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Annex 2B
GCS Discard Dump EMPR
(2016)
GCS (Pty) Ltd. Reg No: 2004/000765/07 Est. 1987
Offices: Durban Johannesburg Lusaka Ostrava Pretoria Windhoek
Directors: AC Johnstone (Managing) PF Labuschagne AWC Marais S Pilane (HR) W Sherriff
(Financial)
Non-Executive Director: B Wilson-Jones
www.gcs-sa.biz
Kangra Coal (Proprietary) Limited
(Reg No. 2001/003104/07)
Unit 12b, 2nd Floor, 3 Melrose Boulevard, Melrose Arch
Melrose North 2196
Postnet Suite 379, Private Bag X1, Melrose Arch, 2076
P O Box 745, Piet Retief 2380
Telephone: +27 (0) 17 826 9700
Facsimile: +27 (0) 17 826 5284
Kangra Coal (Pty) Ltd.: Proposed Discard Dump at Maquasa East Mine
Environmental Impact Report and Environmental Management Programme
In terms of the Mineral and Petroleum Resources Development Act (Act No. 28 of 2002)
Report
Version – 1
26 January 2016
Kangra Coal (Pty) Ltd
GCS Project Number: 13-347
DMR Reference: MP 30/5/1/23/2/1/133 & 134 EM
Submitted on behalf of Kangra Coal (Pty) Ltd. by GCS Water & Environment (Pty) Ltd.
GCS Project Number: 13-347 4a Old Main Road, Judges Walk, Kloof, Kwazulu-Natal, 3610 PO Box
819, Gillitts, 3603 South Africa
Kangra Coal (Pty) Ltd Maquasa East Discard Dump
13-347 9 March 2016 Page ii
Kangra Coal (Pty) Ltd. Maquasa East Discard Dump Environmental Impact Report and Environmental Management Programme
In terms of the Mineral and Petroleum Resources Development Act (Act No. 28 of 2002)
Report Version – 1
26 January 2016
DOCUMENT ISSUE STATUS
Report Issue Final
GCS Reference Number 13-347
DMR Reference MP 30/5/1/23/2/1/133 MR
Title
Kangra Coal (Pty) Ltd Maquasa East Discard Dump: Final
Environmental Impact Report and Environmental Management
Programme
Name Signature Date
Author Renee Francis-Steele January 2016
Document Reviewer Renee Janse van Rensburg January 2016
Director Pieter Labuschagne January 2016
LEGAL NOTICE This report or any proportion thereof and any associated documentation remain the property of GCS until the mandator effects payment of all fees and disbursements due to GCS in terms of the GCS Conditions of Contract and Project Acceptance Form. Notwithstanding the aforesaid, any reproduction, duplication, copying, adaptation, editing, change, disclosure, publication, distribution, incorporation, modification, lending, transfer, sending, delivering, serving or broadcasting must be authorised in writing by GCS.
Kangra Coal (Pty) Ltd Maquasa East Discard Dump
13-347 9 March 2016 Page iii
EXECUTIVE SUMMARY
Background
Kangra Coal (Pty) Ltd (Kangra) owns various operational and defunct coal mines in the
vicinity of Piet Retief in the Mpumalanga Province. An application to combine the approved
Environmental Management Programme (EMPr) for these operations was approved by the
Department of Mineral Resources (DMR) in August 2014. These operations comprise the
Maquasa East (mining completed), Maquasa West (current), Rooikop (historical) and
Nooitgesien (current) mining areas, situated approximately 40km west of the town of Piet
Retief.
All coal from the operational mining areas is transported via conveyors and trucks to the
coal washing plant located at Maquasa East, from where the produced coal discard is
dumped onto the current Discard Dump, also located within the Maquasa East surface area.
Input from the proposed future mine expansion at the proposed Savmore Colliery:
Kusipongo will produce additional discard material in the future which cannot be
accommodated within the existing Discard Dump footprint. To make provision for the
additional discard, a new Discard Dump, to the west of the Maquasa East mining area, is
proposed.
Motivation for the project
In order to facilitate the proposed expansion of Kangra’s mining area and the subsequent
extension of the life of mine (LoM) of these operations, a new Discard Dump is required to
accommodate the additional discard material which will be produced. An expansion of the
LoM will also facilitate the retention of jobs in the long term.
The option for the expansion of the existing Discard Dump was rejected because it was not
considered feasible. The available area would not provide sufficient capacity for the
additional discard disposal required for the extended LoM for the proposed expansions.
Summary of Proposed Development
The proposed new Discard Dump will be situated on Portion 0 (RE) the farm Rooikop 18 HT,
with a portion of the dump overlapping onto Portion 0 (RE) of the farm Maquasa 19HT. The
dump has been designed to cover an area of approximately 65ha, to accommodate
approximately 20 million tonnes of discard, comprising a volume of approximately 11
million m³ over a period of 20 years.
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The proposed new Discard Dump will be equipped with an underdrainage system, liner and
catchment paddocks, Pollution Control Dam (PCD) (two compartments HDPE lined),
stormwater management infrastructure such as trenches and berms, internal haul roads and
fencing/access control.
The proposed dump will be developed in three compartments/phases. Each compartment
will be concurrently rehabilitated to reduce the infiltration of rainwater and to reduce the
amount contaminated runoff, thereby reducing the required capacity of the PCD. The
proposed PCD capacity is 100 000m³, which will be able to accommodate the 1:50 year
storm event, provided that concurrent rehabilitation is undertaken and that a minimum of
200m³/day of water is pumped out of the PCD.
Waste Classification
An assessment of Mineralogy and Total Chemical Composition of a sample of discard found
that the sample consists mostly of Gypsum and Quartz. The acid-base accounting (ABA) and
net acid generation (NAG) analyses revealed that the discard material has a significant
potential to generate acid mine drainage (AMD)/seepage.
Based on the comparison of the leachable concentrations (LC) and total concentrations (TC)
of the discard material to the threshold limits specified in Section 6 of the Norms and
Standards, the discard is classified as Type 3 Waste. This waste may only be disposed of at
a landfill with a Class C liner.
Environmental Authorisation Applications
The following environmental authorisations are being applied for:
• Mineral Resource Development Act, 2002 (Act No. 28 of 2002) (MPRDA): An
addendum to the approved EMPr is required for the proposed Discard Dump. This
application constitutes an amendment to the Consolidated EMPr (approved in
August 2014);
• National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA): The
development of the proposed Discard Dump triggers activities listed in terms of the
NEMA. An environmental authorisation is required, this includes a Scoping and
Environmental Impact Assessment (EIA) process; and
• National Water Act, 1998 (Act No. 36 of 1998) (NWA): The construction and
operation of the proposed Discard Dump and PCD require an Integrated Water Use
Licence (IWUL). Furthermore, an exemption from Regulation 4 (a) of Government
Notice 704, published in Government Gazette vol. 408, No. 20119 on 4 June 1999
(GN704) is required due to the proposed Discard Dump being located within 100m of
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13-347 9 March 2016 Page v
a surface water resource. These exemptions must be issued as a condition of the
IWUL.
• A Waste Management Licence (WML) is also required in terms of the National
Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) (NEMWA), as per
Government Notice Regulation 633 (GNR633), which was published in Government
Gazette No. 39020 on 25 July 2015. A full scoping and EIA process is also required,
which must be undertaken in terms of the NEMA Regulations. The WML application
does not form part of the scope of the current process being undertaken, therefore,
it is recommended that the DMR be consulted in order to determine the process to
be followed in respect of the NEMWA requirements.
Public Consultation
The Public Participation Process (PPP) has been undertaken for the three application
processes and complied with the NEMA regulations PPP, which is more comprehensive than
the MPRDA and NWA public consultation requirements. The PPP included the placement of
advertisements (English and Zulu) in the Excelsior News; the placement of site notices; the
distribution of Background Information Documents (BIDs); sms notifications; a Scoping Phase
and an EIA Phase public meeting; the public review of the draft and final Environmental
Scoping Reports (ESR); and the public review of the Draft Environmental Impact Report
(EIR)/Environmental Management Programme (EMPr). The main issues raised include:
• Environmental:
o The proposed dump lies within one of South Africa’s registered Important
Bird and Biodiversity Areas (IBAs) – IBA SA020 Grasslands (an Avifaunal
Assessment has subsequently been undertaken).
o What measures will be implemented to prevent impacts on air quality,
groundwater and surface water resources, including the Heyshope Dam.
o Are there downstream surface water users?
o The impacts of Kangra’s operations on the environment such as the
dewatering of wetlands (this is not part of the scope of the application as
was dealt with as part of the Consolidation and Amendment application).
o The project may have a secondary impact on farmer support programs run
by the Mpumalanga Department of Agriculture, Rural Development, Land
and Environmental Affairs (MDARDLEA) in the area, such as Masibuyele
Emasimini, Masibuyele Esibayeni, etc.
o The erosion identified at other parts of the mine site raises questions about
Kangra’s ability to manage stormwater within the remaining mining area
and the proposed site.
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o The soils study should focus on returning the land to its current land
capability and not its current land use.
o Liners sometimes fail and surface water may also be impacted on. Kangra
must commit to implementing the required mitigation and monitoring
measures.
o Spontaneous combustion of coal causes air pollution and may affect
livestock. Kangra must ensure that this is controlled.
• Community/Social/Socio-economic:
o How will the Iswepe and Driefontein communities benefit in terms of job
opportunities, assistance in small business development, opportunities for
local businesses and youth to subcontract and community projects.
o Security measures to protect community members, e.g. children who may
play in the area.
o What is Kangra’s budget for social investment for the community?
o A huge investment was made by the MDARDLEA in the
Donkerhoek/Driefontein area with regards to animal and crop farming as
well as infrastructure. The proposed development must be managed to
prevent impacts on these projects.
o The number of locals employed by the mine should increase where possible.
Whenever there are opportunities, the employment of local people must be
prioritised.
o When new areas are developed, fencing is often erected, access routes are
changed and security guards are deployed. Kangra must consult with the
community before making these changes and provide alternative access
routes as this affects the movement and everyday lives of the community.
o The studies and the paper exercise takes time, but the impact on the
farmers in the community is direct and immediate.
• Public Participation Process:
o The scheduling of the public meeting was inconvenient because it was in
the late afternoon when people had difficulty finding transport and it was
during the week (this was in contradiction with previous discussions with
the community where meetings on weekends were highlighted as
inconvenient. The Community Liaison Officer has been tasked with
scheduling a meeting with the community).
o An authority meeting and site visit was requested by the MDARDLEA official
(Natural Resource Investigation Unit) (this meeting is to be facilitated by
the applicant).
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o It would be helpful for authorities to attend public meetings to advise
community members in respect of the issues being discussed.
• Authorisation:
o Proof of rezoning in terms of the Spatial Planning and Land Use
Management, 2013 (Act No. 16 of 2013) (SPLUMA) was requested.
Environmental Baseline Conditions
Climate
The study area lies at an average altitude of approximately 1430 m. It is located in the
South African Highveld sub-humid climatic zone, which is a warm, mild summer rainfall
region. It is characterised by warm, wet summers and cool, dry winters.
The average annual rainfall for the area is in the order of 772 mm and the annual average
evaporation is 1 400 mm.
Geology
The proposed Discard Dump is located in the Ermelo Coalfield. The surface geology in the
study area is characterised by the development of a variable thickness of unconsolidated
overburden consisting of both transported and in-situ weathering material.
The Karoo Supergroup succession in the Ermelo Coalfield consists of the Dwyka Group
diamictites, which occur unconformably above a pre-Karoo basement which is overlain by
the coal bearing Vryheid Formation (Ecca Group); the basal Pietermaritzburg formation of
the Ecca Group not being present. The Vryheid Formation strata consist of five (5) coal
seams, namely A (at the base) – E Seams; of which all five (5) seams are hosted by the
Ermelo Coalfield coal seams.
Although no regional structural features are located within the proximity of and/or
traversing the study area, site-specific geophysical data indicates a number of inferred
structural features (interpreted as dolerite dykes) to traverse the study area.
Impacts and mitigation
No impacts on the geology are anticipated.
Topography
The proposed Discard Dump site is topographically flat with a slight slope in a westerly
direction (i.e. towards the Egude River) at 4.9%.
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Impacts and mitigation
It is anticipated that the construction activities, as well as the development of the
proposed Discard Dump over its life span will have an impact on the topography of the site.
Although the construction phase impacts can be mitigated through careful planning,
reducing the extent of the construction footprint, putting in erosion control measures and a
concerted rehabilitation effort, the Discard Dump will be a permanent structure that can
only be managed through careful shaping capping and vegetating of the dump.
Soils, Land Use and Land Capability
The study area comprises Pinedene (43.53ha), Clovelly (40.79ha), Glencoe (17.06ha) soil
forms, as well as Anthrosol (4.62ha) (soils largely affected by human activity).
The study area comprises land that is under rehabilitation (4.62ha) and Grassland (Themeda
triandra, also known as Redgrass) which is currently used for cattle grazing and has
scattered patches of bare soil.
Three land capability classes were identified within the study area, based on the soil types,
i.e. Intensive Agriculture (84.22ha), Moderate Agriculture (17.06ha) and Undefined Use
(4.62ha, land under rehabilitation).
Impacts and mitigation
The potential soil erosion, soil compaction and soil contamination due to the construction
activities, are rated as Low to Medium significance. The change in land use and land
capability (loss of agricultural potential) due to the development of the Discard Dump are
permanent impacts, and have received a High significance rating. In the event that
pollution from the footprint reaches the surrounding soils, this will result in soil
contamination and a change in the land capability. The proposed development will also
have a cumulative impact on the soil and land capability within the MRA by further altering
the pockets of undeveloped land. These impacts can be mitigated through proper planning,
the implementation of stormwater management and erosion control structures; training of
staff, etc.
There is also the potential for further erosion and compaction of areas surrounding the
dump during the operational phase, as well as the salinization and acidification of the soils
underlying and immediately surrounding the facility. These impacts can be mitigated
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through the construction of the liner system in accordance with the approved design, the
monitoring and management of rehabilitation areas and proper spill management.
Soil erosion and compaction are likely to occur during the decommissioning phase, however
these impacts will be short-term and with a focussed rehabilitation effort. The soil
conditions are expected to improve after decommissioning of the facility.
Terrestrial Ecology
The study area is covered entirely by the Eastern Highveld Grassland, which is an
‘Endangered’ vegetation type which warrants a medium-high environmental sensitivity
rating.
The study area comprises Degraded and Transformed Habitat (irreversible change in the
vegetation due to anthropogenic effects), and Grassland Habitat. The Degraded and
Transformed habitat is comprised of exotic tree stands (of no ecological importance);
excavations (low ecological status and sensitivity); and roads and Infrastructure (no natural
vegetation remaining). The faunal sensitivity of this habitat is low.
The Grassland Habitat has been ascribed a Medium/Low floristic sensitivity, i.e. the natural
habitat has been transformed, but a measure of the original vegetation remains albeit
dominated by secondary climax species. The faunal sensitivity of this habitat is medium.
None of the eight (8) Red Data Listed flora species or the 10 Red Data Listed faunal species
expected to occur within the relevant Quarter Degree Grid (QDS), were recorded in the
study area. However, the possibility that Red Data species might be present within the
study area cannot be excluded at this stage.
Impacts and mitigation
Construction activities may result in the loss of species of conservation importance, and the
fragmentation of habitat. Fauna may be affected through loss of habitat and displacement,
and potential harm from vehicles and workers. These impacts are of Low to Medium
significance and can be mitigated through maintaining as much land cover as possible,
demarcating the construction area, salvaging all plants of conservation importance, a
focussed rehabilitation effort and training and supervision of staff.
During operation, flora and fauna may potentially be impacted on through the spread of
impacts from the dump, as well as direct physical harm to fauna. The implementation of
recommended measures which aim to contain contamination, as well as an alien vegetation
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management plan will likely mitigate these impacts. Staff training and awareness is also
required to avoid unnecessary human-animal conflict.
The decommissioning activities are likely to cause disturbances, however this will be short
term and can be readily mitigated. Any land disturbed or exposed during decommissioning
must be rehabilitated, and monitoring of these areas must take place to avoid the
establishment of alien plants. With a carefully planned and implemented rehabilitation
program and proper control of alien plants, the overall conditions of footprint area is
expected to improve over time.
Avifauna
The proposed dump lies within one of South Africa’s registered Important Bird and
Biodiversity Areas (IBAs) – IBA SA020 Grasslands, which comprised 1 050 000ha, centred on
the towns of Volksrust and Wakkerstroom. This area was previously proposed, but has not
since been declared, a Biosphere Reserve.
The avifaunal sensitivity ratings (habitat availability, likelihood of encountering avifauna,
etc.) for the study area are Medium-Low for the Degraded Habitat and Medium-High for the
Natural Grassland, while the wetland outside of the study area is considered to have a high
sensitivity.
There are 30 Endemic and 7 Near Endemic resident species occupying the relevant QDS.
The residents have 20 listed species, these being 11 Near Threatened, and 9 Vulnerable,
however one species is listed as Critically Endangered in South Africa.
Impacts and mitigation
The loss of habitat has the potential to impact on breeding and feeding behaviour. This
impact cannot be avoided within the Discard Dump footprint, however management of
disturbed areas outside the footprint is required to reduce the effects of habitat
fragmentation and the loss of potential nesting and feeding sites.
Avifauna may potentially be impacted on through the spread of impacts and subsequent
deterioration of suitable habitat outside the footprint during operation. This must be
controlled through the implementation of a liner, stormwater management structures, dust
suppression and concurrent rehabilitation. An alien vegetation management plan will assist
in maintaining the integrity of the habitat outside of the footprint over the life of the
facility.
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Decommissioning activities may potentially disturb the avifaunal habitat surrounding the
dump. Furthermore, this habitat can be degraded in the long term should alien vegetation
establish within the disturbed areas. With a carefully planned and implemented
rehabilitation program and proper control of alien plants, the overall conditions within and
around the development footprint is expected to improve following decommissioning.
Wetlands and Aquatic Environment
A Channelled Valley Bottom Wetland unit was identified to the west of the proposed
Discard Dump site. The Wetland Index of Habitat Integrity (Wetland-IHI) assessment shows
that this wetland unit has been seriously modified. The Present Ecological Status (PES) of
the wetland is Category E (seriously modified) and the Ecological Importance and Sensitivity
(EIS) is Category D (the wetland unit is not important or sensitive and does not play a
significant role in the moderation of water quality and quantity). The wetland received a
low rating for indirect services (some form of erosion control is provided by the wetland)
and very low rating for direct services.
The Egude River is a perennial watercourse to the west of the proposed development which
is the receiving watercourse. The in-situ water quality (2014) indicated that the water
upstream and downstream of the study area is of good quality, with no evidence of mining
impacts at the time. The instream habitat upstream and downstream of the site is
described as Class C (adequate/fair, moderately modified). The aquatic invertebrate
assessment score (SASS5) upstream of the site was Class E/F (seriously impaired), and
downstream was Class B (very good). The improved/higher score downstream could suggest
that the site’s impacts are contained within the sampled areas or alternatively these
impacts are diluted or removed through wetland floodplain services.
Impacts and mitigation
The impacts on the wetland and aquatic ecology unit are ranked as medium significance.
During construction, the wetland soils may be contaminated, the wetland and stream
habitat may be degraded through siltation, potential increased toxicity, an increase in
electrical conductivity (EC) and total dissolved solids (TDS). The degradation may result in a
loss of wetland habitat and subsequent loss in faunal diversity. Mitigation measures include
stormwater management, energy dissipaters to reduce the velocity of stormwater, silt nets,
dust suppression measures and rehabilitation of disturbed areas.
During operation the wetland and stream may be further degraded by the potential spread
of impacts from the dump, i.e. through runoff containing contaminants or silt, dust from
the dump and increased velocity of runoff (leading to the scouring of the stream channel).
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The impacts can be minimised through the maintenance of stormwater management and
silt nets, the monitoring of rehabilitated areas and concurrent rehabilitation of the dump.
The decommissioning phase activities have the potential to create impacts similar in nature
to the construction phase impacts. Careful planning, rehabilitation and monitoring are
required to reduce these impacts. Furthermore, the control of alien plants is required to
prevent long term degradation of the wetland habitat.
Although the wetland ecosystem is already impacted, further contamination during the life
of the facility will also further degrade the wetland ecosystem. A rehabilitation program
must also be developed for the wetland.
Surface Water
The study area is located within the W51B quaternary catchment of the Usutu to Mhalatuze
Water Management Area (WMA). This quaternary catchment is the second catchment of the
Assegai River and the majority of runoff from the study area will eventually drain into this
river. Surface water flows in a north-easterly direction across the site, towards the Egude
River (more than 100m to the west of the proposed dump), which eventually flows into at a
point to the north-east of the study area.
Monitoring results for a point upstream of the proposed site indicates that the water quality
is generally good, falling within SANS 241:2006 drinking water standards.
The majority of surface water abstracted within the catchment is used for commercial
forestry and irrigated agriculture, with domestic use making up a significant portion of the
water abstracted. Water for mining and urban industrial uses makes up a small proportion
of the water use in the catchment.
Based on calculations, the proposed development is expected to cause a stream flow
reduction of not more than 0.7%.
Impacts and mitigation
The quality of the nearby Egude River may be impacted during construction due to runoff
containing silt and contaminants and dust from the cleared areas. The runoff
characteristics are expected to be impacted due to the reduction of runoff (due to dirty
water containment) and the increase of runoff velocity. The impacts are rated as medium
to high, but can be mitigated through the reduction of the footprint area, implementation
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of stormwater management structures, erosion control measures and the dissipation of the
energy of runoff.
During the operation, the surface water resource may be contaminated due to runoff from
the dump, overflow from the PCD or runoff from site where spillages have occurred. The
capturing of runoff from the “dirty catchment” will also reduce the volume of flow to the
stream. The maintenance of stormwater and erosion control structures, as well as timeous
intervention to contain and capture any potential pollution is required. Furthermore,
concurrent rehabilitation will reduce the amount of contaminated water created.
The decommissioning phase activities have the potential to create impacts similar in nature
to the construction phase impacts. Careful planning, rehabilitation and monitoring are
required to reduce this impacts.
Groundwater
Based on the aquifer characteristics (e.g. weathering depth, groundwater strike and static
water levels), the hydrogeological system within the study area can be categorised into two
aquifers: a shallow weathered rock/material aquifer and a deeper fractured rock aquifer,
hosted within the Vryheid Formation sediments.
Groundwater levels across the greater study area, range from artesian to ~64m below
ground level (mbgl), with an average water level of ~9.2mbgl. The regional groundwater
flow is from west to east, however, on a local scale the groundwater flow is likely to be
significantly more complex due to geological and structural controls (i.e. groundwater
barriers and/or discrete conduits to flow).
No hydrocensus boreholes were identified within the proposed footprint area. Furthermore,
the greater study area is characteristic of low groundwater usage, with the key source for
water supply to surrounding communities and farmers in the area being surface water. No
groundwater receptors were identified in proximity of the proposed development area.
The prevailing groundwater quality is dominantly of sodium-bicarbonate type, however,
groundwater sourced from monitoring borehole MONBH3 is characteristic of calcium-
sulphate rich water, which is typically associated with water influenced by weathering of
naturally occurring sulphide minerals and/or stagnant water. This deviation in water quality
can most probably be attributed to the mining activities located up-gradient of the study
area.
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Impacts and mitigation
During the construction phase of the development, the impact on groundwater is expected
to be of Low significance. This will be limited to potential groundwater contamination due
to uncontrolled spillages and the reduction of groundwater quantity due to the reduction of
recharge from the compaction of the base of the facility and installation of the liner.
During the operational phase, minimal impact on the groundwater system is expected, due
to proposed design and phasing of the facility (i.e. the liner and underdrainage system,
paddocks and concurrent rehabilitation). Seepage from the PCD is not considered likely as
this facility will also be lined. Recharge of the aquifers will be low due to the liner system
and ground compaction. Monitoring is important to detect potential damage of the liners.
Also, pumping and reuse or treatment of water from the PCD is required to avoid an
emergency release during high rainfall conditions, as this would cause contaminated
seepage to migrate from site (both vertically and laterally).
The reduction of recharge due to the use of liners below the Discard Dump and PCD in
conjunction with mining activities is likely to reduce the amount of groundwater within the
resource. The lack of groundwater users in the area and the fact that the removal of water
from the mining areas is likely to end once mining ends, makes this impact of Medium
significance.
Air Quality
The proposed Discard Dump site is located within the north-eastern portion of the Highveld
Priority Area (HPA) declared in 2007 in terms of the National Environmental Management:
Air Quality Act, 2004 (Act No. 39 of 2004) (NEMAQA)
According to the HPA Air Quality Management Plan (AQMP), most of the HPA experiences
relatively good air quality, but there are nine extensive areas (hotspots) where ambient air
quality standards for SO2, NO2, PM10 and Ozone (O3) are exceeded. The Pixley ka Seme Local
Municipality (PSLM) is highlighted as a hotspot.
The greater study area is characterised by high stability levels, which inhibits the ability of
inversion layers to develop, particularly in the early hours of winter mornings. This
phenomenon may result in increasing ground level pollution concentrations.
The sensitive receptors identified in the vicinity of the study area include the Heyshope
Dam, Driefontein community and surrounding farms.
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Impacts and mitigation
Air quality effects during the life of the facility will be limited to the creation of dust due
to surface being exposed to the action of wind, as well as the movement of vehicles on site
and haul roads. These impacts, which are considered to be of Medium significance, are not
significant in the context of the development site location, i.e. within a MRA, adjacent to
existing mine operations. However, the location of the footprint area within the HPA means
that special care should be taken to reduce the creation of dust and to monitor these
potential impacts. Proper rehabilitation of disturbed areas, the concurrent rehabilitation of
the dump and dust suppression spraying of the haul roads are required to mitigate these
impacts.
Noise
Mining and mining related activities are the sources of noise in the vicinity of the study
area. The prevailing noise level recorded at gravel road (to the south of the site and
adjacent to a conveyor) is around 66.7dBA during the daytime and 70.0dBA during the
night-time.
The Driefontein residential area and the residents are already exposed to a certain extent
of higher noise levels than expected in a residential area.
Impacts and mitigation
Although noise is likely to be created during the life of the facility, these are not likely to
be above the ambient noise levels of the nearby mining operations. Therefore, the impact
on sensitive receptors is considered low. The impact, however, can be mitigated through
following a daily work schedule and the regular servicing of all vehicles and equipment.
Visual
The proposed Discard Dump site is located within an existing MRA. The site comprises
grassland which is used for cattle grazing. Mining facilities and infrastructure are clearly
visible from the centre of the site, i.e. haul roads, a conveyor rehabilitated area, etc. The
site is not clearly visible by the nearby Driefontein community, or from any major routes or
residential roads.
The study area presents a disturbed sense of place due to the existing mining activities and
infrastructure, and the previous disturbances (area under rehabilitation).
Impacts and mitigation
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Although the removal of vegetation and undertaking the construction as well as the
increasing size of the dump are likely to result in a major change to the aesthetics of the
landscape, this impact is considered of low significance due to the fact that the footprint is
located within an existing MRA and is not visible from any local or regional roads, or the
nearby community. The concurrent rehabilitation, including the shaping of the dump, must
be undertaken with the aim of blending the dump in with the surrounding landscape as far
as possible.
Dust creation is likely to cause poor visibility conditions, however this impact would be
limited in spatial extent and duration. This impacts can be mitigated through the proper
rehabilitation of disturbed areas, the concurrent rehabilitation of the dump and dust
suppression spraying of the haul roads are required to mitigate these impacts.
Socio-economic Environment
The study area is located within the north-eastern corner of the Pixley ka Seme Local
Municipality (PSLM), which forms part of the Gert Sibande District Municipality (GSDM) of
the Mpumalanga Province.
The community which is closest to the project area, is the Driefontein community. The
community, which is located approximately 2km to the west of the proposed development
site, is a densely populated settlement consisting largely of Reconstruction and
Development Property (RDP) style housing, or low cost housing. Approximately 365 of
Kangra’s employees are from Driefontein.
Driefontein has many dwellings without clean running water and sanitation facilities; and a
number of roads are in poor condition which pose a risk to the safety of pedestrians and the
health of the larger community by dust creation.
Impacts and mitigation
The proposed Discard Dump poses very few impacts to the socio-economics of the
immediate area surrounding the region. Temporary labour will be created during the
construction phase, however a very limited number of jobs would be created for a short
period. The nuisance created by dust and noise are considered to be of Low significance,
due to the current ambient conditions created by the existing mining operation and the
distance of the site from the community. The potential nuisance impacts can be mitigated
through the implementation of the recommended environmental management measures.
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Although no additional socio-economic impacts are likely to be created by the operation of
the dump, the additional disposal capacity created will accommodate for the proposed
expansions, and will maintain employment for the current mine workers in the long term.
Heritage and Archaeology
Heritage resources, which are quite common in region, include historical remains
associated with farmstead complexes. These consists of houses, associated outbuildings,
cattle enclosures; formal graveyards, and abandoned graveyards left by farm workers who
moved from farms to urban areas. No sites of high significance (e.g. graveyards) were
identified within the areas surveyed.
Impacts and mitigation
Although no impacts on any sites of heritage or archaeological value are anticipated, it is
always a possibility that the assessments may have missed heritage resources in the areas
surveyed. Heritage sites may occur in tall grass or in Blue Gum lots and others may lie
below the surface of the earth and may only be exposed once development commences.
In the event that any heritage resource of significance is identified within the footprint, all
development activities must cease. The South African Heritage Resources Authority (SAHRA)
should be notified immediately, and an accredited archaeologist consulted to determine
appropriate mitigation measures for the discovered finds. This may include obtaining the
necessary authorisation (permits) from SAHRA to conduct the mitigation measures.
Main Issues and Recommendations
The main gaps identified area:
• Surface Water Quality: No baseline surface water data exists for any points
downstream of the proposed site. Downstream monitoring points must be included
in the monitoring programme to establish the baseline conditions of the affected
reach of the Egude River (pre-construction) and to measure potential impacts.
• Groundwater: It is recommended that a numerical model is constructed, during the
operational phase of the proposed Discard Dump. This model should be updated
using the groundwater monitoring data collected to assist in closure planning
objectives and management plans.
• Aquatic environment: There is currently no biomonitoring programme in place
within the vicinity of the proposed Discard Dump. It is recommended that a
programme is established prior to construction in order to establish the baseline
conditions of the affected watercourse.
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• Wetlands: A Wetland Rehabilitation Plan would be required as part of the IWULA
process, as per the DWS requirements. It is recommended that such a plan is
compiled for sign-off by the DWS.
• Authorisations:
o A Waste Management Licence (WML) is required in terms of the National
Environmental Management: Waste Act, 2008 (Act No. 59 of 2008)
(NEM:WA) before the development of the Discard Dump may commence. A
Scoping and EIA process is required, which must be undertaken in
accordance with the NEMA EIA Regulations (2014 Regulations) in order to
apply for this authorisation from the regional DMR.
It is recommended that the DMR is consulted with regarding the NEM:WA
application, taking cognisance of the current EIA process in terms of the
NEMA Regulations.
o The properties on which the proposed Discard Dump will be located may
require rezoning. It is recommended that Kangra liaise with the local
municipality prior to construction to determine whether rezoning would be
required.
EAP recommendation
No fatal flaws have been identified during the EIA process. There is however, the potential
for impacts on the environment, particularly of a cumulative nature, due to the proximity
of the development site to the existing mining activities. The proposed Discard Dump is
necessary to accommodate for the proposed expansion and continuation of Kangra’s mining
activities, which will preserve jobs over the long term and benefit the economy of the
region and the country. It is recommended that the development is authorised, provided
that the mitigation and management measures recommended in this report and in the IWUL
(should this granted) are enforced and monitored. Furthermore, the WML required must
also be applied for and obtained prior to the development proceeding.
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LIST OF ACRONYMS
BID Background Information Document
EMP Environmental Management Plan
EMPr Environmental Management Programme
ESR Environmental Scoping Report
DMR Department of Mineral and Resources
DWA Department of Water Affairs (changed to DWS)
DWS Department of Water and Sanitation (formerly DWA)
DEA Department of Environmental Affairs
EAP Environmental Assessment Practitioner
EC Electrical Conductivity
EIA Environmental Impact Assessment
EIS Ecological Importance and Sensitivity
ELWU Existing Lawful Water Use
GA General Authorisation
GSDM Gert Sibande District Municipality
GNR Government Notice Regulation
I&AP Interested and Affected Parties
IBA Important Bird and Biodiversity Areas
IHAS Invertebrate Habitat Assessment System
IUCN International Union for the Conservation of Nature
IWULA Integrated Water Use License Application
IWUL Integrated Water Use License
IWWMP Integrated Waste Water Management Plan
LOM Life of Mine
MAE Mean Annual Evaporation
mamsl Metres above mean sea level
MAR Mean Annual Runoff
mbgl Metres below ground level
MDARDLEA Mpumalanga Department of Rural Development, Land and Environmental Affairs
MPRDA Minerals and Petroleum Resource Development Act, 2002 (Act No. 28 of 2002)
MRA Mining Right Area
Mtpa Million tons per annum
NEM:WA National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008)
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NEMA National Environmental Management Act, 1998 (Act No. 107 of 1998)
NWA National Water Act, 1998 (Act No. 36 of 1998)
PES Present Ecological Status
PPP Public Participation Process
PCD Pollution Control Dam
PES Present Ecological Status
PSLM Pixley ka Seme Local Municipality
ROD Record of Decision
RoM Run of Mine
SANS South African National Standards
SASS South African Scoring System
SAWS South African Weather Service
SAWQG South African Water Quality Guidelines
SWMP Storm Water Management Plan
TDS Total Dissolved Solids
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CONTENTS PAGE
1 INTRODUCTION .......................................................................................................................... 1
1.1 BACKGROUND AND HISTORY ............................................................................................................ 1 1.2 DESCRIPTION OF LAND .................................................................................................................... 4 1.3 NEED AND DESIRABILITY OF THE PROJECT ........................................................................................... 4 1.4 THE APPLICANT ............................................................................................................................. 6 1.5 ENVIRONMENTAL ASSESSMENT PRACTITIONER .................................................................................... 6 1.6 LEGISLATIVE CONTEXT .................................................................................................................... 7
1.6.1 Constitution of South Africa .............................................................................................. 7 1.6.2 Mineral and Petroleum Resources Development Act ....................................................... 7 1.6.3 National Environmental Management Act ....................................................................... 8 1.6.4 National Water Act ......................................................................................................... 10 1.6.5 GN704 ............................................................................................................................. 11 1.6.6 National Environmental Management: Air Quality Act .................................................. 11 1.6.7 National Environmental Management: Waste Act ......................................................... 12 1.6.8 Spatial Planning and Land Use Management Act........................................................... 14 1.6.9 Other Legislation ............................................................................................................. 15
1.7 ENVIRONMENTAL PROCESS ............................................................................................................ 15 1.7.1 Application phase ........................................................................................................... 16 1.7.2 Scoping and PPP initiation .............................................................................................. 17 1.7.3 EIA Phase and Public Feedback ....................................................................................... 17
1.8 REPORT STRUCTURE ..................................................................................................................... 18
2 PROJECT DESCRIPTION ............................................................................................................. 20
2.1 PROJECT BACKGROUND (CURRENT AND FUTURE MINING) ..................................................................... 20 2.1.1 Maquasa East (underground and opencast) and West (underground) .......................... 20 2.1.2 Nooitgesien Mining Area ................................................................................................ 21 2.1.3 Rooikop ........................................................................................................................... 21 2.1.4 Kusipongo ....................................................................................................................... 21 2.1.5 Projected coal tonnages ................................................................................................. 21
2.2 DESCRIPTION THE DISCARD MATERIAL ............................................................................................. 22 2.2.1 Hydrogeochemical Characterisation of the Discard ....................................................... 22 2.2.2 Waste Classification ........................................................................................................ 24
2.3 DESCRIPTION THE PROPOSED DEVELOPMENT ..................................................................................... 25 2.3.1 General Layout ................................................................................................................ 25 2.3.2 Dimensions and life of the facility ................................................................................... 27 2.3.3 Construction/Disposal Method ....................................................................................... 27 2.3.4 Groundwater/Seepage management ............................................................................. 29 2.3.5 Surface Water/Stormwater Management ...................................................................... 31 2.3.6 Safety Classification ........................................................................................................ 37 2.3.7 Access Control ................................................................................................................. 38
2.4 DISCARD DUMP REHABILITATION .................................................................................................... 38
3 PROJECT ALTERNATIVES ........................................................................................................... 40
3.1 ACTIVITY/PROJECT ....................................................................................................................... 40 3.1.1 Expansion of existing Maquasa East Discard Dump ....................................................... 40 3.1.2 Development of a New Discard Dump (Preferred Option) .............................................. 40
3.2 ALTERNATIVE LOCATIONS FOR NEW DISCARD DUMP .......................................................................... 42 3.3 DISPOSAL ALTERNATIVES ............................................................................................................... 46
3.3.1 Integrated Discard “Dry” (Preferred Alternative) ........................................................... 46 3.3.2 Co-disposal “Wet and Dry” ............................................................................................. 46 3.3.3 Integrated Discard “Wet” ............................................................................................... 46 3.3.4 Separate Disposal ”Wet – Site 1 and Dry Site 2” ............................................................ 46
3.4 LAND USE ALTERNATIVES .............................................................................................................. 47
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3.4.1 Tourism ........................................................................................................................... 47 3.4.2 Residential ...................................................................................................................... 47 3.4.3 Grazing of Cultivated Land.............................................................................................. 47 3.4.4 Mining ............................................................................................................................. 47
3.5 NO GO ALTERNATIVE ................................................................................................................... 48
4 ENVIRONMENTAL BASELINE DESCRIPTION ............................................................................... 49
4.1 CLIMATE .................................................................................................................................... 49 4.1.1 Temperature ................................................................................................................... 49 4.1.2 Wind................................................................................................................................ 49 4.1.3 Rainfall ............................................................................................................................ 49 4.1.4 Evaporation..................................................................................................................... 50
4.2 GEOLOGY ................................................................................................................................... 51 4.2.1 Regional Geology ............................................................................................................ 51 4.2.2 Local Geology .................................................................................................................. 52 4.2.3 Structural Geology .......................................................................................................... 54
4.3 TOPOGRAPHY ............................................................................................................................. 54 4.4 SOILS, LAND USE AND LAND CAPABILITY .......................................................................................... 56
4.4.1 Soil forms ........................................................................................................................ 56 4.4.2 Current Land Use ............................................................................................................ 59 4.4.3 Land Capability ............................................................................................................... 61
4.5 TERRESTRIAL ECOLOGY (FLORA AND FAUNA) ..................................................................................... 64 4.5.1 Vegetation Unit ............................................................................................................... 64 4.5.2 Declared Conservation Areas .......................................................................................... 67 4.5.3 Flora ................................................................................................................................ 67 4.5.4 Fauna .............................................................................................................................. 73 4.5.5 Avifauna .......................................................................................................................... 75
4.6 AQUATIC ECOLOGY ...................................................................................................................... 80 4.6.1 Sampling Sites ................................................................................................................. 80 4.6.2 Affected River Reaches ................................................................................................... 83 4.6.3 In-situ Water Quality ...................................................................................................... 84 4.6.4 Invertebrate Habitat Assessment ................................................................................... 85 4.6.5 Aquatic Invertebrate Assessment ................................................................................... 86
4.7 WETLANDS ................................................................................................................................. 89 4.7.1 Wetland Delineation ....................................................................................................... 91 4.7.2 Wetland Classification .................................................................................................... 93 4.7.3 Wetland Index of Habitat Integrity ................................................................................. 93 4.7.4 Wetland PES and EIS ....................................................................................................... 93 4.7.5 Wetland Eco-services ...................................................................................................... 94
4.8 SURFACE WATER ......................................................................................................................... 94 4.8.1 Catchment and Hydrology Description ........................................................................... 95 4.8.2 Mean Annual Runoff ....................................................................................................... 97 4.8.3 Flood Flows and Volumes ............................................................................................... 97 4.8.4 Floodlines ........................................................................................................................ 98 4.8.5 Surface Water Quality .................................................................................................... 98 4.8.6 Water Users within the Catchment ............................................................................... 100
4.9 GROUNDWATER ........................................................................................................................ 100 4.9.1 Aquifer description ........................................................................................................ 100 4.9.2 Drilling program ............................................................................................................ 102 4.9.3 Groundwater Strikes and Air-lift yield ........................................................................... 104 4.9.4 Groundwater Level and Direction ................................................................................. 104 4.9.5 Hydrocensus .................................................................................................................. 104 4.9.6 Natural Springs ............................................................................................................. 107 4.9.7 Groundwater Quality .................................................................................................... 107 4.9.8 Source-Pathway-Receptor Description ......................................................................... 112
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4.10 HERITAGE AND ARCHAEOLOGY ..................................................................................................... 113 4.10.1 Summary of findings ..................................................................................................... 115
4.11 NOISE...................................................................................................................................... 115 4.12 AIR QUALITY ............................................................................................................................. 116
4.12.1 Regional Air Quality ...................................................................................................... 116 4.12.2 Local Air Quality ............................................................................................................ 116
4.13 SOCIO-ECONOMIC ENVIRONMENT ................................................................................................. 117 4.13.1 Demographic Profile ..................................................................................................... 118 4.13.2 Economic Profile ........................................................................................................... 118 4.13.3 Neighbouring community ............................................................................................. 119
5 PUBLIC PARTICIPATION .......................................................................................................... 120
5.1 IDENTIFICATION OF INTERESTED AND AFFECTED PARTIES (I&APS) ....................................................... 120 5.2 NOTIFICATION OF I&APS ............................................................................................................ 121
5.2.1 Background Information Document ............................................................................. 121 5.2.2 Site Notices ................................................................................................................... 121 5.2.3 Newspaper Advertisement ........................................................................................... 122 5.2.4 Sms notification ............................................................................................................ 122
5.3 CONSULTATION WITH THE AUTHORITIES ......................................................................................... 122 5.4 CONSULTATION WITH I&APS ....................................................................................................... 123
5.4.1 Public review of documents .......................................................................................... 123 5.4.2 Scoping Phase Public Meeting & Distribution of Minutes ............................................. 123 5.4.3 Public Feedback (EIA Phase) Meeting ........................................................................... 124
5.5 STAKEHOLDER DATABASE ............................................................................................................ 124 5.6 COMMENTS AND RESPONSE SUMMARY ......................................................................................... 124
6 REHABILITATION PLAN ........................................................................................................... 152
6.1 AIM OF THE REHABILITATION PLAN ............................................................................................... 152 6.2 CLOSURE OBJECTIVES ................................................................................................................. 152 6.3 POST-CONSTRUCTION REHABILITATION .......................................................................................... 153 6.4 POST-DECOMMISSIONING REHABILITATION ..................................................................................... 153
6.4.1 Phase 1 .......................................................................................................................... 153 6.4.2 Phase 2 .......................................................................................................................... 153
7 ASSESSMENT OF ENVIRONMENTAL IMPACTS ......................................................................... 157
7.1 ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGY ................................................................... 157 7.2 CONSTRUCTION PHASE IMPACTS ................................................................................................... 159
7.2.1 Construction Phase Activities ........................................................................................ 159 7.2.2 Description of potential impacts ................................................................................... 160 7.2.3 Assessment of Potential Impacts .................................................................................. 164
7.3 OPERATIONAL PHASE IMPACTS ..................................................................................................... 174 7.3.1 Operational Phase Activities ......................................................................................... 174 7.3.2 Description of potential impacts ................................................................................... 174 7.3.3 Assessment of Operational Phase Impacts ................................................................... 178
7.4 DECOMMISSIONING AND CLOSURE PHASE IMPACTS ......................................................................... 185 7.4.1 Decommissioning and Closure Phase Activities ............................................................ 185 7.4.2 Description of impacts .................................................................................................. 185 7.4.3 Assessment of Decommissioning Phase Impacts .......................................................... 188
7.5 CUMULATIVE IMPACT ASSESSMENT ............................................................................................... 197 7.5.1 Description of Impacts .................................................................................................. 197 7.5.2 Assessment of Impacts ................................................................................................. 199
8 ENVIRONMENTAL MANAGEMENT PROGRAMME ................................................................... 205
8.1 RESPONSIBILITIES ....................................................................................................................... 205 8.1.1 Project Manager ........................................................................................................... 205 8.1.2 Environmental Control Officer ...................................................................................... 205
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8.1.3 Contractor ..................................................................................................................... 206 8.1.4 Environmental Manager/Officer................................................................................... 206 8.1.5 Consulting/Project Engineer ......................................................................................... 206 8.1.6 Plant Engineer ............................................................................................................... 206
8.2 ENVIRONMENTAL MANAGEMENT: CONSTRUCTION PHASE ................................................................. 207 8.2.1 Action Plan .................................................................................................................... 207 8.2.2 Reporting and General Requirements........................................................................... 217 8.2.3 Soil Management Plan .................................................................................................. 218
8.3 ENVIRONMENTAL MANAGEMENT: OPERATIONAL PHASE ................................................................... 219 8.3.1 Action Plan .................................................................................................................... 219 8.3.2 Reporting and General Requirements........................................................................... 227
8.4 ENVIRONMENTAL MANAGEMENT ACTION PLAN: DECOMMISSIONING AND CLOSURE PHASE .................... 228 8.4.1 Action Plan .................................................................................................................... 228 8.4.2 Reporting and General Requirements........................................................................... 240
9 MONITORING AND AUDITING ................................................................................................ 242
9.1 SURFACE WATER MONITORING .................................................................................................... 242 9.2 GROUNDWATER MONITORING ..................................................................................................... 245 9.3 AQUATIC BIOMONITORING .......................................................................................................... 248 9.4 AIR QUALITY MONITORING ......................................................................................................... 251 9.5 REHABILITATION PROGRESS .......................................................................................................... 251 9.6 REPORTING .............................................................................................................................. 251 9.7 ENVIRONMENTAL PERFORMANCE AUDITS....................................................................................... 252
10 ENVIRONMENTAL AWARENESS AND EMERGENCY RESPONSE PLAN....................................... 253
11 FINANCIAL PROVISION ........................................................................................................... 254
12 INFORMATION GAPS AND RECOMMENDATIONS ................................................................... 256
12.1 SURFACE WATER ....................................................................................................................... 256 12.1.1 Water Quality ............................................................................................................... 256 12.1.2 Floodlines ...................................................................................................................... 256
12.2 GROUNDWATER ........................................................................................................................ 257 12.3 AVIFAUNA ................................................................................................................................ 257 12.4 AQUATIC ENVIRONMENT ............................................................................................................. 257 12.5 WETLANDS ............................................................................................................................... 257 12.6 FURTHER AUTHORISATIONS REQUIRED........................................................................................... 258
12.6.1 Waste Management Licence ........................................................................................ 258 12.6.2 Rezoning ....................................................................................................................... 258
13 CONCLUSION AND IMPACT STATEMENT ................................................................................ 259
14 REFERENCES ........................................................................................................................... 265
LIST OF FIGURES
Figure 1.1 Locality of Kangra Mining Operations near Piet Retief ..................................................... 3 Figure 1.2 Property Details ................................................................................................................ 5 Figure 1.3 Environmental Process Flow Diagram ............................................................................ 16 Figure 2.1 Discard Dump Layout (Geotail, 2014) ............................................................................. 26 Figure 2.2 Proposed Liner for the Discard Dump (Source: Geotail, 2014)....................................... 30 Figure 2.3 Proposed Liner for the PCD (Source: Geotail, 2014) ....................................................... 31 Figure 2.4 Proposed Liner for the PCD (Source: Geotail, 2014) ....................................................... 33 Figure 2.5 Discard Dump Process Flow Diagram ............................................................................. 34 Figure 2.6 Discard Dump Water Balance ......................................................................................... 35 Figure 2.7 Proposed Cover for the PCD (Source: Geotail, 2014) ..................................................... 39
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Figure 3.1 Existing Discard Dump .................................................................................................... 41 Figure 3.2 Potential Discard Dump Locations .................................................................................. 44 Figure 4.1 Geological Map of the Study Area .................................................................................. 53 Figure 4.2 Topographical Map of the Study Area ............................................................................ 55 Figure 4.3 Soil forms within the Study Area .................................................................................... 57 Figure 4.4 Current Land Use of the Study Area ............................................................................... 60 Figure 4.5 Land Capability of the Study Area................................................................................... 63 Figure 4.6 Vegetation Units within the Study Area ......................................................................... 66 Figure 4.7 Macro-habitats within the Study Area ........................................................................... 70 Figure 4.8 Aquatic Sampling Points ................................................................................................. 82 Figure 4.9 NFEPA Wetlands around the study area......................................................................... 90 Figure 4.10 NFEPA Wetlands around the study area ..................................................................... 92 Figure 4.11 Channelled valley Bottom Wetland ............................................................................ 93 Figure 4.12 Discard Dump: Watercourse 100m Buffer Map ......................................................... 96 Figure 4.13 Location of groundwater monitoring boreholes ...................................................... 103 Figure 4.14 Location of hydrocensus boreholes .......................................................................... 106 Figure 4.15 Location of the Power Station project area (GCS, 2008) .......................................... 114 Figure 6.1 Phase 1 of Rehabilitation .............................................................................................. 155 Figure 6.2 Phase 2 of Rehabilitation .............................................................................................. 156 Figure 9.1 Proposed Surface Water Monitoring Points ................................................................. 244 Figure 9.2 Proposed Groundwater Monitoring Locations ............................................................. 247 Figure 9.3 Proposed Biomonitoring Sites ...................................................................................... 250
LIST OF TABLES
Table 1.1 Property Details ................................................................................................................ 4 Table 1.2 Applicant’s Details ............................................................................................................ 6 Table 1.3 EAP’s Details ..................................................................................................................... 6 Table 1.4 NEMA Listed Activities triggered by the proposed Discard Dump ................................... 9 Table 1.5 Summary of Environmental Authorisations Required .................................................... 15 Table 2.1 Dimensions and Capacity of the proposed Discard Dump ............................................. 27 Table 2.2 Stormwater Channel Dimensions ................................................................................... 31 Table 2.3 PCD Design Specifications ............................................................................................... 37 Table 2.4 Discard Dump Safety Classification................................................................................. 38 Table 3.1 Fatal Flaw Assessment of Potential Sites (Hatch 2011) .................................................. 42 Table 3.2 Assessment of Alternative Sites...................................................................................... 45 Table 4.1 Summary of rainfall data (Ilanda, June 2014) ................................................................. 50 Table 4.2 Summary of monthly evaporation data (Ilanda, June 2014) .......................................... 51 Table 4.3 Land Capability Classes- Description and Suitability ....................................................... 61 Table 4.4 Plant families recorded (March 2014 survey) ................................................................. 68 Table 4.5 Estimate of Floristic Sensitivity of the Study Area .......................................................... 71 Table 4.6 Red Data Flora Species known to occur in QDS2730AB ................................................. 72 Table 4.7 Estimate of Faunal Habitat Sensitivity of the Study Area ............................................... 74 Table 4.8 Red Data Fauna Species known to occur in QDS2730AB ................................................ 74 Table 4.9 Animal Species recorded in the Study Area .................................................................... 75 Table 4.10 Avifaunal Habitat Sensitivity of the study area............................................................... 78 Table 4.11 Aquatic Sampling Sites .................................................................................................... 81 Table 4.12 In situ water quality at the Aquatic Sampling sites (4-6 March 2015) ............................ 84 Table 4.13 IHAS results for the Aquatic Sampling sites (4-6 March 2015) ....................................... 85 Table 4.14 Ecological Classes Assigned to the SASS5 and ASPT Scores ............................................ 87 Table 4.15 SASS results for the Aquatic Sampling sites (4-6 March 2015) ....................................... 87 Table 4.16 Wetland IHI Assessment Results .................................................................................... 93
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Table 4.17 PES of the Wetland Unit ................................................................................................. 94 Table 4.18 EIS of the Wetland Unit .................................................................................................. 94 Table 4.19 Wetland Ecosystem Services .......................................................................................... 94 Table 4.20 Summary of flood peak calculations ............................................................................... 98 Table 4.21 Surface water chemistry (July & September 2014) ........................................................ 99 Table 4.22 Surface water users within the quaternary catchment ................................................ 100 Table 4.23 Hydro-chemical Parameter Summary .......................................................................... 109 Table 4.24 Sensitive Air Quality Receptors (GCS, 2008) ................................................................. 117 Table 5.1 Venues for public review of reports ............................................................................. 123 Table 5.2 Issues and Response Summary ..................................................................................... 125 Table 7.1 Impact Significance Ratings .......................................................................................... 158 Table 7.2 Impacts & Mitigation Measures: Construction Phase .................................................. 165 Table 7.3 Impacts & Mitigation Measures: Operational Phase .................................................... 179 Table 7.4 Impacts & Mitigation Measures: Decommissioning Phase .......................................... 189 Table 7.5 Impacts & Mitigation Measures: Cumulative Impacts.................................................. 200 Table 8.1: Environmental Management Action Plan: Construction Phase ........................................... 208 Table 8.2: Recommended Soil Stripping Depths .................................................................................. 218 Table 8.3: Soil Stockpile Volumes ......................................................................................................... 219 Table 8.4: Environmental Management Action Plan: Operational Phase ............................................ 221 Table 8.5: Environmental Management Action Plan: Decommissioning and Closure Phase ............... 229 Table 9.1: Proposed Surface Water Monitoring Sites .......................................................................... 242 Table 9.2: Water Quality Parameters for Sample Analysis ................................................................... 243 Table 9.3: Proposed Groundwater Monitoring Points ......................................................................... 245 Table 9.4 Proposed Aquatic Biomonitoring Sites ......................................................................... 248 Table 11.1 Closure Cost Summary .................................................................................................. 254
LIST OF APPENDICES
APPENDIX A: A3 FIGURES ............................................................................................................... 266
APPENDIX B: PROOF OF PUBLIC PARTICIPATION ............................................................................ 266
APPENDIX C: SPECIALIST STUDY REPORTS ...................................................................................... 266
APPENDIX C-1: SOILS, LAND USE AND LAND CAPABILITY REPORT .................................................. 266
APPENDIX C-2: HYDROLOGICAL STUDY REPORT ............................................................................. 266
APPENDIX C-3: WETLAND AND AQUATIC ASSESSMENT REPORT .................................................... 266
APPENDIX C-4: ECOLOGICAL ASSESSMENT REPORT ....................................................................... 266
APPENDIX C-5: AVIFAUNAL ASSESSMENT REPORT ......................................................................... 266
APPENDIX C-6: HYDROGEOLOGICAL INVESTIGATION REPORT ........................................................ 266
APPENDIX C-7: GEOTECHNICAL ASSESSMENT REPORT ................................................................... 266
APPENDIX C-8: WATER MONITORING REPORTS ............................................................................. 266
APPENDIX D: DISCARD DUMP SITE SELECTION REPORT ................................................................. 266
APPENDIX E: DESIGN REPORT ........................................................................................................ 266
APPENDIX F: ENVIRONMENTAL AWARENESS AND EMERGENCY RESPONSE PLAN ......................... 266
APPENDIX G: FINANCIAL PROVISION.............................................................................................. 266
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1 INTRODUCTION
This Final Environmental Impact Report (EIR)/Environmental Management Programme
(EMPr) has been compiled in accordance with the Regulations published in terms of the
National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA). The
applicable regulations are discussed under Chapter 2 of this report.
1.1 Background and History
Kangra Coal (Pty) Ltd (Kangra) owns various operational and defunct coal mines in the
vicinity of Piet Retief in the Mpumalanga Province. Kangra holds approved Environmental
Management Programmes (EMPr) for their Maquasa East (mining has ceased), Maquasa West
(current), Rooikop (historical) and Nooitgesien (current) mining areas, situated
approximately 40km west of the town of Piet Retief (refer to Figure 1.1). The EMPrs for
each coal mine were combined into one EMPr during the application process undertaken by
GCS (Pty) Ltd (GCS) in terms of Section 102 of the MPRDA during 2013 (approval received
during August 2014).
Mining at Rooikop and Maquasa East has ceased. Mining currently takes place at Maquasa
West (farm Maquasa 19HT Portion 0 (Remaining Extent) (RE) and farm Rooikop 18HT Portion
0 (Remaining Extent) (RE)) (mining is close to completion), via underground. Opencast
mining is undertaken at Nooitgesien (Nooitgesien 381 IT, a Portion Mineral Area 1 of farm
Maquasa 19 HT and a Portion of Mineral Area 1 of Remainder (RE) of farm Rooikop 18KT).
All coal from the active mining areas is transported (via conveyors and trucks) to the coal
washing plant situated at the Maquasa East mining area.
Kangra intends to expand their operations in the area, pending the outcomes of the various
environmental application processes undertaken. The expansion includes the Kangra Group
(Pty) Ltd (Kangra Group) Savmore Colliery: Kusipongo (underground mining), which will
provide additional feed to the washing plant. The proposed Kusipongo adit (-27.016267°S,
30.285800°E) will be located approximately 10km to the west of the Maquasa East mining
area, with a conveyor planned between the adit and the Maquasa East coal washing plant.
The proposed expansion will increase the life of the current operations and will require a
larger capacity of coal discard area than current existing Discard Dump located within
Maquasa East mining area. As a result a new discard dump is required. Kangra proposes to
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construct this discard to the west of the Maquasa East mining area, within an area
previously earmarked for the Kangra Power Station.
The proposed 65 hectare (Ha) Discard Dump will be designed to accommodate
approximately 20 million tonnes of discard, comprising a volume of approximately 11
million m³ over a period of 15 years. The Maquasa East discard dump will be situated on
Portion 0 (RE) of the farm Rooikop 18 HT, with a portion of the dump overlapping onto
Portion 0 (RE) of the farm Maquasa 19HT.
The Discard Dump complex will include the Discard Dump, Pollution Control Dam (PCD)
stormwater management infrastructure such as trenches and berms.
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Figure 1.1 Locality of Kangra Mining Operations near Piet Retief
[REFER TO A3 FIGURE UNDER APPENDIX A]
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1.2 Description of Land
The proposed Discard Dump will be located on Portion RE of the farm Rooikop 18 HT and
Portion RE of the farm Maquasa 19 HT, which is located immediately adjacent (west of) the
Maquasa East rehabilitated open cast pits, and to the east of the Maquasa West operation
(refer to Figure 1.1). This area forms part of the Maquasa East mining right area (MRA). The
proposed Discard Dump area is situated 40km west of the centre of the town of Piet Retief,
approximately 2km north-east of the Heyshope Dam and approximately 2km east of the
Driefontein Community in the Mpumalanga Province.
Furthermore, the Discard Dump is located within the jurisdiction of the Pixley ka Seme
Local Municipality (PSLM), which forms part of the Gert Sibande District Municipality
(GSDM). Part of the Maquasa East Mine, within which the Discard Dump site is located,
forms part of the Mkhondo Local Municipality, which also falls within the GSDM.
The property details are provided in Table 1.1 and the property portions are shown in
Figure 1.2.
Table 1.1 Property Details
PROPERTY DESCRIPTION EXTENT (HA) TITLE DEED NUMBER OWNER ON TITLE DEED
Rooikop 18HT, Portion 0 (Remaining Extent)
1278.2241 T78816/2004 Kangra Coal (Pty) Ltd
Maquasa 19 HT, Portion 0 (Remaining Extent)
1712.3421 T145840/2004 Kangra Coal (Pty) Ltd
The boundary of the proposed Discard Dump complex is shown in Figure 1.2. More detailed
information regarding the layout of the Discard Dump is provided in Chapter 3.
1.3 Need and Desirability of the project
Ms Susan Shabangu, the former Minister of Mineral Resources of South Africa, in an address
at the South African Coal Export Conference 2012, stated the vital and strategic role played
by coal in South Africa’s economy.
In order to facilitate the proposed expansions of Kangra’s mining areas and the subsequent
extension of the life of mine (LoM) of these operations, a new Discard Dump is required to
accommodate the additional discard that will be produced. An expansion of the LoM will
also facilitate the retention of jobs in the long term.
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Figure 1.2 Property Details
[REFER TO A3 FIGURE UNDER APPENDIX A]
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1.4 The Applicant
The applicant is Kangra Coal (Pty) Ltd. (Kangra). The relevant contact details for the
applicant are provided in Table 1.2.
Table 1.2 Applicant’s Details
NAME OF APPLICANT Kangra Coal (Pty) Ltd
CONTACT PERSON(S) Millicent Mkhwanazi
CONTACT NUMBER +27 17 730 6309
FAX +27 17 826 5284
POSTAL ADDRESS Savmore Colliery – Maquasa East
P.O. Box 745
Piet Retief
2380
EMAIL Millicent.Mkhwanazi@kangracoal.co.za
1.5 Environmental Assessment Practitioner
GCS has been appointed by Kangra to undertake the environmental authorisation
application processes in terms of the MPRDA, NEMA and National Water Act, 1998 (Act No.
36 of 1998) (NWA). The relevant details of the GCS Environmental Assessment Practitioner
(EAP) are presented in Table 1.3.
Table 1.3 EAP’s Details
NAME OF EAP Renee Francis-Steele
YEARS OF PROFESSIONAL EXPERIENCE
8 years
PROFESSIONAL REGISTRATION Cert. Sci. Nat. (Registration No. 200224/13)
CONTACT NUMBER (031) 764 7130
FAX (031) 764 7140
POSTAL ADDRESS PO Box 819, Gillitts, 3603
EMAIL renee@gcs-sa.biz
GCS is an independent environmental consulting firm and declares itself an independent
EAP, which has no vested interest in the outcomes of the applications.
Furthermore objectivity will not, under any circumstances, be compromised in the carrying
out of the environmental authorisation application processes. All the relevant specialist
investigations, project material, reports as well as the issues and response report resulting
from the public consultation process will be submitted to the competent authorities to
allow for informed decisions to be made.
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1.6 Legislative Context
The environmental legislation applicable to the Discard Dump project is discussed in this
chapter.
1.6.1 Constitution of South Africa
The Constitution of South Africa, 1996 (Act No. 108 of 1996) reigns supreme and the
advancement of human rights is one of the foundations of South Africa’s democracy.
Section 24(a) proclaims the right of everyone “to an environment that is not harmful to
their health or well-being”.
The constitutional environmental right elevates the importance of environmental
protection and conservation, and emphasises the significance that South Africans attach to
a sound and healthy environment. In addition, the environmental right applies horizontally
and this implies that any industry has to exercise a duty of care if liability, on the basis of
the constitutional environmental right, is to be avoided. The constitutional environmental
right is given effect to by means of detailed statutory provisions ranging from framework to
sectorial legislation which relate to mining.
1.6.2 Mineral and Petroleum Resources Development Act
The MPRDA provides that South Africa’s mineral and petroleum resources belong to the
nation and that the DMR is the custodian thereof. The MPRDA allows the DMR to promote
equitable access to these resources, as well as give effect to Section 24 of the South
African Constitution by ensuring the nation’s mineral and petroleum resources are
developed in an efficient and ecologically sustainable manner.
By virtue of Section 37(1) of the MPRDA, the NEMA principles apply to the mining sector and
therefore the mining industry must adopt a risk-averse and cautious approach; prevent
negative impacts or effects of their activities on the health and well-being of people and
the environment; and pay for all their pollution since they remain liable for the effects of
their policies, projects, programmes, products, processes, services or activities throughout
their life cycles.
Section 102 of the MPRDA provides 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 the extension of the area covered by it or by
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the addition of minerals or a share or shares or seams, mineralized bodies, or strata, which
are not at the time subject thereof) without written consent of the Minister.”
Legal Requirement
The proposed development of the Discard Dump constitutes a change to the EMPr,
therefore an approval of the EMPr addendum is required from the DMR before the
development may commence. An EMPr amendment was submitted to the DMR in 2012 to
combine the EMPrs for the different Kangra operations in the Piet Retief area.
The current application process comprises an application for an addendum to the 2013
EMPR Consolidation and Amendment.
The EMPr Consolidation and Amendment document approved in August 2014, applied to
combine the mining rights and EMPrs for the Maquasa East, Maquasa West, Nooitgesien and
Rooikop mining areas. Mining Right No. (MP) 30/5/1/2/2/134MR and (MP)
30/5/1/2/2/2/209MR were consolidated into (MP) 30/5/1/2/2/133MR:
• (MP) 30/5/1/2/2/134MR: issued on Portion of the Remainder of the Farm
Nooitgesien 381 IT, Portion of Mineral Area No. 1 of the Farm Maquasa 19 HT and
Portion of the Mineral Area No. 1 on the Remaining Extent of the Farm Rooikop 18
HT, Magisterial District of Wakkerstrom (Maquasa West and Nooitegesien);
• (MP) 30/5/1/2/2/2/209MR: issued on Portions 1 and 2 of the Farm Kransbank 15 HT,
Magisterial District of Wakkerstrom (Maquasa West underground);
• (MP) 30/5/1/2/2/133MR: issued on Remaining Extent of the Farm Maquasa 19 HT,
Roodekraal 21 HR and Rooikop 18 HT, Magisterial District of Wakkerstrom (Maquasa
East and Rooikop).
1.6.3 National Environmental Management Act
Section 2 of the NEMA provides for a comprehensive array of principles which cumulatively
aim to create among others, corporate socially responsible behaviour by establishing legal
liability for environmental damage, as well as damage to human health and well-being.
Any decision taken in respect of the application for environmental authorisation should take
into account these principles which includes the Polluter Pays Principle, the Precautionary
Principle, the Preventative Principle and the Cradle-to-Grave Principle.
Apart from these principles, the NEMA also contains mechanisms, procedures and structures
to facilitate pollution prevention, minimisation and remediation. A duty of care is
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contained in Section 28, which encompasses the main liability provision which applies
retrospectively (includes historical pollution).
Section 24 of the NEMA provides that the Minister may list activities which may not
commence without prior authorisation from the competent authority. Furthermore the
potential consequences for or impacts on the environment of listed activities must be
considered, investigated, assessed and reported on to the competent authority before such
a decision is made.
Legal Requirement
The proposed construction of the Discard Dump and associated infrastructure trigger
activities listed (refer to Table 1.4) in terms of Section 24 of the NEMA.
A Scoping and EIA process is therefore required in order to apply for environmental
authorisation from the Mpumalanga Department of Agriculture Rural Development, Land
and Environmental Affairs (MDARDLEA).
The applicable activities, summarised in Table 1.4, are listed in Listing Notice 2
(Government Notice 545 (GN545) as amended by Government Notice 923, published in
Government Gazette No. 37085 on 29 November 2013. This Listing Notice has since been
repealed by Government Notice R 984, published in Government Gazette (GG) No. 38282 on
4 December 2014.
Furthermore, the regulations published in terms of the NEMA (2010 Regulations:
Government Notice 543 (GNR543), published in GG No. 33306 on 18 June 2010) where
repealed and replaced by Government Notice R 982 published in GG No. 38282 on 4
December 2014. However, due to the fact that the application for the Discard Dump was
submitted before 4 December 2014, the application process being followed to comply with
the 2010 regulations.
Table 1.4 NEMA Listed Activities triggered by the proposed Discard Dump
ACTIVITY LISTED ACTIVITY DESCRIPTION TRIGGERED BY
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ACTIVITY LISTED ACTIVITY DESCRIPTION TRIGGERED BY
GNR545
Activity 2
The construction of facilities or infrastructure for any process or activity which requires a permit or license in terms of national or provincial legislation governing the generation or release of emissions, pollution or effluent and which is not identified in Notice No. 544 of 2010 or included in the list of waste management activities published in terms of section 19 of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) in which case that Act will apply.
The construction and operation of the discard dump and pollution control dam requires a Water Use Licence for the water use listed in terms of Section 21 (g) (Disposing of waste in a manner which may detrimentally impact on a water resources), which must be issued by the DWS
GNR545
Activity 15
Physical alteration of undeveloped vacant or derelict land for residential retail, commercial, recreational, industrial or institutional use where the total area to be transformed is 20 hectares or more;
except where such physical alteration takes place for:
(i) linear development activities; or
(ii) agriculture or afforrestation where activity 16 in this Schedule will apply.
The proposed discard dump area is planned on undeveloped land and exceeds 20 hectares in extent.
GNR545
Activity 19
The construction of a dam, where the highest part of the dam wall, as measured from the outside toe of the wall to the highest part of the wall, is 5 metres or higher or where the high-water mark of the dam covers an area of 10 hectares or more.
The development of a pollution control dam.
1.6.4 National Water Act
One of the main and ever-continuing concerns in South Africa is the sustainability of water
management, and the costs associated with the prevention and remediation of pollution in
a country with an average rainfall far below international standards. The NWA is one of the
government’s answers to some of these challenges and functions as sectoral legislation
within the framework of NEMA.
Section 19 of the NWA mirrors the provision of Section 28 of NEMA and addresses the
prevention and remediation of the effects of pollution.
Section 21 of the NWA lists 11 consumptive and non-consumptive water uses. Section 22 of
the NWA provides that water may be used if it is permissible in terms of Schedule 1 of the
NWA, is an existing lawful water use defined under Section 32; is permissible under a
General Authorisation Notice published in terms of the Section 39, or if it is licensed in
terms of Section 40 of the NWA.
The following water uses are triggered by the proposed development:
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• Section 21(g) - Disposing of waste in a manner which may detrimentally impact on a
water resource.
• Section 21 (c): Impeding or diverting the flow of water in a water resource.
• Section 21 (i): Altering the bed, banks, course or characteristics of a watercourse.
Legal Requirement
A water use licence is required for the above listed water uses triggered by the construction
and operation of the Discard Dump and PCD.
An Integrated Water Use Licence Application Report (IWULA) and an accompanying
Integrated Water and Waste Management Plan (IWWMP) need to be submitted to the DWS
to apply for the WUL in respect of the proposed water uses.
1.6.5 GN704
Section 26 (1) of the NWA makes provision for the Minister of Water Affairs to make
regulations to control, monitor, modify or prohibit various practices related to water use.
Government Notice 704 was promulgated by the Minister on 4 June 1999 in Government
Gazette vol. 408, No. 20119 (GN704). The GN704 Regulations were published in terms of
Section 26 (1), (b), (g) and (i) of the NWA and pertain specifically to water uses for mining
and related activities.
Section 3 of the GN704 makes provision for exemption from the requirements of the GN 704
schedules. This exemption will only be granted if the mine can prove that they have
implemented measures according to the best practice guidelines and regulations that will
ensure the protection of the water resources at all times.
Legal Requirement
Exemption is required from Regulation 4 (a) of the GN704 due to the proposed Discard
Dump being located within 100m of a surface water resource. This application will be made
as part of the IWULA report to be submitted.
1.6.6 National Environmental Management: Air Quality Act
The purpose of the National Environmental Management Act, 2004 (Act No. 39 of 2004)
(NEMAQA) is to prevent air pollution, to enhance air quality and to ensure sustainable
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development. Section 8 of the Act provides for the setting of national air quality standards,
monitoring and management of air quality and emissions.
Section 32 deals with dust control measures and provides for the Minister to prescribe
measures for the control of dust in specified places or areas, either in general of by
specified machinery or in specified instances the steps to be taken to prevent nuisance or
other measures aimed at the control of dust.
Section 34 provides for measures to control noise. These measures may be promulgated
through regulations. As none have been promulgated, it appears that the noise control
measures promulgated in terms of the Environment Conservation Act, 1989 (Act No. 73 of
1989) (ECA) still apply.
Section 21 of the NEMAQA makes provision for the listing of activities which result in
atmospheric emissions, which must be licensed prior to commencement in accordance with
Section 22 of the NEMAQA.
Legal Requirement
No Atmospheric Emission Licence is required in terms of the NEMAQA.
The storage and handling of ore and coal not situated on the premises of a mine or works is
listed in Subcategory 5.1 of Government Notice No. 248, published in GG No. 33064 on 31
March 2010. The proposed Discard Dump falls within a mining right area, therefore this
listed activity is not triggered.
The proposed Discard Dump area is located within the Highveld Priority Area (HPA),
declared in terms of section 18 (1) of the NEMAQA, in Government Notice No. 1123, in
Government Gazette No. 30518, dated 23 November 2007.
A Priority Area Air Quality Management Plan (AQMP) for the HPA was developed in terms of
section 19 (3) of the NEMAQA, and published in Government Notice NO. 144, in Government
Gazette No. 35072, dated 2 March 2012.
1.6.7 National Environmental Management: Waste Act
The National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) (NEMWA)
fundamentally reformed the law regulating waste management, and for the first time
provides a coherent and integrated legislative framework addressing all the steps in the
waste management hierarchy (waste avoidance, reduction, re-use, recycle, which is the
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overall approach that informs waste recycling, recovery, treatment and safe-disposal as a
last resort). The NEMWA (Section 5 (2)) provides that the Act should be interpreted and
guided in accordance with the NEMA principles.
The objects of the NEMWA are to protect health, well-being and the environment by
providing reasonable measures for, inter alia, remediating land where contamination
presents, or may present, a significant risk of harm to health or the environment.
The NEMWA provides for a licensing regime specific to waste management activities. It
replaces the historical system of permits issued in terms of the repealed Section 20 of the
Environment Conservation Act, 1989 (Act No. 73 of 1989) (ECA). Category A activities
require a basic assessment process and Category B activities require a Scoping and EIA
process as prescribed in the NEMA regulations.
On 2 June 2014 the amendment to the NEMWA was published (effective on the date of
publication), providing that residue stockpiles, which includes discard dumps, were
included under Schedule 3 of the NEMWA as hazardous waste. This meant that the proposed
Discard Dump requires a Waste Management Licence (WML) in terms of the NEMWA.
Following the above mentioned amendment, Government Notice Regulation 633 (GNR633)
was published in Government Gazette No. 39020 on 25 July 2015, which amended the
Waste Management Activities List (published in Government Notice No. 921, of 29
November 2013 as amended by Government Notice No. R. 332 of 2 May 2014). This
amendment specifically lists the establishment or reclamation of residue deposits and
stockpiles as a waste management activity, which requires a WML.
Legal Requirement
A WML is required for the following Category B activity now listed under the Waste
Management Activities List:
(11) The establishment or reclamation of a residue stockpile or residue deposit resulting
from activities which require a mining right, exploration right or production right in terms
of the Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002).
The competent is authority for the NEMWA application is the DMR.
The WML application is beyond the scope of this process. It is recommended that the DMR is
contacted regarding the required WML to determine if an additional application is
necessary of if the current process is sufficient for the granting of a WML.
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Government Notice Regulation No. 632, published in Government Notice 39020 on 24 July
2015 (GNR632) (“Regulations Regarding the Planning and of Residue Stockpiles and Residue
Deposits from a Prospecting, Mining, Exploration or Production Operation”) must be
adhered to in respect of the proposed Discard Dump.
Legal Requirement
The GNR632 provides that the planning, management and assessment of the residue
stockpile must be undertaken in accordance with the regulations set out therein. The
planning, i.e. design, waste characterisation, geotechnical study and groundwater
assessment was undertaken in accordance with the relevant regulations and DWS best
practices.
1.6.8 Spatial Planning and Land Use Management Act
The Spatial Planning and Land Use Management, 2013 (Act No. 16 of 2013) (SPLUMA), which
came into effect in 2015, provides a framework for local and provincial authorities in
respect of spatial planning and land use policies.
Section 24 of the SPLUMA provides that local municipalities must, within 5 years of
commencement of the Act, adopt and approve a single land use scheme for its entire area,
including areas not previously subject to a land use scheme.
Section 26 (3) of SPLUMA provides:
“Where no town planning or land use scheme applies to a piece of land, before a land use
scheme is approved in terms of this Act such land may be used only for the purposed listed
in Schedule 2 to this Act and for which such land was lawfully used or could lawfully have
been used immediately before the commencement of this Act.”
Schedule 2 lists land use for mining purposes as: “purposed normally or otherwise
reasonably associated with the use of land for mining.
Although the proposed Discard Dump will be located within an existing MRA, adjacent to
rehabilitated opencast pits, Kangra must ensure that the correct land use is allocated to
the properties in question by the local municipality in any land use scheme being prepared.
Kangra must also liaise with the local municipality regarding any rezoning permit which may
be required. The rezoning does not form part of the EIA process, so it will therefore this
issue will be addressed by Kangra during the planning phase of the development.
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Legal Requirement
The rezoning requirements must be determined in consultation with the local municipality.
Should it be determined that rezoning is necessary, this must be undertaken by Kangra prior
to any construction taking place.
1.6.9 Other Legislation
The legislation which has been reviewed during the compilation of this document includes:
• Hazardous Substance Act, 1973 (Act No. 15 of 1973)(HSA);
• The National Environmental Management: Biodiversity Act, 2004 (Act No. 10 of
2004) (NEM:BA);
• The National Heritage Resources Act, 1999 (Act No. 25 of 1999) (NHRA);
• The Conservation of Agricultural Resources Act, 1983 (Act No. 43 of 1983) (CARA);
• The Mine Health and Safety Act, 1996 (Act No. 29 of 1996) (MHSA); and
• The Occupational Health and Safety Act, 1993 (Act No. 85 of 1993) (OHSA).
1.7 Environmental Process
The three (3) environmental application processes currently underway in respect of the
proposed Discard Dump are summarised in Table 1.5. This section provides an overview of
the application process undertaken to date, as well as the remaining process. A detailed
description of the public participation process (PPP) is given under Chapter 5 of this report.
The application processes have been integrated as far as possible to also allow for an
integrated public participation process (PPP) (refer to Chapter 5 of this report) and for the
completion of all the necessary specialist studies.
The application process can be divided into four main phases (refer to Figure 1.3 and the
discussion which follows):
• Application phase;
• Scoping and PPP initiation;
• EIA Phase and public feedback and
• Final submission and CA feedback.
Table 1.5 Summary of Environmental Authorisations Required
LEGISLATION APPLICATION PROCESS
AUTHORISATION REQUIRED COMPETENT AUTHORITY (CA)
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LEGISLATION APPLICATION PROCESS
AUTHORISATION REQUIRED COMPETENT AUTHORITY (CA)
NEMA Scoping and EIA Positive Record of Decision
Mpumalanga Department of Agriculture Rural Development, Land and Environmental Affairs (MDARDLEA)
NWA IWULA Integrated Water Use Licence (IWUL)
Department of Water and Sanitation (DWS)
MPRDA Addendum to approved EMPr
Approval of addendum Department of Mineral Resources (DMR) Witbank
Figure 1.3 Environmental Process Flow Diagram
1.7.1 Application phase
An application form was submitted to the MDARDLEA on 25 February 2014 to initiate the
NEMA application process.
The application was accepted and a reference number (17/2/3 GS-240) issued on 5 March
2014. The applicant and EAP were instructed to continue with the application process.
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1.7.2 Scoping and PPP initiation
Once the NEMA application reference number was received the registered Interested and
Affected Parties (I&APs) and the public were notified of the application in writing via a
newspaper advertisement, site notices, Background information documents (BIDs) and text
messages (sms).
A draft Environmental scoping report (ESR) was compiled in accordance with the
requirements set out in the NEMA 2010 Regulations (GNR543) and the MPRDA Regulations
(GNR527, published in GG 26275, on 23 April 2004).
The Draft ESR was placed at public venues for public review during April/May 2014 (refer to
chapter 5) before submission to the DMR. After a second review period the Final ESR was
submitted to the MDARDLEA in November 2014.
In terms of the MPRDA, Ms Matshilele Ramhova of the DMR confirmed that the EIA process
could proceed (email dated 11 November 2014). In terms of the NEMA process, the final ESR
was accepted in a letter dated 21 January 2015. The MDARDLEA also requested that an
Avifaunal Assessment is undertaken for the proposed development area and submitted with
the EIR.
1.7.3 EIA Phase and Public Feedback
The EIA Phase will involve the following activities:
• Public review of the draft EIR/EMPr (30 calendar days);
• A public feedback meeting to discuss the outcomes of the various specialist studies
undertaken; and
• Compilation of the IWULA and IWWMP.
1.7.3.1 NEMA EIR/EMP
The application process set out in the NEMA regulations (GNR543) requires that an EIR and
EMP are compiled. This report has been compiled as a combined EIR and EMP report and
meets the requirements set out in the GNR543.
Furthermore, all specialist studies have been compiled by qualified environmental experts,
in accordance with the minimum requirements stipulated in the regulations.
1.7.3.2 MPRDA EMP Addendum
This report has been compiled as a combined EIR and EMP report and meets the
requirements set out in the MPRDA regulations.
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1.7.3.3 Integrated Water Use Licence Application
The IWULA Report will contain all the necessary information as required on the relevant
report checklist (as provided by the DWS). The IWWMP has been compiled in accordance
with the IWWMP Operational Guideline, 2010.
These reports will not be placed in the public domain for review and comment, as this is
not required in terms of the NWA.
1.7.3.4 Final Submission and Authority Feedback
After the comments are received during the public feedback meeting and the public review
period, they will be incorporated into the Final EIR/EMPr and IWULA and IWWMP Reports.
The following authority review periods are applicable:
• NEMA: The GNR543 makes provision for a minimum of 121 days for the MDARDLEA to
issue a decision (Acknowledgement of receipt- 14 days after submission;
Accept/reject EIR/EMP- 60 days after submission; Reach a decision (grant/refuse) -
45 days after submission; and issue the Record of Decision (ROD) - 2 days after
reaching decision);
• MPRDA: The MPRDA (section 39 (4) (a)) provides that a decision would be reached
within 120 days of the lodgement of an EMPr. Section 39 (5) further provides that
the Minister may request additional information, although no timeframes are
stipulated for a decision following the submission of additional information; and
• NWA: There are no legislated timeframes for the consideration of IWULAs. Most
applicants wait between 1 to 2 years to receive a decision from the DWS.
1.8 Report Structure
This report has been compiled to meet the requirements set out in the GNR543 in terms of
the NEMA and the GNR527 in terms of the MPRDA. As such, it contains the following
chapters:
• Chapter 1: Introduction - This includes the applicant and EAP details, an
assessment of the environmental legal requirements, as well as a brief description
of the environmental application process.
• Chapter 2: Project Description. This provides a brief overview of the current
operations and a description of the proposed development.
• Chapter 3: Project Alternatives. This provides a description of the alternative
disposal methods, options for discard disposal, disposal methods and land uses
considered.
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• Chapter 4: Environmental Baseline Description. This provides a current description
of the biophysical and socio-economic environment within and immediately
surrounding the proposed development area.
• Chapter 5: Public Participation. This chapter describes the process undertaken to
inform and consult with the public and registered Interested and Affected Parties
(I&APs). The proof of the consultation is attached under Appendix B.
• Chapter 6: Assessment of Environmental Impacts. This chapter includes the
identification and assessment of the potential environmental and socio-economic
impacts which may be caused by the proposed development. The significance of the
potential impacts is assessed without, then with proposed mitigation measures to
determine if the potential impacts can be appropriately avoided, mitigated or
managed.
• Chapter 7: Environmental Management Plan. This chapter comprises the
environmental management plan which includes specific environmental
management measures, timeframes within which each measure must be
undertaken, the persons to whom the tasks must be assigned as well as the
associated annual management costs.
• Chapter 8: Monitoring Programme. This chapter comprised the proposed
programme for monitoring the environmental impacts of the proposed development
as well as the efficacy of the proposed management measures.
• Chapter 9: Rehabilitation Plan. This chapter comprises the rehabilitation plan for
the closure of the discard dump.
• Chapter 10: Environmental Awareness and Emergency Response Plan. The plan is
attached as a separate report under Appendix E.
• Chapter 11: Financial Provision. This chapter comprises a summary of the
Financial Provision for closure. A full report which presents the methodology and
full assessment is attached under Appendix F.
• Chapter 12: Information Gaps and Recommendations. This chapter summarises all
information gaps and the significance of these information gaps.
• Chapter 13: Conclusion. This is a summary of the main findings and includes the
EAPs recommendations.
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2 PROJECT DESCRIPTION
2.1 Project background (current and future mining)
The information in this section has been extracted from the Section 102 Consolidation and
Amendment Report (GCS, April 2013), which was approved in August 2014.
The Maquasa East, Maquasa West, Rooikop and Nooitgesien mining areas are the closest
Kangra operations to the proposed Discard Dump operation. The proposed Kusipongo
underground mine will be located to the west of the proposed Discard Dump.
2.1.1 Maquasa East (underground and opencast) and West (underground)
The Maquasa West is an active underground and opencast operation (Nooitgesien), while
mining at Maquasa East recently ceased. All mining related surface infrastructure, which
includes the coal washing plant, is located at Maquasa East. All coal mined at the Maquasa
West and Nooitgesien areas is processed at this washing plant. In addition, there is a
screening plant at Maquasa West.
The following infrastructure are existing at Maquasa East:
• Conveyors and associated service roads (transporting mined coal to the Maquasa
East processing plant);
• Power lines and associated service roads;
• Access roads;
• Haul roads;
• Water Pipeline;
• Crushers (Maquasa East);
• Washing and screening plant (Maquasa East);
• Overburden and stockpile (i.e. topsoil, run of mine ore, product) dumps;
• Existing Discard dump (Maquasa East);
• Offices, workshops and ancillary buildings (Maquasa East and West);
• Diesel storage; and
• Borrow pits.
The following expansions were applied for in the 2012 Section EMPr:
• The addition of two (2) new opencast resource pits at Maquasa East (Pit A and D);
and
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• The expansion of four (4) opencast resource pits at Maquasa West (Pit A, B, C and
D).
The proposed Discard Dump area is located adjacent to the Maquasa East Pit D (refer to
Figure 1.1), which already been mined and backfilled.
2.1.2 Nooitgesien Mining Area
Kangra has expanded their mining operations by establishing six (6) new opencast pits (one
of which is situated near the Maquasa East mining area and the remainder at the
Nooitgesien mining area), as well as the addition of two (2) underground resource areas and
four (4) waste rock discard dumps.
2.1.3 Rooikop
Rooikop was mined coal using both opencast and underground mining methods. Mining has
ceased at this operation and the open voids are filled with water. Kangra Coal intends to
explore various options to make use of or treat the water.
2.1.4 Kusipongo
The proposed Savmore Colliery Kusipongo adit will be located approximately 10km to the
west of the Maquasa East operation, with a 10km overland conveyor linking the adit to the
coal washing plant.
2.1.5 Projected coal tonnages
According to the approved Consolidated EMPr, it is envisaged that the mining of the
Maquasa West and Nooitgesien expansion areas will produce 80 000 tons of coal per month
with an estimated life of mine (LoM) of 5 to 6 years
According to the EIA Report compiled by ERM Southern Africa (ERM) in respect of the
proposed Kusipongo mining area, it is envisaged that the operation will have a LoM of 10 to
20 years with the potential to generate a run of mine (ROM) production volume of
approximately 3.6 to 3.8Mtpa.
Kangra proposes to construct a new Discard Dump at the Maquasa East mining area, to
dispose of the additional discard which will be created due to Kangra’s’ proposed
underground mining expansion project.
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2.2 Description the Discard Material
2.2.1 Hydrogeochemical Characterisation of the Discard
A hydro-geochemical assessment was performed on a 52kg sample of discard provided by
Kangra. The assessment methodology, as well as the detailed results are presented in the
Hydrogeochemical Report compiled by Geostratum, attached under Appendix C of the
Hydrogeological Report (Appendix C-6).
The sample provided was crushed, split into two samples (ABK601 and ABK602), and milled
prior to testing.
2.2.1.1 Mineralogy and Total Chemical Composition
The results showed that Gypsum (CaSO42H2O) and Quartz (SiO2) (originating from calcic
rock) were the major minerals in the sample.
Kaolinite (Al2Si2O5 (OH) 4); Microcline (KAlSi3O8); and Muscovite (KAl2(Si3Al)O10(OHF)2)
occurred as minor minerals within the sample. Calcite (CaCO3) occurred as an accessory
mineral and is an important mineral in the neutralisation of acidity produced by pyrite
oxidation in acid-mine drainage (AMD) and frequently occurs in Karoo sedimentary rocks.
Plagioclase (NaAlSi3O8-CaAl2Si2O8) and Pyrite (FeS2) occurred in trace quantities.
2.2.1.2 Acid Rock Drainage Potential
The potential of geological material to oxidise and generate acidic drainage were
determined through acid-base accounting (ABA) and net acid generation (NAG) analyses,
respectively.
ABA is a set of analytical methods that measures acid generation potential through
independent determination of acid generating (AP) and neutralising (NP) content. These
tests provide an important first order assessment of potential drainage that could be
expected from the discard material.
NAG analysis, in combination with ABA tests, can be used to indicate the likelihood of acid
generation or stored acidity.
From the ABA and NAG test results, the following observations could be made:
• Pyrite was the only sulphide detected in the rock through means of X-ray
Diffraction (XRD). It was assumed that oxidation of pyrite will be the only
contributor to acidity;
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• Both samples showed high percentage Sulphur (%S), above 0.3%, of 0.55% and 1.49%
respectively;
• The neutralisation potential for the one sample is slightly higher than the acid
potential, while the other sample has a higher acid potential and is likely to
generate AMD; and
• During the NAG tests, only the second sample acidified. However, the part of the
discard with lower %S will not be able to neutralise all acidity generated by the
discard with the higher %S.
Overall, it could be concluded that the discard has a significant potential to generate
acid mine drainage/seepage.
2.2.1.3 Static Leach Tests
Discard material was subjected to the following leach tests in order to identify the
constituents that may leach out:
• Peroxide leaching test – reacted with 400 ml of 15 % hydrogen peroxide with a
rock/water ration of 1:100. This test simulates extreme conditions as all pyrite is
oxidised at once. Under field conditions, not all pyrite constituents will be oxidised
as some minerals are physically shielded by the rock matrix and oxidation will occur
over a long period of time.
• Reagent water leach test – 50g discard material reacted 1 000ml of reagent water
solution for 18 hours with water/rock ration of 1:20. The test was performed using
the extraction procedure for mono-filled waste according to Australian Standard
(AS) 4439.3.
• Toxicity Characteristic Leaching Procedure (TCLP) test – the test was performed
using the extraction procedure for mono-filled waste according to AS 4439.3.
The leachate composition does not reflect the leachate that may be expected from the
discard materials under field conditions. This is due to the fact that different leach rates
and water rock ratios are used in the leach tests and do not reflect conditions that is site-
specific.
The following observations were made from the leach testing:
• Peroxide leach test:
o The pH of the discard material is neutral to acidic, ranging between 3.26
and 6.92 (pH unit);
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o The leachate showed elevated dissolved concentrations of aluminium, iron,
manganese, nickel, lead and vanadium and to a lesser degree chromium;
and
o A positive correlation is present between the %S and the sulphate extracted
from the material.
• Reagent water leach test:
o The pH of the discard material is neutral, ranging between 6.49 and 6.55
(pH unit); and
o The leachate showed no elevated dissolved concentrations for metals or
trace elements.
• TCLP leach test:
o The pH of the discard material is acidic, ranging between 5.25 and 5.39 (pH
unit); and
o The leachate showed elevated dissolved concentrations of iron and
manganese and to a lesser degree aluminium and nickel.
2.2.2 Waste Classification
The NEMWA, Waste Classification and Management Regulations (Government Notice No.
634, published in Government Gazette No. 36784, dated 23 August 2013) require that all
waste generated by waste generators, subject to sub regulation (2) of the act, be classified
in accordance with SANS 10234 within one-hundred-and-eighty (180) days of generation.
Waste must be assessed in terms of the NEMWA National Norms and Standards for the
Assessment of Waste for Landfill Disposal (GN634). Waste is assessed for the purpose of
disposal to the landfill, by identifying the chemical substances present in the waste. This is
done by sampling and analysing the total concentrations (TC) and leachable concentrations
(LC) of the elements that have been identified in the waste and comparing that to the
threshold limits specified in Section 6 of the Norms and Standards.
The results of the TC and LC are summarised below (refer to the results in Table 6.7 and
Table 6.8 of the Hydrogeology Report, Appendix C-6):
• Barium, copper and lead results fall below the total concentration threshold (TCT0)
limits (<TCT0); and
• All chemicals falls below the total leachable concentration (LTC0) limits (<LTC0).
The discard material would be classified as Type 3 Waste based on the results of the TC and
LC analysis and the determination of waste types for landfill disposal Section 7(2) (d) that
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stipulates: “Wastes with all element or chemical substance leachable concentration levels
for metal ions and inorganic anions below or equal to the LCT0 limits are Type 3 Waste.”
2.3 Description the proposed development
A new Discard Dump is required, which will be located within the Maquasa East Mining Area
on Portion RE of the farm Rooikop 18 HT, with a small area of the dump on Portion RE of
the farm Maquasa 19 HT, in the vicinity of Piet Retief, Mpumalanga Province.
The Discard Dump will accommodate discard produced from the washing plant located at
Maquasa East, which currently wash and screens coal from the surrounding Kangra Mining
sections and will, in future, receive coal from the future expansion areas which are
discussed under section 2.1 of this report.
The Discard Dump has been designed by Geotail (Pty) Ltd and the description provided in
this section has been extracted from the Design Report (September 2014), which is
attached under Appendix E of this report. The recommendations made in the Geotechnical
Report (Appendix C-7) and in the draft Groundwater Assessment Report (refer to final
version under Appendix C-6) were incorporated into the Discard Dump design.
2.3.1 General Layout
The Discard Dump will be developed as a three-compartment side hill type storage facility
with a footprint of approximately 65ha. The three-compartment layout allows for a modular
implementation approach (Phases 1, 2 and 3) with the benefit of delaying capital
expenditure.
The following structures will be required:
• Lined Discard Dump (to be constructed in three different compartments/phases);
• Under-drainage system;
• Boundary fence;
• Internal haul roads
• Catchment Paddocks;
• Two compartment, HDPE lined Pollution Control Dam (PCD) (one compartment to
be operated as empty); and
• Stormwater management infrastructure, such as berms and trenches.
The layout of the proposed Discard Dump is presented in Figure 2.1. The location and
extent of the Discard Dump is provided in Figure 1.2 (refer to chapter 1 of this report).
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Figure 2.1 Discard Dump Layout (Geotail, 2014)
[REFER TO A2 FIGURE UNDER APPENDIX A]
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2.3.2 Dimensions and life of the facility
The proposed Discard Dump was three-dimensionally modelled for an accurate
determination of the relationship between the height, area and capacity. The results of this
modelling, are the capacity and dimensions of the Discard Dump summarised in Table 2.1.
Table 2.1 Dimensions and Capacity of the proposed Discard Dump
DESCRIPTION TOTAL/UNIT PHASE 1 PHASE 2 PHASE 3
Life of facility 20 years 7.4 7.4 5.4
Extent of Discard Dump 65ha 23.5 21.9 19.3
Capacity of discard dump 20.2 million tonnes (Mt)
7.4 7.4 5.4
Airspace available 11.2 million m³ 4.1 4.1 3.0
Final vertical height of Discard Dump
m 34 33 32
Deposition rate 1 million tonnes per annum of coarse
material**
- - -
Final side slope area Ha 13.1 9.0 8.2
Final top surface area 38ha 9.5 13.9 14.6
2.3.3 Construction/Disposal Method
The coal discard will be transported from the Maquasa East coal washing plant to the new
Discard Dump by truck, where it will be placed and compacted mechanically. The discard
will be placed in horizontal layers (bottom-up) following an approved performance
compaction specification.
The design report recommends the following (to be verified by the Project Engineer prior to
construction):
• An access ramp will be required from where dumping can take place. Simultaneous
dumping from more than one platform should be considered in order to reduce the
advance rate of a platform and to prevent potential damage to the HDPE
geomembrane;
• The side slopes will be terraced and berm penstocks will be utilised to drain the
permanent benches;
• The final side slope geometry should include 10m wide benches at 10m vertical
intervals;
• The benches should be cross-graded at 1(v):10(h) and a 0.5m (minimum) high
perimeter bund wall should be constructed. Berm penstocks should be extended to
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the final height of the Discard Dump. The longitudinal slope of the benches should
be modified to achieve the required longitudinal fall to the berm penstocks;
• A perimeter bund wall should be implemented on the top surface. The top surface
of each lift should be constructed to a 1(v):100(h) gradient that falls away from the
perimeter bund wall in order to prevent overtopping at the side slopes (also an
operational safety measure);
• The soil cover (including vegetation) should be constructed to a final side slope
angle of 1(v):3(h), giving the Discard Dump an overall slope of 1(v):4(h). The soil
cover should be constructed to an agreed performance specification;
• Survey control should be implemented to indicate the required limits for soil cover
construction, as well as the required final as-built dimensions; and
• The compaction specification for the coal discard should be investigated further
and confirmed during the operation phase, by implementing the following
procedure:
o The Design Engineer should approve the compaction specification and lift
thickness before construction commences. The specification will be
influenced by the size of the construction equipment. If necessary, a test
fill program should be implemented prior to construction;
o Lift thickness should be measured;
o The density and moisture content of the compacted discard material should
be determined directly by conventional methods and indirectly by observing
settlement of the fill;
o Test pits should be excavated through the compacted layers to allow visual
observation of lift thickness, particle size distribution and distribution of
density;
o Inspection should form a critical part of the quality control plan. The
inspector should ensure that the field-testing program establishes the
methods required to achieve the required quality, then to ensure that the
quality is being maintained and quantify means of rejecting substandard
work;
o Records and data should be kept up to date (by means of photographs,
notes and visual observations); and
o The Design Engineer reserves the right to re-execute tests and to re-specify
the compaction requirements from time to time based on material
variability, compactor type, moisture content etc.
Recommended