume 2022 (Shangoni Aquiscience, 2020)

95

6.2.5. Terrestrial Ecology

The approved EMP (Digby Wells and Associates, 2006) identifies impacts from mining activities

to include habit loss and displacement of animals due to noise, machinery and fences. Due

to the site-specific impact the significance was rated as Moderate.

The proposed partial pillar extraction is not expected to have a direct impact on the fauna

and flora. Although indirect impacts associated with the change in surface water flow

dynamics and ponding, should subsidence occur, could result in potential changes in soil and

wetland characteristics.

Impacts identified in the decommissioning and closure phase are largely positive as the

disturbed surface area will be rehabilitated, fertilized and vegetated. Biodiversity in the area

should increase as animals begin to return back to the area. Other impacts identified include

those associated with environmental pollution as a results of hydrocarbon spillages/leaks and

the potential encroachment of alien invasive species.

6.2.6. Freshwater Ecology

Two wetland systems were identified with the MRA, specifically a CVB wetland partially within

and adjacent to the western boundary of the MRA, and a depression wetland in the south-

eastern corner of the MRA. Generally, the conversion of natural areas to largely agricultural

and mining-related land-uses have impacted on the overall hydrological and

geomorphological functioning of both wetlands (Scientific Aquatic Services, 2019).

Taking into consideration the locality of the depression wetland, approximately 1.7km from the

existing and proposed mining activities, and the presence of a catchment divide between the

wetland and the mining activities, no impacts on the depression wetland are anticipated as

result of Tumelo’s planned activities (Scientific Aquatic Services, 2019).

The CVB wetland is however, located downgradient of the existing mine infrastructure area. In

addition to this some of the remaining No. 2 seam reserves are located under the CVB wetland,

the area is however not targeted for pillar extraction (Scientific Aquatic Services, 2019).

Changes to the hydrological regime as a result of potential subsidence, impaired water quality

and the establishment of alien vegetation is likely to present a Moderate risk prior to mitigation.

The significance of potential decant and the impact on the receiving environment is

considered to be High (Scientific Aquatic Services, 2019).

6.2.7. Air Quality and Noise

Dust-fall, PM10 and PM2.5 are key pollutants of concern associated with operations at Tumelo

Colliery and are emitted from the following key sources:

• Particulate Emissions:

o Wind erosion from exposed areas: the coal product stockpile and ROM stockpile;

o Front-end loaders used to load trucks with coal and load the hopper;

o Conveyor transfer points; and

o Crushing and screening.

The following conclusions are made based on the Air Quality Impact Assessment (AQIA) and

dispersion model compiled for the operations (Rayten Environmental and Engineering

Consultants, 2020), attached as Annexure 6:

96

• Predicted incremental dust-fall rates and PM2.5 concentrations comply with the

applicable standards over most of the areas surrounding Tumelo Colliery (Figure 20).

• Higher daily average PM2.5 concentrations and dust-fall rates are predicted west of the

mine, but in near proximity to the mining right area boundary, and emission sources

(Figure 21). Predicted daily average PM10 concentrations comply with the daily

standard of 75 µg/m3 over areas situated east, west and south of the mine (Figure 22).

• Higher PM10 concentrations are projected north-west and north of the mine.

Exceedances of the daily standard are predicted near the MRA boundary (within

~5km) and south-west of Pullens Hope.

• Predicted annual average PM10 concentrations comply with the annual standard of 40

µg/m3 over most of the project area.

• Maximum predicted incremental PM10 and PM2.5 concentrations and dust-fall rates at

the identified nearby sensitive receptors (represented as discrete receptors)

surrounding the mine are mostly low and comply with the applicable standards. Higher

concentrations and dust-fall rates are predicted around discrete receptors 2 (mine

building), 7 (dwelling), 23 (farmhouse/dwellings) and 26 (Hendrina Power Station)

which are located in close proximity to the western and northern parts of the mining

right boundary.

In conclusion the dispersion modelling results indicate relatively low incremental dust-fall rates,

PM2.5 concentrations and annual average PM10 concentrations. On the other hand, high

incremental daily average PM10 concentrations with exceedances are projected over areas

situated north-west and north of the mine (Rayten Environmental and Engineering Consultants,

2020).

Figure 20: Predicted Dust-Fall Rates associated with Tumelo Colliery (Rayten, 2020)

97

Figure 21: Predicted Daily Average PM2.5 Concentrations associated with Tumelo Colliery

(Rayten, 2020)

Figure 22: Predicted Daily Average PM10 Concentrations associated with Tumelo Colliery

(Rayten, 2020)

98

Figure 23: Predicted Annual Average PM2.5 Concentrations associated with Tumelo Colliery

(Rayten, 2020)

Figure 24: Predicted Annual Average PM10 Concentrations associated with Tumelo Colliery

(Rayten, 2020)

6.2.8. Sites of Archaeological and Cultural Significance

One cultural heritage site, an old farmyard, was identified in the MRA. It is noted that the

farmyard will not be undermined (Plan 23) and thus no direct or indirect impacts to the site is

expected.

It should be noted that the subterranean presence of archaeological artifacts and/or remains

is always a distinct possibility. It is possible that some sites may only become known later on. In

99

such cases a qualified archaeologist should be called in to investigate the occurrence. The

‘Chance Find’ protocol and monitoring programme as outlined in the EMP should be followed.

The MRA is underlain by the highly fossiliferous Vryheid formation and unfossiliferous Jurassic.

The Vryheid Formation is known to be rich in coal deposits, while the coal itself does not contain

any recognisable fossil plant material the mudstone and shales associated with the coal

deposits are known to host plant fossils. The underground mining will be undertaken by

continuous miners, as such only the coal seam, and not the shales, will be targeted. Taking this

into account, the potential impact to fossil heritage resources is low. In the event fossils are

found, these should be rescued and a palaeontologist called to assess and collect a

representative sample. The ‘Chance Find’ protocol and monitoring programme as outlined in

the EMP should be followed.

6.2.9. Socio-Cultural Environment

In terms of socio-economic impacts of the Mine, the approved EMP (Digby Wells and

Associates, 2006) identified the development and operation of the mine as a benefit to local

trade and industry, the EMP rated the impact as “highly significant, definite, regional, medium

term beneficial and positive”.

The positive impact of employment (both direct and indirect) is acknowledged and included

in this impact assessment. It must be noted however, that the change in mine plan to include

partial pillar extraction will not contribute to job creation but rather focus on the retention of

jobs by prolonging the Life of Mine (LoM) (MTS Holdings (Pty) Ltd, 2019).

The potential negative socio-economic impacts associated with Mining operations includes

the influx of job-seekers to the area, resulting in increased unemployment and poverty in the

local communities, and an increased risk in criminal activities.

6.3. Impact Assessment

The summary impact assessment is presented in Table 20. The most significant anticipated

impacts, without mitigation, include:

• Potential for subsidence, and altered surface water flow dynamics;

• Alteration of groundwater flow due to dewatering; and

• Reduction in water quality as a result of decant and subsequent loss of biodiversity of

the CVB wetland.

100

Table 20: Impact Assessment

Description of Impact Phase Nature of

Impact

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Ma

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Sc

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Exte

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Significance

(without

Mitigation)

Lik

elih

oo

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Se

nsi

tivity

Ma

gn

itu

de

Du

ratio

n

Sc

ale

/

Exte

nt

Significance (with

Mitigation)

Alteration of geological nature and sequence. Operational Negative 5 5 3 5 2 75 High 5 5 3 5 2 75 High

Potential contamination plume of groundwater. Coal surfaces exposed to the

atmosphere within underground workings can potentially generate acid mine

drainage (AMD).

All Phases Negative 4 4 2 4 3 52 Moderate 3 4 2 4 3 39 Low

Sub-surface cracking, subsidence, roof collapse and sinkhole formation.

Subsidence of surface layers will also alter surface water flow dynamics and

possible ponding.

All Phases Negative 4 4 5 5 2 64 High 3 4 5 5 2 48 Moderate

Although the project is not expected to result in any new job opportunities, the

extended LoM will result in the continued employment of mine personnel. Operations Positive 5 3 5 2 4 70 High 5 3 5 2 4 70 High

Influx of unsuccessful job seekers which may informally settle in area. Operational Negative 3 3 3 2 4 36 Low 2 3 3 2 3 22 Low

During the operational phase the mining will be active that will require

dewatering of the deep aquifer(s).This will result in a cone of depression and a

decline in water levels with a potential loss in resource for users. Water level

impacts are however, expected to be localised and restricted to the site. No

privately owned boreholes were identified as sensitive receptors as they are not

overlying the underground mining activities and are not located within the

predicted cone of depression.

Operational Negative 5 4 2 3 2 55 Moderate 5 4 2 3 2 55 Moderate

Potential creation of a cone of depression, which may drain water from the

adjacent CVB wetland, thus resulting in desiccation of the wetland; and water

entering the underground mining area as a result of ingress into underground

mine workings may necessitate dewatering of the underground mining area,

which may result in the discharge of dirty water into the adjacent wetland

environment.

Operational Negative 4 4 4 3 3 56 Moderate 4 4 4 3 2 52 Moderate

Seepages from the overburden and RoM stockpiles could be highly mineralised

with mostly sulphate. Operational Negative 4 4 2 4 3 52 Moderate 3 4 2 4 2 36 Low

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Impact

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Ma

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ratio

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Sc

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/

Exte

nt

Significance

(without

Mitigation)

Lik

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oo

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Se

nsi

tivity

Ma

gn

itu

de

Du

ratio

n

Sc

ale

/

Exte

nt

Significance (with

Mitigation)

Erosion via wind and water leading to sedimentation and pollution of

downstream water resources.

Operational

Decommissioning Negative 4 4 3 3 3 52 Moderate 3 4 3 3 3 39 Low

Potential for poor quality water impacting on groundwater and/or surface

water and wetlands if pipelines or dams/trenches burst, spill or leak. Due to the

close proximity of the Boschmanskop Dam and CVB wetland, pollution

incidents may directly result in the deterioration of water quality.

Operational Negative 4 4 4 3 3 56 Moderate 3 4 2 3 3 36 Low

Reduction in catchment yield due to containment of dirty water on site,

ponding, infiltration and evaporation. Operational Negative 4 4 3 3 4 56 Moderate 2 4 2 3 1 20 Low

Increased runoff volumes and velocity and associated potential erosion and

silt-loading of drainage lines and downstream water bodies and wetlands. The

site is already established. However, the clean water diversion channels and

culverts still pose a risk for erosion. Culvert outlets can directly impact on

sediment transport. Loose particles are erodible.

Stockpile areas can also contribute to erosion.

Operational Negative 4 4 3 3 3 52 Moderate 2 4 3 3 2 24 Low

Impacts on water quality due to potential hydrocarbon and other chemical

spills.

Operational


Spread and/or establishment of alien invasive plant species and resultant

impacts on surrounding natural vegetation. All Phases Negative 4 2 4 4 3 52 Moderate 3 2 4 4 2 36 Low

Potential leaks, discharges, pollutant from mining activities leaching into the

surrounding environment. Operational Negative 4 2 3 4 3 48 Moderate 2 2 3 4 2 22 Low

Continued displacement and fragmentation of the faunal community

(including threatened species) due to ongoing anthropogenic disturbances

(noise, dust and vibrations) and habitat degradation (litter, road mortalities

and/or poaching).

Operation


Compaction and alteration of soil characteristics Operational

Decommissioning Negative 3 3 3 3 2 33 Low 2 3 3 3 2 22 Low

Loss of and disturbance to archaeological / heritage sites / fossils Operational Negative 2 5 3 5 3 32 Low 2 5 3 5 2 30 Low

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Impact

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ratio

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Sc

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Exte

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Significance

(without

Mitigation)

Lik

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tivity

Ma

gn

itu

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Du

ratio

n

Sc

ale

/

Exte

nt

Significance (with

Mitigation)

The plant and stockpile area may be visible to neighbouring land users. Operational Negative 3 3 2 3 2 30 Low 2 3 2 3 2 20 Low

Increased ambient noise levels. Operational


Gaseous emissions from machinery and vehicles. Operational

Decommissioning Negative 4 4 3 3 3 52 Moderate 4 4 3 3 3 52 Moderate

Potential hydrocarbon contamination as a result of leaks / spills. All Phases Negative 4 3 2 3 2 40 Moderate 3 3 2 3 1 27 Low

Dust generation and particulate matter. Operational

Decommissioning Negative 4 4 4 3 3 56 Moderate 4 4 3 3 3 52 Moderate

Deterioration of road conditions. Operational Negative 4 3 3 3 3 48 Moderate 4 3 2 3 2 40 Moderate

Irresponsible use of water and waste of water. Operational Negative 4 4 2 3 3 48 Moderate 3 4 2 3 2 33 Low

Potential contamination through littering and/or incorrect waste disposal. All Phases Negative 4 3 3 3 2 44 Moderate 3 3 3 3 1 30 Low

Odours and visual impacts. All Phases Negative 2 3 2 3 2 20 Low 2 3 1 3 1 16 Insignificant

Increased recharge. Generally, a management measure for underground

coal mines is to flood the mine as quickly as possible. The benefit of flooding is

reduced oxygen ingress and the subsequent formation of AMD. Recharge

could be up to 10 times greater if subsidence occurs. The disadvantage of this

is that decanting will be likely to occur within a shorter time period. The negative

impact of decanting outweighs the positive impact of mine flooding.

Decommissioning

Closure

Post Closure

Negative 4 4 4 4 3 60 High 3 4 4 4 3 45 Moderate

103


Impact

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Significance

(without

Mitigation)

Lik

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Ma

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ratio

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Sc

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Exte

nt

Significance (with

Mitigation)

Potential contamination plume of groundwater. Coal surfaces exposed to the

atmosphere within underground workings can potentially generate acid mine

drainage (AMD). However, the water accumulating in the underground voids

are likely to be circumneutral but saline with high to elevated SO4. It is expected

that Fe and Mn will also be in the mobile phase and high F is also likely.

Decommissioning

Closure

Post Closure

Negative 4 4 4 4 3 60 High 3 4 3 4 3 42 Moderate

Potential for poor quality leachate from decant or plume day lighting

impacting on nearby water bodies. Decant is expected for Tumelo Colliery

after approximately 40 years post-operation. Although the risk of acid formation

is low, the decant water quality is expected to contain high total dissolved salts,

with SO4 the greatest contributor, as well as Ca, F and Mn and possibly other

metals such as As, B and Fe in solution. Likely decant points are the incline shaft,

the ring dyke structure west of the Boschmanskop Dam as well as cracks or

fractures created by subsidence at an elevation of approximately 1610 mamsl.

The decant quality will likely be unacceptable for release to the environment

until the contrary can be confirmed through

measurement. Subsequent negative impacts on biota and vegetation; altered

flow regimes (increased hydroperiod); and habitat degradation.

Post Closure Negative 4 4 4 5 3 64 High 3 4 3 5 3 45 Moderate

Improved aesthetics. Decommissioning

Closure Positive 5 3 4 4 2 65 High 5 3 4 4 2 65 High

Eradication of stockpiles and replacement of material, profiling and restoration

of free drainage.

Decommissioning

Closure Positive 4 3 4 4 2 52 Moderate 4 3 4 4 2 52 Moderate

Soil replacement, amelioration and seeding. Vegetative cover and plant

community succession. Influx of animals to the area once vegetation re-

establishes.

Decommissioning

Closure Positive 5 3 4 4 2 65 High 5 3 4 4 2 65 High

Loss of job opportunities. Decommissioning Negative 5 4 2 4 3 65 High 5 4 2 4 3 65 High

104

7. IMPACT MANAGEMENT

The significance of impacts associated with the project is discussed in Sections 6.2 and 6.3 in

terms of the probability of the impact occurring, the intensity, the duration and the spatial

scale of the impact.

Impact Management should be proportionate to the significance of an impact prior to the

implementation of mitigation measures and will aim to reduce either the probability of an

impact occurring, or the consequence of an impact (in terms of its duration, scale and

intensity).

7.1. Impact Management Outcomes

For each activity associated with the proposed project, a set of impact management

outcomes and associated management actions have been identified and are described in

this section.

Table 21: Impact Management Outcomes

Impact Description Impact Management Outcomes

Alteration of geological nature and sequence. No management required – this is the nature of

mining.




acid mine drainage (AMD).

Measures aim to reduce the likelihood of AMD

formation and ensure adequate rehabilitation is

implemented.

Sub-surface cracking, subsidence, roof collapse

and sinkhole formation.

Measures aim to reduce the potential for roof /

pillar failure and surface subsidence.

Altered flow dynamics due to subsidence of

surface layers as pillars are removed on retreat.

Management measures seek to ensure the

surface areas are restored to free-draining, self-

sustaining systems

Influx of unsuccessful job seekers which may

informally settle in area.

Management measures aim to ensure effective

communication regarding opportunities, and

the prevention of informal settlement formation,

as well as to provide an emergency plan in the

event of people settling illegally in the area.

Reduction of local groundwater and alteration of

groundwater flow due to dewatering.

The impact can only be mitigated by ensuring

affected water users are appropriately

compensated should dewatering result in loss of

access to their lawful water use.

Potential creation of a cone of depression, which

may drain water from the adjacent CVB wetland,

thus resulting in desiccation of the wetland. Water

entering the underground mining area as a result

of ingress into underground mine workings may

necessitate dewatering of the underground mining

area, which may result in the discharge of dirty

water into the adjacent wetland environment.

Management measures aim to protect wetland

habitats by containing potential pollution

sources within the dirty water footprint.

105


Seepages from the overburden and RoM /product

stockpiles could be highly mineralised with mostly

sulphate.

The management measures aim to prevent

groundwater contamination.

Erosion of stockpiles via wind and water leading to

sedimentation and pollution of downstream water

resources.

The aim of the management measures is to

prevent erosion from occurring, thereby

preventing siltation of downstream water bodies

Potential for poor quality water impacting on

groundwater and/or surface water and wetlands if

pipelines or dams/trenches burst, spill or leak. Due

to the close proximity of the Boschmanskop Dam

and CVB wetland, pollution incidents may directly

result in the deterioration of water quality.

Management measures aim to prevent leaks

from dirty-water containment facilities and

ensure leak detection and repair is implemented

timeously if leaks do occur, to prevent

contamination

Reduction in catchment yield due to containment

of dirty water on site, ponding, infiltration and

evaporation.

The impact is unavoidable as water is contained

on site to prevent pollution downstream.

Management measures aim to keep the dirty

water footprint as small as possible.

Increased runoff volumes and velocity and

associated potential erosion and silt-loading of

drainage lines and downstream water bodies and

wetlands.

The aim of the management measures is to

prevent erosion from occurring, thereby

preventing siltation of downstream water

bodies.

Impacts on water quality due to potential

hydrocarbon and other chemical spills.

The objective of the management measures is

firstly to prevent the spillage of hydrocarbons,

and to ensure that contamination is contained

and remedied in the event of accidental spills in

such a manner as not to cause contamination.

Spread and/or establishment of alien invasive

plant species and resultant impacts on surrounding

natural vegetation.

Management measures aim to limit the spread

of alien invasive species and other problem

weeds.

Potential leaks, discharges, pollutant from mining

activities leaching into the surrounding

environment.

Management measures aim to ensure that

pollution sources are contained within the dirty

water areas on site.

Continued displacement and fragmentation of

the faunal community (including threatened

species) due to ongoing anthropogenic

disturbances (noise, dust and vibrations) and

habitat degradation (litter, road mortalities and/or

poaching).

Activity footprint is limited to the approved

areas, limiting residual impacts caused by creep

and edge-effects. The CVB wetland associated

with the Boschmanskop Dam will provide an

ecological corridor for fauna movement.

Management measures aim to create

awareness amongst staff.

Compaction and alteration of soil characteristics

Compaction is limited to the approved footprint

areas and remediated by ripping / scarifying as

soon as an area is no longer required.

Loss of and disturbance to archaeological /

heritage sites / fossils

During the course of the project activities, no

heritage sites are affected / damaged in any

way.

The plant and stockpile area may be visible to

neighbouring land users.

The management measures aim to improve

housekeeping, and limit the potential for dust

fallout.

106


Increased ambient noise levels. To keep noise generation to a minimum.

Gaseous emissions from machinery and vehicles.

The management measures seek to limit and

minimise the gaseous emissions associated with

vehicles and machinery.

Potential hydrocarbon contamination as a result of

leaks / spills from vehicles and machinery.

Management measures aim to prevent

hydrocarbon spills and ensure effective clean-

up in emergency situations to prevent

contamination.

Dust generation and particulate matter

The management measures intend to ensure

that dust generation is minimised and managed

on site, and that ongoing monitoring is

undertaken to ensure compliance to the

relevant legislation.

Deterioration of road conditions. To ensure the safety and security of other road

users.

Irresponsible use of water and waste of water. Management measures aim to promote

awareness and prevent water wastage.

Potential contamination through littering and/or

incorrect waste disposal.

The measures prescribed in terms of general

waste management aim to ensure compliance

with the Norms and Standards for the storage

and handling of waste, to prevent wind-blown

waste dispersion, to promote awareness among

staff to prevent littering and to ensure that waste

management areas are neat and well-

managed.

Odours and visual impacts

Management measures aim to ensure waste

storage areas are well-managed and that waste

does not remain on site for excessive periods.

Increased recharge in the event of subsidence

could result in decant occurring within a shorter

time period.

The management measures seek to minimise the

amount of recharge from rainfall.

Potential for poor quality leachate from decant or

plume impacting on nearby water bodies.

Management measures aim to contain

contamination should decant occur.

Reduced risk of silt loading on downstream water

bodies (due to clearing of stockpiles). Free

drainage restored to area.

The impact Is positive. Management measures

aim to prevent potential erosion from occurring

from rehabilitated surface areas.

Create adequate environment for flora to establish

and reduce risk of erosion and associated

sedimentation of water courses.

The impact is positive. Management measures

are aimed at effective amelioration of topsoil as

required.

Loss of employment at closure.

Management measures aim to ensure that job-

losses are communicated well in advance and

that mine workers had received adequate

experience and training while employed at the

mine to improve their chances of finding

alternative employment after closure.

107

7.2. Impact Management Actions

Specific management actions for each of the identified impacts are described in Table 22

overleaf along with the time-periods for implementation of the mitigation measures, the

monitoring methods (monitoring of implementation of mitigation measures and monitoring of

compliance to standards where relevant), monitoring frequency and the person(s) responsible

for monitoring.

Monitoring and reporting requirements are further detailed in Section 7.3.

108

Table 22: Impact Management Actions

Activity Impact / Risks Management Actions / Mitigation Measures

Time periods for

implementation of

Mitigation

Monitoring Method

(Implementation & Compliance)

Monitoring

Frequency

Person(s) Responsible for

Monitoring

Continued mining of the

underground workings, with

partial pillar extraction on

retreat

Alteration of geological

nature and sequence. No mitigation possible. This is the nature of mining. - - - -




retreat

Potential contamination

plume of groundwater. Coal

surfaces exposed to the

atmosphere within

underground workings can

potentially generate acid

mine drainage (AMD).

Minimize residence time in underground workings

by pumping groundwater seepage to surface.

Maintain water pumped from underground in a

closed circuit.

Operational

Groundwater Monitoring.

Routinely refine, update and

validate the conceptual and

numerical models by incorporating

ongoing monitoring data.

Quarterly

Every 2 years

SHE Manager

Geohydrologist




retreat

Sub-surface cracking,

subsidence, roof collapse and

sinkhole formation.

Subsidence of surface layers

will also alter surface water

flow dynamics and possible

ponding.

Avoid mining in areas where subsidence is likely to

occur (i.e. areas shallower than 40m or areas where

surface infrastructure exists). Apply reasonable

mining techniques with appropriate safety factors.

Should cracks be identified, these are to be filled

and rehabilitated. Should subsidence occur, this

must be made to be free draining.

Throughout LoM

Mining tell-tales to be

systematically installed to monitor

for real time roof movement. In

addition to this convergence

monitoring between the mining

roof and floor could be conducted

by installing monitoring

instrumentation in strategic

locations before commencing with

mining.

Daily Mine Engineer / Rock

Mechanic




retreat

Although the project is not

expected to result in any new

job opportunities, the

extended LoM will result in the

continued employment of

mine personnel.

No mitigation required. Implement the approved

Social and Labour Plan. Manage job-seeker

expectations and ensure clear communication.

Operational Community liaison officer and

forum reports. Monthly

Community liaison officer / HR

Manager




retreat

Influx of unsuccessful job

seekers which may informally

settle in area.

Implement the approved Social and Labour Plan.

Manage job-seeker expectations and ensure clear

communication.

Operational Community liaison officer and



Manager

Dewatering of the

underground workings for the

safe continuation of mining.

During the operational phase

the mining will be active that

will require dewatering of the

deep aquifer(s).This will result

in a cone of depression and a

decline in water levels with a

potential loss in resource for

users. Water level impacts are

however, expected to be

localised and restricted to the

site. No privately owned

boreholes were identified as

sensitive receptors as they are

not overlying the

underground mining activities

and are not located within

the predicted cone of

depression.

No specific management measures are proposed

other than to continue with water level and quality

monitoring in source and receptor monitoring

boreholes. If impact is confirmed by monitoring,

impacts to the community’s and farmers’ water

supply must be mitigated by the client providing an

alternative reliable, clean water supply.

Operational

Flow meters to be installed on the

dewatering point and abstraction

Volumes to be recorded monthly.

Groundwater Monitoring (incl.

levels).

Routinely refine, update and

validate the conceptual and

numerical models by incorporating

ongoing monitoring data.

Monthly

Quarterly

Every 2 years

SHE Manager

Geohydrologist

109


Time periods for

implementation of

Mitigation

Monitoring Method


Monitoring

Frequency


Monitoring

Dewatering of the

underground workings for the

safe continuation of mining.

Potential creation of a cone

of depression, which may

drain water from the adjacent

CVB wetland, thus resulting in

desiccation of the wetland;

and water entering the

underground mining area as

a result of ingress into

underground mine workings

may necessitate dewatering

of the underground mining

area, which may result in the

discharge of dirty water into

the adjacent wetland

environment.

Ensure that the shallow underground mining areas

are located outside of the wetland recharge soils.

Any areas where decant points may be

determined by a geohydrological assessment,

need to be carefully managed throughout the life

of the mine. Water levels need to be strictly

managed to ensure they are kept below any

decant level while ensuring that a significant cone

of depression impact does not take place. If

decant does occur, all water is to be treated to the

background water quality values prior to release

into the receiving environment. All measures as

stipulated by the Rock Mechanic Engineer and the

geohydrologist to mitigate against subsidence and

dewatering, formation of a pollution plume and

decant respectively, must be implemented.

Throughout LoM. Visual inspections. Weekly SHE Manager

All material stockpiles.

Seepages from the

overburden and RoM

stockpiles could be highly

mineralised with mostly

sulphate.

Move coal stockpiles on a first-in-first-out basis to

reduce extent of coal stockpile areas. Coal

stockpile and handling must be in the designated

areas only. Intercept seepage from stockpiles and

maintain in the affected water circuit. PCD to be

managed with the sufficient freeboard (0.80m).

Should environmentally unacceptable

concentrations of constituents of concern be

identified during monitoring of the seepage plume,

hydraulic plume containment should be initiated.

Do not discharge water that does not comply to

release standards.

Throughout LoM.

Visual inspections.

Groundwater Monitoring.

Annual IWUL Compliance Audit to

include compliance against

GN704.

Weekly

Quarterly

Annually

SHE Manager

External Auditor

All material stockpiles.

Erosion via wind and water

leading to sedimentation and

pollution of downstream

water resources.

All soil and overburden stockpiles must have top

and toe

perimeter berms to prevent soil wash out.

Revegetate all bare soils. Rehabilitate all disturbed

areas as soon as they are no longer required.

Provide erosion control infrastructure (including

drains and energy dissipaters) in all areas of

concentrated water discharge, along all linear

infrastructure, and in any area within the footprint

where erosion has resulted/been accelerated due

to mining or related activities.

Throughout LoM. Visual inspections.

Annual EMP Compliance Audits.

Weekly

Annually

SHE Manager

External Auditor

110


Time periods for

implementation of

Mitigation

Monitoring Method


Monitoring

Frequency


Monitoring

Operation and maintenance

of the existing stormwater

management system

associated with the existing

mining activities.

Potential for poor quality

water impacting on

groundwater and/or surface

water and wetlands if

pipelines or dams/trenches

burst, spill or leak. Due to the

close proximity of the

Boschmanskop Dam and CVB

wetland, pollution incidents

may directly result in the

deterioration of water quality.

Dirty water channels should be designed and

upgraded to collect contaminated water and to

dispose it into the PCD. PCD to be managed with

the sufficient freeboard (0.80m) at all times. Regular

inspections to be conducted of all pipelines,

trenches and berms. Should any spills or leaks be

detected, these should be attended to

immediately. Ensure the clean and dirty water

diversion systems are maintained and regularly

cleaned. Emergency response measures must be

put in place. Dirty water should be prioritised for re-

use. Stormwater Management Plan (SWMP) must

be adhered to throughout the project. All

discharges should be managed according to the

Direct Estimation of Ecological Effect Potential

(DEEEP) method if unavoidable.

Throughout LoM.

Visual inspections.

Surface water Monitoring.



GN704.

Weekly

Quarterly

Annually

SHE Manager

External Auditor



management system


mining activities.

Reduction in catchment yield

due to containment of dirty

water on site, ponding,

infiltration and evaporation.

Dirty water footprint to be maintained as small as

possible. No new areas to be disturbed. All clean

water to be diverted around site. SWMP must be

adhered to throughout the project.

Throughout LoM GN704 audits to be undertaken

annually as part of IWUL Audits. Annual External Auditor



management system


mining activities.

Increased runoff volumes and

velocity and associated

potential erosion and silt-

loading of drainage lines and

downstream water bodies

and wetlands. The site is

already established.

However, the clean water

diversion channels and

culverts still pose a risk for

erosion. Culvert outlets can

directly impact on sediment

transport. Loose particles are

erodible. Stockpile areas can

also contribute to erosion.

Implement clean and dirty water separation

throughout the site in accordance with GN704.

Install silt traps where necessary. Prevent erosion

and remedy eroded areas immediately if erosion is

detected despite preventative measures. The

necessary flood attenuation and erosion control

structures to be put in place at each outlet.

Throughout LoM

Visual inspections.



GN704.

Monthly

Annually

SHE Manager

External Auditor

Continued operation of mine

surface infrastructure.

Impacts on water quality due

to potential hydrocarbon and

other chemical spills.

All diesel storage must be within concrete bunded

areas that contain 110% of storage capacity if

roofed or 120% storage capacity if not roofed. Re-

fuelling must take place on a sealed surface area

to prevent ingress of hydrocarbons into the topsoil.

Bunds in the workshop, wash bay and fuel storage

facility will be fitted with an outlet valve and drain

to an oil trap. The outflow will flow through an oil

trap and water component will be treated and

recycled as process water. Oil from oil traps will be

removed to the used hydrocarbon drums which will

be temporarily stored in concrete bunded areas

prior to removal from site by a reputable

hydrocarbon waste contractor. Spills should be

reported and cleaned up immediately. Spill kits

must be available on site and personnel trained to

utilise these.

Throughout LoM Visual inspections Daily Workshop Manager

111


Time periods for

implementation of

Mitigation

Monitoring Method


Monitoring

Frequency


Monitoring



Spread and/or establishment

of alien invasive plant species

and resultant impacts on

surrounding natural

vegetation.

The mine must compile and implement an Alien

Invasive Species management plan. Throughout LoM

Visual Inspections.

EMP Compliance Audit.

Quarterly

Annual

SHE Manager

External Auditor



Potential leaks, discharges,

pollutant from mining

activities leaching into the

surrounding environment.

Good housekeeping will be implemented to

prevent spills and leaks from occurring. The site will

be managed in accordance with GN704, to ensure

accidental spills are contained in dirty areas.

Throughout LoM

Visual inspections.



GN704.

Monthly

Annually

SHE Manager

External Auditor



Continued displacement and

fragmentation of the faunal

community (including

threatened species) due to

ongoing anthropogenic

disturbances (noise, dust and

vibrations) and habitat

degradation (litter, road

mortalities and/or poaching).

Ensure activities are limited to the surface

infrastructure area, and that no new areas are

disturbed. Prohibit the harvesting of indigenous

trees for firewood

and indigenous flora in general. Do not hinder,

harm, and trap animals.

Maintenance of wetlands and associated natural

vegetation will provide ecological corridors and

refuges for animals.

Throughout LoM Visual inspection of

all demarcations/barriers. Monthly SHE Manager



Operation of machinery and

vehicle movement.

Compaction and alteration of

soil characteristics

Only designated / approved roads to be used and

driving outside of these areas will not be allowed.

Rehabilitate all disturbed areas as soon as they are

no longer required. Revegetate all bare soils.

Ameliorate soils as needed to establish stable

vegetation communities on stockpiles / berms. Soils

must not be trafficked if wetter than the plastic limit.

Rip or disc any compacted soils as needed.

Throughout LoM Visual inspection of

all demarcations/barriers. Monthly SHE Manager




vehicle movement.

Loss of and disturbance to

archaeological / heritage

sites / fossils

A chance find procedure will be implemented on

site, for archaeological and palaeontological

resources that may occur on site and are as yet

undiscovered. If any fossiliferous material such as

leaf impressions, stems, seeds, wood, insect wings, is

identified, the palaeontologist will be consulted. If

potential heritage resources are discovered, all

work in the area will stop and an archaeologist will

be consulted.

Throughout LoM, Chance

find procedure to be

included in induction

Training records. Annual SHE Manager


surface infrastructure. All

material stockpiles.

The plant and stockpile area

may be visible to

neighbouring land users.

Apply dust control measures and other

environmental measures to ensure impact area is

contained. Apply good housekeeping practices. All

berms and soil stockpiles will be vegetated.

Throughout LoM

Maintain communication with

I&APs and provide a platform for

I&APs to lodge any comments

and/or complaints. Complaints

register to be inspected weekly.

Weekly Mine Manager




vehicle movement.

Increased ambient noise

levels.

Machinery and equipment will be regularly

serviced. Noise control measures will be considered

such as soundproofing of point sources, use of

silencers, using strobe lights rather than beepers

where feasible and where this won't compromise

safety of people on site. Machinery will be

maintained within operational noise limits and will

be switched off when not in use.

Throughout LoM Ambient noise monitoring. Annual SHE Manager

112


Time periods for

implementation of

Mitigation

Monitoring Method


Monitoring

Frequency


Monitoring


vehicle movement. Gaseous emissions from

machinery and vehicles.

Vehicles and machinery will be regularly serviced.

Implement a strict speed limit on all roads. Where

possible, use cleaner fuels.

Throughout LoM. Servicing

of vehicles as per

manufactures

recommendations.

Inspect vehicle servicing logs. Monthly Workshop Manager


vehicle movement.

Potential hydrocarbon

contamination as a result of

leaks / spills.

Trucks, machinery and equipment will be regularly

serviced, as per maintenance schedule, to reduce

the risk of leaks. Spill kits and drip trays must be

available on site and personnel trained on utilising

these. Any leakages should be reported and

treated immediately. Implement good

housekeeping practices. Ensure vehicles are

serviced timeously.

Throughout LoM Visual inspections. Daily Workshop Manager

Crushing and screening,

wind erosion on exposed

areas, material handling,

loading & offloading, and

vehicle movement.

Dust generation and

particulate matter.

Implement dust suppression measures (e.g. water

sprays on unpaved roads and other dust-

generating areas). Reduce height of material

transfer. Immediate clean-up of any material (i.e.

coal) spillages. Trucks transporting coal product

offsite must use covers (e.g. tarpaulin covers) to

prevent windblown dust during transportation.

Throughout LoM Dust Fallout Monitoring. Monthly SHE Manager

Hauling of coal. Deterioration of road

conditions.

Regular inspections by the Mine of the main routes

to and from the site, along with regular reporting to

and liaison with the relevant roads authorities.

Maintain a complaints register and record

community complaints regarding the state of

roads. Resolve complaints in consultation with the

roads authorities.

Throughout LoM.

Remediation as required. Visual inspections Monthly SHE Manager

Provision of Services:

Abstraction of water

Irresponsible use of water and

waste of water.

Water saving initiatives to be included in the

environmental awareness training. Utilise water on

site responsibly. Water use at the Mine must be

measured and recorded. Inspect all water

management facilities and pipelines for leakages

and immediately repair.

Throughout LoM

Flow meters to be installed on all

abstraction points, and volumes

recorded.

Update water balance.

Monthly

Annually SHE Manager

Domestic and industrial

waste generation, handling

and disposal.


through littering and/or

incorrect waste disposal.

Waste will be managed to comply with norms and

standards and be stored in a designated area

protected from runoff. Environmental awareness

training will be implemented to all employees and

visitors to the site. Regular clean-up campaigns will

be undertaken if necessary. Bins with covers will be

provided in all necessary areas where waste is

generated. Reputable contractors will be used to

remove waste off site for disposal, and records of

disposal will be kept.

Throughout LoM

Visual inspections, review of waste

manifest as part of the Annual EMP

Compliance Audit.

Monthly

Annually

SHE Manager

External auditor

Domestic and industrial

waste generation, handling

and disposal.

Odours and visual impacts. Good housekeeping and regular removal of waste

off site for safe disposal. Throughout LoM

Visual inspections, review of waste

manifest as part of the Annual EMP

Compliance Audit.

Monthly

Annually

SHE Manager

External auditor

113


Time periods for

implementation of

Mitigation

Monitoring Method


Monitoring

Frequency


Monitoring

Sealing and closure of

underground workings

Increased recharge.

Generally, a management

measure for underground

coal mines is to flood the mine

as quickly as possible. The

benefit of flooding is reduced

oxygen ingress and the

subsequent formation of

AMD. Recharge could be up

to 10 times greater if

subsidence occurs. The

disadvantage of this is that

decanting will be likely to

occur within a shorter time

period. The negative impact

of decanting outweighs the

positive impact of mine

flooding.

Minimise recharge of rainwater into underground

voids by creating free draining slopes. No ponding

should be allowed. Installation and testing of

additional groundwater monitoring boreholes

(cluster of shallow and deep piezometers) to

monitor the shallow and fractured aquifer.

Rehabilitate all high recharge footprints as soon as

possible. If subsidence occurs and sinkholes are

formed during operation or after closure, they

should be rehabilitated as soon as possible to

minimise water and oxygen inflow from the surface.

Through LOM and 5 years

post closure

Visual inspections for subsidence.

Groundwater monitoring Quarterly SHE Manager, Mine Manager




plume of groundwater. Coal

surfaces exposed to the

atmosphere within

underground workings can

potentially generate acid

mine drainage (AMD).

However, the water

accumulating in the

underground voids are likely

to be circumneutral but saline

with high to elevated SO4. It is

expected that Fe and Mn will

also be in the mobile phase

and high F is also likely.

The deterioration of groundwater within the deep

aquifer cannot be prevented. Sealing of the adit to

prevent free recharge of the adit. The final surface

needs to be free draining to minimize recharge. A

rehabilitation plan must be compiled and

implemented in line with NEMA and NWA.

Abstraction from deep boreholes that are close to

the mine workings should be avoided so that

contaminants will not migrate towards the

abstraction boreholes, and away from the mine

voids. If impact is confirmed by monitoring, impacts

to the community’s and farmers’ water supply must

be mitigated by the client providing an alternative

reliable, clean water supply.


post closure Groundwater Monitoring Quarterly SHE Manager, Mine Manager

114


Time periods for

implementation of

Mitigation

Monitoring Method


Monitoring

Frequency


Monitoring



Potential for poor quality

leachate from decant or

plume impacting on nearby

water bodies. Decant is

expected for Tumelo Colliery

after approximately 40 years

post-operation. Although the

risk of acid formation is low,

the decant water quality is

expected to contain high

total dissolved salts, with SO4

the greatest contributor, as

well as Ca, F and Mn and

possibly other metals such as

As, B and Fe in solution. Likely

decant points are the incline

shaft, the ring dyke structure

west of the Boschmanskop

Dam as well as cracks or

fractures created by

subsidence at an elevation of

approximately 1610 mamsl.

The decant quality will likely

be unacceptable for release

to the environment until the

contrary can be confirmed

through measurement.

Subsequent negative impacts

on biota and vegetation;

altered flow regimes

(increased hydroperiod); and

habitat degradation.

Sealing of the adit to prevent free recharge of the

adit. Pond formation should be prevented on

surface by creating a free draining surface through

landscaping along slopes and filling of

holes/fractures/cracks in flat-lying areas. A

rehabilitation plan must be compiled and

implemented in line with NEMA and NWA.

Re-establish surface drainage to the pre-mining

conditions as far as practical. Restore normal

infiltration rates to areas where recharge was

reduced due to surface compaction, such as at the

shaft infrastructure areas. Regulate rebounding

water levels to below maximum critical level to

prevent decant. Install monitoring boreholes into

different parts of the mine voids to monitor the

rebounding water levels. If subsidence occurs

and sinkholes are formed during operation or after

closure, they should be rehabilitated as soon as

possible to minimise water and oxygen inflow from

the surface. Mine-affected water should be

intercepted at decant points and treated prior to

being released into the environment. Installation of

passive treatment systems will be considered.


post closure

Visual inspections for subsidence.

Groundwater monitoring Quarterly SHE Manager, Mine Manager

Backfilling of boxcut adit. Improved aesthetics. Rehabilitate disturbed areas as soon as possible.

Rehabilitation monitoring

must continue for at least

5 years after rehabilitation

has been implemented, or

until the relinquishment

criteria are me

The rehabilitated area must be

assessed once a year for

compaction, fertility, and erosion.

The soils fertility must be assessed

by a soil specialist yearly (during

the dry season so that

recommendations can be

implemented before the start of

the wet season) as to correct any

nutrient deficiencies. Rehabilitated

areas must be free-draining to

prevent ponding and ingress of

water.

Annually SHE Manager, External

Specialists (as required)

Backfilling of boxcut adit,

removal of surface

infrastructure and overall

rehabilitation.

Eradication of stockpiles and

replacement of material,

profiling and restoration of

free drainage.

Rehabilitate disturbed areas as soon as possible.






criteria are me



115


Time periods for

implementation of

Mitigation

Monitoring Method


Monitoring

Frequency


Monitoring

Backfilling of boxcut adit,

removal of surface

infrastructure and overall

rehabilitation.

Soil replacement,

amelioration and seeding.

Vegetative cover and plant

community succession. Influx

of animals to the area once

vegetation re-establishes.

Rehabilitate disturbed areas as soon as possible.






criteria are me



Decommissioning and

Closure of the Mine and

associated infrastructure.

Loss of job opportunities.

Before closure, communicate with employees the

downscaling process to manage expectations.

Assist with reference letters etc. where possible.

Implement the SLP.

Throughout LoM Community liaison officer and



Manager

116

7.3. Monitoring and Reporting Requirements

This section of the report contains the monitoring, auditing and reporting requirements relevant

to the mine with specific emphasis on the proposed projects.

Table 23 contains a summary of the monitoring plans that must be implemented and identifies

the person responsible for undertaking the audit / monitoring and the frequency of each

monitoring / auditing and reporting exercise.

All monitoring that requires the analysis of laboratory results must only be associated with

SANAS accredited laboratories. Surface and groundwater monitoring must be undertaken

according to the Mine’s approved Water Use License. Air Quality and dust monitoring should

be undertaken in accordance with the National Environmental Management Air Quality Act

and the Regulations promulgated thereunder. Auditing will be in accordance with the EIA

Regulations, 2014 (as amended).

Table 23: Monitoring, Auditing and Reporting Summary

Impact that

requires

monitoring

Monitoring description Person

responsible for

monitoring

Frequency

of

monitoring

Reporting

requirements

General

compliance – all

EMPr

commitments

Visual inspections SHE Manager11 Weekly Internal

Internal audits SHE Manager Monthly

during

operations

Internal –

maintain register

External Regulation 34

Audits

Independent

External Auditor

Annually DMR

(note: PPP to be

undertaken if

audit findings

result in the

need for EMPr

Amendment)

Hazardous

excavations and

structures

Visual inspections to ensure

that safety measures

including barriers, fencing

etc. are in place.

SHE Manager Weekly Internal

Mine Engineer Monthly Internal –

maintain register

Mine Manager Bi-Annually Mine Health &

Safety

Pillar failure,

surface

subsidence and

/ or cracking

During operations: Mining

tell tales to be systematically

installed to monitor for real

time roof movement. In

addition to this

convergence monitoring

between the mining roof

and floor could be

Mine Engineer Daily Mine Health &

Safety

11 Note, the responsible person indicated here as the Safety Health and Environmental Manager (SHE

Manager) is the person responsible for the management of environmental matters on the Mine, as

designated by the Mine Manager.

117

Impact that

requires

monitoring


responsible for

monitoring

Frequency

of

monitoring

Reporting

requirements

conducted by installing

monitoring instrumentation

in strategic locations before

commencing with mining.

Post closure field surveys to

identify areas of surface

subsidence and / or

cracking, compare to

previous surveys.

Mine Engineer &

Mine Manager

Bi-Annually Mine Health &

Safety

Physical

destruction and

general

disturbance of

biodiversity

Visual inspections to ensure

that EMPr commitments with

respect to biodiversity are

complied with

SHE Manager Monthly Internal

Rehabilitation monitoring. SHE Manager Monthly Internal

Independent

Specialist

Annually Report to DMR

(Financial

Provision & EMPr

Compliance)

Monitoring the

establishment and spread

of Alien Invasive Plant

Species.

SHE Manager Quarterly Internal

Independent

Specialist

Annually Report to DMR

(Financial

Provision & EMPr

Compliance)

Aquatic Biomonitoring Independent

Specialist

As per IWUL Annual Report

to DHSWS

Deterioration of

soil quality or loss

of soils

Soil monitoring of

rehabilitated areas.

Independent

Specialist

Annually

for fertility

Report to DMR

(Financial

Provision & EMPr

Compliance)

SHE Manager Bi-annually

for erosion

Report to DMR

(Financial

Provision & EMPr

Compliance)

Pollution of

surface water

resources

Surface Water Monitoring. Samples: SHE

Manager;

Analysis: SANAS

accredited

laboratory;

Reporting:

suitably qualified

independent

specialist

Monthly Report to DHSWS

118

Impact that

requires

monitoring


responsible for

monitoring

Frequency

of

monitoring

Reporting

requirements

Contamination

of groundwater

The water monitoring

programme should be

assessed and updated by a

professional geohydrologist

on an annual basis.

Effectiveness of existing

monitoring borehole

positions should be re-

evaluated on closure.

Samples: SHE

Manager;

Analysis: SANAS

accredited

laboratory;

Reporting:

suitably qualified

independent

specialist

Quarterly Report to DHSWS

Groundwater

quantity

Dipping of groundwater

levels.

SHE Manager Quarterly Report to DHSWS

Increase in air

pollution

Monthly Dust Fallout

Monitoring must continue at

the existing 4 buckets.

SHE Manager /

Independent

Specialist

Monthly Annual

Reporting to the

National

Atmospheric

Emissions

Inventory System

(NAEIS)

Greenhouse Gas (GHG)12 SHE Manager Annually Annual

Reporting to the

National

Atmospheric

Emissions

Inventory System

(NAEIS)

Increase in noise

levels

Occupational noise

monitoring.

SHE Manager Monthly Internal

Ambient noise monitoring. Independent

Specialist

Annually Internal Report

and conflict

resolution

7.4. Environmental Awareness Plan

Environmental awareness training is critical for two primary reasons:

a) the workforce must understand how they can play a role in achieving the objectives

specified in the EMP, and

b) the workforce must understand their obligations in terms of the implementation of the

EMP and adherence to environmental-legislative requirements.

A training needs analysis is to be performed through all levels of the organization including

those within the administration, plant, workshop and underground sectors. Each of the

12 GHG Emissions Reporting is also required to also comply with the Carbon Tax Act.

119

categories/levels of the organization have different responsibilities and roles, accordingly

different knowledge requirements are applicable.

The Training Department in conjunction with the SHE Manager are responsible for ensuring job

specific training for personnel performing tasks, which can cause significant environmental

and social impacts (e.g. receipt of bulk hazardous chemicals/fuel, hazardous materials

handling, responding to emergency situations etc.).

The SHE Officer responsible for environmental awareness training will keep records of the

persons who attended the training sessions and these sessions must incorporate methods to

test the training attendee’s understanding of the subject matter presented. The SHE Officer

must, on the basis of evidence, determine that the employees are competent in the training

material and learning outcomes.

Effectiveness of the environmental awareness training will be done by the management

through task observations and during internal and external audits. All training material for

presentation to personnel and contractors will be reviewed annually to ensure consistency

with organizational requirements and best practice guidelines. In addition to this, annual

monitoring reports, audit results and all incident reports will be reviewed; any short comings

and non-compliancy will be highlighted and management measures incorporated or

improved upon within the training material.

7.5. Emergency Response

Though every effort has been made to identify the potential impacts and risks associated with

the Tumelo Colliery and to prescribe management and mitigation measures associated with

each impact, emergency situations can arise for which the Mine has to prepare.

Procedures that the Mine has to implement in response to certain emergency events are

detailed in the table below.

Table 24: Emergency Response

No Situation Response procedure

1 Spillage of chemicals,

hydrocarbons or waste

If there is a risk of a spillage of any substance migrating outside of

the dirty-water containment areas on the Mine, the Mine

Management will immediately notify residents/users downstream of

the pollution incident. The Mine will further identify and provide

alternative resources should contamination impact adversely on

the existing users.

In the event of a spill occurring on site:

• Cut off the source if the spill is originating from a pump,

pipeline or valve and ensure the infrastructure is ‘made

safe’.

• Contain the spill (e.g. construct temporary earth bund

around source).

• Pump excess hazardous liquids on the surface to temporary

containers (e.g. 210 litre drums, mobile tanker, etc.) for

appropriate disposal.

120


• Remove hazardous substances from damaged

infrastructure to an appropriate storage area before it is

removed/repaired.

Spill kits will be available at all areas where hydrocarbons,

chemicals etc are stored and/or handled. Access to these areas

will be restricted to those personnel who have received training in

the storage and handling of hazardous substances, and the

emergency clean-up procedure (including the use of spill kits and

the appropriate disposal of contaminated soils as hazardous

waste).

All spill incidents must be reported to the SHE Manager

immediately, who will assess the incidents and set up an

investigation team if deemed necessary.

Reportable incidents must be reported to the DMR, DHSWS and all

other relevant authorities.

2 Discharge of dirty water to

the environment (Dam

Wall Failure, burst dirty

water pipes / trenches,

overtopping)

Turn off supply to the Dam / Pipeline.

Dispatch necessary emergency services.

All reasonable measures must be implemented to stop the spread

of contaminated water (berms / channels can be placed around

the spillage area).

All incidents must be reported to the SHE Manager immediately,

who will assess the incidents and set up an investigation team if

deemed necessary.

As a preventative measure, all water containment facilities should

be operated with a freeboard of at least 0.8 m.

Reportable incidents must be reported to the DMR, DHSWS and all

other relevant authorities.

3 Pollution of surface water Personnel discovering the incident must inform the SHE

department of the location and contaminant source

(immediately).

Apply the principals listed for Item 1 and 2 above.

Absorbent brooms will be used to absorb surface spills of

hydrocarbon contaminants.

Contamination entering the surface water drainage system should

be redirected into the dirty water system.

The SHE Manager will collect in-stream water samples downstream

of the incident to assess the immediate risk of contamination.

4 Groundwater

contamination

Use the groundwater monitoring boreholes as scavenger wells to

pump out the polluted groundwater for re-use in the process water

circuit (hence containing the contamination and preventing

further migration).

Investigate the source of contamination and implement

control/mitigation measures.

5 Evacuate the area downstream of the failure (if relevant).

121


Flooding (from failure of

surface water control

infrastructure and/or

extreme rainfall events)

Using the emergency response team, rescue/recover and

medically treat any injured personnel.

Temporarily reinstate/repair storm-water diversions during the storm

event (e.g. emergency supply of sandbags).

Close the roads affected by localised flooding or where a storm-

water surge has destroyed crossings/bridges.

The use of emergency pumps should occur if the water floods the

opencast areas or boxcut adits.

6 Risk of drowning from

falling into water dams

Attempt rescue of individuals from land.

Get assistance of emergency response team whilst attempting

rescue or to carry out rescue of animals and/or people as relevant.

Ensure medical assistance is available to recovered individual.

Prevent this situation by ensuring adequate access control to water

containment facilities.

7 Veld fires Evacuate mine employees (as well as contractors, visitors etc.) from

areas at risk.

Notify downwind residents and industries of the danger.

Assist those in imminent danger/less able individuals to evacuate

until danger has passed.

Provide emergency firefighting assistance with available trained

mine personnel and equipment.

8 Falling into hazardous

excavations

Personnel discovering the fallen individual or animal must mobilise

the emergency response team to the location of the incident and

provide a general appraisal of the situation (e.g. human or animal,

conscious or unconscious, etc.).

The injured party should be recovered by trained professionals such

as the mine emergency response team.

A doctor (or appropriate medical practitioner)/ambulance should

arrive at the scene to provide first aid and transport individual to

hospital.

A nearby vet should be consulted in the case of animal injury.

9 Road traffic accidents (on

site)

The individual discovering the accident (be it bystander or able

casualty) must raise the alarm giving the location of the incident.

Able personnel at the scene should shut down vehicles where it is

safe to do so.

Access to the area should be restricted and access roads cleared

for the emergency response team.

Vehicles must be made safe first by trained professionals (e.g.

crushed or overturned vehicles).

Casualties will be moved to safety by trained professionals and

provided with medical assistance.

122


Medical centres in the vicinity with appropriate medical

capabilities will be notified if multiple seriously injured casualties are

expected.

A nearby vet should be consulted in the case of animal injury.

10 Development of informal

settlements

The mine will inform the local authorities (municipality and police)

that people are illegally occupying the land and ensure that action

is taken within 24hrs.

11 Explosions Explosions can occur in the workshop areas when working with gas

cylinders and chemicals. Explosives are also present on site for

blasting. Underground coal mining operations without proper

ventilation can also lead to underground explosions. These could

result in employees being injured and requiring medical assistance.

The procedure to be followed is:

Safe evacuation routes should be devised in the event of an

uncontrolled explosion and all staff trained on relevant evacuation

routes and assembly points

Once safe to do so first responders may provide first aid to injured

parties.

All relevant emergency response units must be notified and

hospitals informed of incoming patients.

DMR to be notified of the incident.

12 Uncovering of graves,

archaeological / historical

sites

Upon finding any archaeological or historical material all work at

the affected area must cease.

Personnel discovering the site must inform the SHE Manager

immediately.

The area should be demarcated in order to prevent any further

work there until an investigation has been completed.

An archaeologist should be contacted immediately to provide

advice on the matter.

• Should it be a minor issue, the archaeologist will decide on

future action. Depending on the nature of the find, it may

include a site visit.

• Should the find prove to be of archaeological significance

a Phase 2 rescue operation may be required subject to

permits issued by SAHRA.

SAHRA’s APM unit must be notified (Phillip Hine, Tel: 021 202 8654). In

the event that unmarked human burials are uncovered, the SAHRA

Burial Grounds and Graves unit should be notified (Mimi Seetelo, Tel:

012 320 8490).

Prior to the relocation of any graves, permission for the exhumation

and relocation of graves must be obtained from the relevant

descendants (if known), SAHRA, the National Department of

Health, the Provincial Department of Health, the Premier of the

Province and the local Police.

123


The exhumation process must comply with the requirements of the

relevant Ordinance on Exhumations, and the Human Tissues Act, 65

of 1983 (and the NHRA if relevant).

Work on site will only continue after the archaeologist/ SAHRA has

agreed to such.

13 Uncovering of fossils

Personnel discovering the fossil must inform the SHE Manager

immediately.

Any fossiliferous material (plants, insects, bone, coal) should be

rescued, and put aside in a suitably protected place. This way the

mining activities will not be interrupted.

A professional palaeontologist should be contacted immediately

to provide advice on the matter.

Photographs of the putative fossils can be sent to the

palaeontologist for a preliminary assessment.

Fossil plants or vertebrates that are considered to be of good

quality or scientific interest by the palaeontologist must be

removed, catalogued and housed in a suitable institution where

they can be made available for further study. Before the fossils are

removed from the site a SAHRA permit must be obtained.

124

8. CLOSURE, REHABILITATION AND FINANCIAL PROVISION

8.1. Closure Objectives

The closure objectives for Tumelo Colliery, can be summarised as follows:

• To limit the possible health and safety threats to humans and animals. Ensure the area

is made safe and that the backfilled boxcut adit is stable over time. Undertake suitable

corrective actions in areas where surface subsidence may develop due to pillar

extraction activities, integrating these into the surrounding topography, and ensuring

they are free draining.

• To ensure post-mining land capability is at least similar to pre-mining which is grazing

and some arable lands.

• To ensure that the land capability is self-sustaining.

• To ensure that pre-mining land uses can continue.

• To ensure that no dirty water from the site enters the surrounding surface water systems.

• To maintain flow in downstream rivers to prevent deterioration of downstream

ecological status.

• To ensure that possible plumes originating from the mining areas do not impact

significantly on the surface water features or surrounding users’ boreholes.

• To ensure that groundwater users that are impacted have alternative sustainable

water sources of the similar quality and quantity.

• To ensure that vegetation growth and cover on the rehabilitated areas is sustainable.

• To ensure that alien invasive growth is eradicated until the closure certificate is granted.

• To encourage surrounding animals to return into the rehabilitated areas to maintain the

surrounding biodiversity.

• To ensure that aquatic ecosystems are maintained as close as possible to that of the

pre-mining environment.

• To minimise the disturbance on wetlands.

• To ensure that the adjacent wetland conditions are similar to that of the current Present

Ecological State.

• To ensure that residual impacts after closure of the mine are adequately managed.

• To ensure appropriate closure certification is obtained.

8.2. Actions to Attain Closure Objectives

Closure and rehabilitation of the Tumelo Colliery will involve the following activities:

• During decommissioning, infrastructure no longer required by the future land

owner/user will be demolished or removed.

• Non-leaching building waste, such as concrete foundations, can be placed in the

boxcut adit if additional material is required.

• Plant and processing infrastructure will be re-used at other sites or sold to other mining

companies before being considered as scrap.

• All scrap metal will be removed and sold where possible, or disposed of at an

appropriate site.

• All other waste will be separated and removed from site. These will be recycled where

possible or removed by reputable contractors to appropriate waste facilities for that

particular waste type.

125

• All fences will be dismantled and either disposed of at a permitted disposal site or sold

as scrap. Fences erected to cordon off dangerous areas will remain in place and

maintained, and will only be removed once such sites are considered safe and stable.

• The underground mine will be sealed as per standard mining practices and the boxcut

adit filled with the overburden and subsoil stockpile material.

• Roads or sections of roads no longer required after completion of mining will be

identified. These roads will be ripped down and rehabilitated, as will all compacted

infrastructure areas.

• The pollution control dam will remain on site to ensure the protection of the surrounding

environment. This will only be rehabilitated once the area is stable and runoff water

from the area is of a quality suitable for discharge into the environment.

• The entire site will be appropriately graded and contoured and the topsoil will be

spread over site using agricultural equipment to prevent compaction of soils.

• The soil fertility status should be determined by soil chemical analysis after levelling

(before seeding/re-vegetation), and soil amelioration should be done as

recommended by a soil specialist, in order to correct the pH and nutritional status

before re-vegetation.

• The rehabilitated sections should be re-vegetated with a grass mixture dominated by

local climax species in early summer to stabilize the soil.

• A short-term fertilizer program should be based on the soil chemical status after the first

year in order to maintain the fertility status for 2 to 3 years after rehabilitation until the

area can be declared as self-sustaining.

• Once the seed mixture is sown, the land must be rolled using a Cambridge roller to

ensure consolidation around the seeds and effective moisture retention. Seeded lands

are to be checked after germination has occurred, via soil sample analysis and visual

surveys conducted on a monthly basis. Following the results of this sampling, post

dressing of fertiliser should be considered. Where poor germination or cover is noted,

these areas will be reseeded or hand-planted with seedling plugs. Once the area has

been rehabilitated and seeded, access to the area should be restricted (to prevent

grazing / trampling preventing effective vegetation establishment).

• A floral assessment should be completed on an annual basis during decommissioning

and closure to ensure plant communities are well established.

8.3. Financial Provision

The estimated financial provision required for rehabilitation of the Tumelo Colliery is

R12,477,858.42 (ex. Vat). These costs are based on estimated areas and average rates for the

activities provided by three different contractors, refer to Table 25. This estimate further

assumes that no rehabilitation is undertaken during the operational life of the facility.

126

Table 25: Quantum for Financial Provision

Environmental Consultant:

K.van Rooyen

(Pr.Sci.Nat) Mine Manager:

Client: Tumelo Coal Mines (Pty) Ltd Signed: Surveyor:

Site: Location: CPI 4,5%

Date: Co-ord SE: 26° 4'3.08"S 29°36'48.81"E VAT 15%

Total 1 Total 2 Total 3 Total FP

Current Impacts Annual Opex Expected Disturbance Latent Risks and Impacts[((Total1-Annual

Opex)+Total2+Total3)*(1+CPI+2%)*

VAT]

Concrete R 0,00 R 0,00 R 0,00 R 0,00 R 0,00

Material handling R 3 867 744,29 R 0,00 R 0,00 R 0,00 R 4 737 019,82

Mining R 837 342,14 R 0,00 R 0,00 R 0,00 R 1 025 534,79

Parking Area R 0,00 R 0,00 R 0,00 R 0,00 R 0,00

Rail R 0,00 R 0,00 R 0,00 R 0,00 R 0,00

Rehabilitation R 562 489,35 R 0,00 R 0,00 R 195 000,00 R 927 735,08

Roads R 0,00 R 0,00 R 0,00 R 0,00 R 0,00

Structures and Buildings R 0,00 R 0,00 R 0,00 R 0,00 R 0,00

Waste facilities R 0,00 R 0,00 R 0,00 R 0,00 R 0,00

Water Management R 0,00 R 0,00 R 0,00 R 0,00 R 0,00

Concrete R 36 710,13 R 0,00 R 0,00 R 0,00 R 44 960,74

Material handling R 56 363,34 R 0,00 R 0,00 R 0,00 R 69 031,00

Mining R 0,00 R 0,00 R 0,00 R 0,00 R 0,00


Rail R 0,00 R 0,00 R 0,00 R 0,00 R 0,00

Rehabilitation R 174 731,28 R 0,00 R 0,00 R 0,00 R 214 002,13

Roads R 0,00 R 0,00 R 0,00 R 0,00 R 0,00

Structures and Buildings R 2 143 133,70 R 0,00 R 0,00 R 0,00 R 2 624 803,00

Waste facilities R 291 500,00 R 0,00 R 0,00 R 0,00 R 357 014,63


Concrete R 59 933,19 R 0,00 R 0,00 R 0,00 R 73 403,17

Material handling R 0,00 R 0,00 R 0,00 R 0,00 R 0,00

Mining R 0,00 R 0,00 R 0,00 R 0,00 R 0,00


Rail R 0,00 R 0,00 R 0,00 R 0,00 R 0,00

Rehabilitation R 0,00 R 0,00 R 0,00 R 0,00 R 0,00

Roads R 0,00 R 0,00 R 0,00 R 0,00 R 0,00

Structures and Buildings R 1 329 077,30 R 0,00 R 0,00 R 0,00 R 1 627 787,42



Concrete R 2 327,20 R 0,00 R 0,00 R 0,00 R 2 850,24


Mining R 0,00 R 0,00 R 0,00 R 0,00 R 0,00

Parking Area R 6 315,00 R 0,00 R 0,00 R 0,00 R 7 734,30

Rail R 0,00 R 0,00 R 0,00 R 0,00 R 0,00

Rehabilitation R 72 498,30 R 0,00 R 0,00 R 0,00 R 88 792,29

Roads R 0,00 R 0,00 R 0,00 R 0,00 R 0,00

Structures and Buildings R 65 800,00 R 0,00 R 0,00 R 0,00 R 80 588,55



Concrete R 29 320,72 R 0,00 R 0,00 R 0,00 R 35 910,55


Mining R 0,00 R 0,00 R 0,00 R 0,00 R 0,00


Rail R 0,00 R 0,00 R 0,00 R 0,00 R 0,00


Roads R 0,00 R 0,00 R 0,00 R 0,00 R 0,00

Structures and Buildings R 37 748,91 R 0,00 R 0,00 R 0,00 R 46 232,98



Concrete R 0,00 R 0,00 R 0,00 R 0,00 R 0,00


Mining R 0,00 R 0,00 R 0,00 R 0,00 R 0,00


Rail R 0,00 R 0,00 R 0,00 R 0,00 R 0,00


Roads R 420 051,23 R 0,00 R 0,00 R 0,00 R 514 457,74




Concrete R 0,00 R 0,00 R 0,00 R 0,00 R 0,00


Mining R 0,00 R 0,00 R 0,00 R 0,00 R 0,00


Rail R 0,00 R 0,00 R 0,00 R 0,00 R 0,00


Roads R 0,00 R 0,00 R 0,00 R 0,00 R 0,00




Current Liability (Ex Vat) R 9 993 086,08 R 0,00 R 0,00 R 195 000,00 R 12 477 858,42

PullenshopeTumelo Colliery

Year ending 29 February 2020

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127

9. ASSUMPTIONS, UNCERTAINTIES AND GAPS IN KNOWLEDGE

• All specialist studies are conducted to certain levels of confidence, and in all instances

known and accepted methodologies have been used and confidence levels are

generally high. This means that in most cases the situation described is accurate at high

certainty levels, but there exists the probability that some issues have not been

identified. Specific assumptions, limitations and gaps in knowledge are discussed in the

specialist reports contained in Annexure 3 – Annexure 7.

• There are inherent errors in GPS and mapping programmes which must be considered

when transferring plans to on-site activities.

• Statistical analyses and mathematical models are merely tools that assist the

researcher in assessing field observations and have innate assumptions which can

reduce objectivity of the results obtained. This is not seen as a major flaw but should

always be considered when assessing results.

• Impact assessment is a predictive tool to identify aspects of a development that need

to be prevented, altered or controlled in a manner to reduce the impact to the

receiving environment, or determine where remediation activities will need to be

incorporated into the overall development plan. This does not mean that the impact

will occur at the predicted significance, but provides guidance on the formulation of

the management and monitoring requirements which need to be incorporated into

the EMP.

• This report was made available for a public review and comment period of 30 days,

extended by an additional 21 days as per the Directions published on 5 June 2020.

• The level of project detail presented in this report is sufficient to ensure a realistic

identification of potential impacts associated with the proposed project changes. In

assessing the potential significance of those impacts, the precautionary principle was

implemented and a worst-case scenario assessed in each instance.

10. CONCLUSION AND RECOMMENDATIONS

The application relates to a change in mine plan to include the partial pillar extraction of the

No. 2 seam on retreat (checkerboard layout). No additional surface infrastructure is proposed.

Thus, no new Listed Activities are triggered by the proposed project changes, and a Part 2

Amendment is relevant.

This report has been compiled as per Regulation 32 of the EIA Regulations, 2014 (as amended).

The advantages and disadvantages associated with the proposed project changes are

summarised in Table 26 below.

Table 26: Advantage and disadvantages associated with the proposed project changes

Advantages Disadvantages

Economically viable

Maximum exploitation of the Reserve

Continued employment of mine personnel

Continued support of local businesses, contractors

and suppliers

Risk of subsidence

Potential decrease in groundwater quantity

and quality

Possible disturbance of flow drivers to CVB

wetland

128

Advantages Disadvantages

Contribution to GDP

10.1. Concluding Statement / Impact Statement

The impact assessment in Section 6 above discusses impacts in terms of the specialist findings

and the approved EMP; and provides an overall impact assessment associated with the


Although some impacts of high significance have been identified, no fatal flaws have been

identified for the project. Impacts of high significance (pre-mitigation) are largely associated

with post-closure groundwater quality (potential decant) and the change of surface flow

regimes as a result of potential surface subsidence. Additional consequences resulting from

surface subsidence are disturbances of the flow drivers into the wetlands and loss of post-

closure land usages (Shangoni Aquiscience, 2020).

The risk of subsidence is rated as high during the post-operational phases.

Surface subsidence will create fractures and cracks that will not only increase recharge into

the underground voids but also increase the risk of decant due to the creation of preferential

flow paths linking the deeper fractured aquifer to surface. It is however unlikely that decant

water from the mine will be acidic, but it will potentially be high in TDS, contributed largely by

sulphate (SO4) (Shangoni Aquiscience, 2020).

10.2. Specific Conditions to be Included in the Amended Environmental

Authorisation

• Upon finding any archaeological, cultural or historical material all work at the affected

aera must cease and the chance find protocol as outlined in the Emergency Response

Plan followed (Section 7.5).

• It should not be necessary to encroach on the CVB wetland, since no new surface

infrastructure is planned. Therefore, the CVB wetland and applicable zone of

regulation as defined by GN704 as it relates to the NWA must be demarcated and

marked as a no-go area.

• Underground mining closer to the surface should be carried out with extreme caution

to ensure that the subsurface process sustaining the CVB wetland system are not

impaired. In this regard, safety factors as determined by the Rock Mechanic Engineer

(GeoMech Consulting (Pty) Ltd (2019) must be implemented.

• Clean and dirty water systems must be kept separate in line with GN704 as it relates to

the NWA.

• The adit must be sealed on closure to prevent free recharge of the adit.

• If decant does occur, all water is to be treated to the background water quality values

prior to release into the receiving environment.

129

• A rehabilitation plan must be implemented, and the plan should be done in the line

with the contents of the NWA and NEMA, to avoid subsequent negative environmental

impacts that may occur.

• Continuation of the water monitoring programme for a period of 5 years post

operations, to establish trends.

11. REFERENCES

Archaetnos Culture and Cultural Resources Consultants . (2020). Archaeological impact

assessment for the Tumelo Colliery application for Amendment to include partial pillar

extraction, Report No. AE02019V. Pretoria.

Bamford, P. M. (2019). Palaeontological Impact Assessment for the Section 102 Amendment

Application for the existing Tumelo Colliery, located on Farm Boschmanskop 154 IS,

between Pullenshope and Hendrina, Mpumalanga Province.

Delta Water Systems Modelling. (2013). Tumelo Coal, Numerical Flow and Transport Model.

Digby Wells and Associates. (2006). Environmental Impact Assessment Report and

Environmental Management Programme, Boschmanskop Coal Mine, Pullenshope,

Mpumalanga.

GCS Water and Environmental (Pty) Ltd. (2014). Application form for the rectification of

unlawful commencement or continuation of a listed activity in terms of S24G of the

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

GCS Water and Environmental Services (Pty) Ltd. (2018). Tumelo Coal Mine, 2017 Integrated

Water and Waste Management Plan Update.

Geomech Consulting (Pty) Ltd. (2019). Tumelo No.2 Seam Pillar Design Criteria Comparison on

the No.2 Seam Future Secondary Extraction and No Secondary Extraction.

G-Ro Geotechnical Services. (n.d.). Geotechnical Report on the Feasibility of

Checkerboarding the mined out areas at Tumelo Coal Mine.

Home. (2020, February 25). Retrieved from Steve Tshwete Local Municipality:

https://www.stevetshwetelm.gov.za/index.html

Letsolo Environmental and Water Services. (2020). Tumelo Coal Mines (Pty) Ltd, Hydrological

Impact Assessment, Ref No.: LWES 873.

Metallurgical Resources Consulting. (2019). Tumelo Coal Mine, Mine Works Programme.

MTS Holdings (Pty) Ltd. (2019). Social and Labour Plan, Mmakau Mining (Pty) Ltd for Tumelo

Coal Mines (Pty) Ltd, MP30/5/1/2/2/10115 MR.

Mucina, L. a. (2006). The vegetation of South Africa, Lesotho and Swaziland. Strelitzia 19.

Pretoria: South African National Biodiversity Institute.

Rayten Environmental and Engineering Consultants. (2020). Tumelo Colliery Air Quality Impact

Assessment.

130

Scientific Aquatic Services. (2019). Freshwater Ecological Assessment as part of the

Environmental and Water Use Authorisation Process for the proposed Amendment to

the Mine Plan of the Tumelo Colliery.

Shangoni Aquiscience. (2020). Geohydrological Impact Assessment for Underground Mining

Activities at Tumelo Colliery.

Steve Tshwete Local Municipality. (2019/2020). Integrated Development Plan, 2017 - 2022

Cycle.

Annexure 1: Curriculum Vitae of EAP

Annexure 2: Public Participation Report

Annexure 3: Groundwater Report

Annexure 4: Surface Water Report

Annexure 5: Freshwater Ecological Assessment

Annexure 6: Air Quality Impact Assessment

Annexure 7: Archaeological Impact Assessment

Annexure 8: Desktop Palaeontological Assessment

licence number: mp 30/5/1/2/2/10115mr july 2020

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