1 Environmental Authorisation and an Integrated Water Use Licence Application for the Reclamation of the Marievale Tailings Storage Facilities, …

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APPENDIX C:

Public Participation Information

❖ Appendix C1 – I&AP Database

❖ Appendix C2 – Land Claims Letters

❖ Appendix C3 – Background InformationDocument

❖ Appendix C4 – Newspaper Advert

❖ Appendix C5 – Site Notice Report and Map

❖ Appendix C6 – Announcement Notifications

❖ Appendix C7 – Organs of State Correspondence

❖ Appendix C8 – Minutes of Meetings and

Presentations

❖ Appendix C9 – Comments and Responses Report

❖ Appendix C10 – 5 June 2020 Regulations PP Plan

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APPENDIX C:


❖ Appendix C1 – I&AP Database

1

Environmental Authorisation and an Integrated Water Use Licence Application for the Reclamation of the Marievale Tailings Storage Facilities, Ekurhuleni Metropolitan Municipality - Gauteng Province

Landowner Database Directly Affected

Farm Name Farm ID Farm

Portion Infrastructure Farm owner Contact PERSON

DAGGAFONTEIN 125 IR 125 IR RE/154 Alternative 1 EBM Project (Pty) Ltd Mr Niel West (CEO)

DAGGAFONTEIN 125 IR 125 IR 128 Alternative 1 EBM Project (Pty) Ltd Mr Niel West (CEO)

DAGGAFONTEIN 125 IR 125 IR 137 Alternative 1 Transnet Ltd Mr Qatjha Ramokhothoane

DAGGAFONTEIN 125 IR 125 IR 112 Alternative 1 I&W Van Der Merwe Boerdery (Pty) Ltd Mr Harry Olpherman Van Der Merwe

DAGGAFONTEIN 125 IR 125 IR 1 (RE) Alternative 1 STI Consulting Services (Pty) Ltd Mr Ferdi Theo Kleynhans

DAGGAFONTEIN 125 IR 125 IR 126 Alternative 1 STI Consulting Services (Pty) Ltd Mr Ferdi Theo Kleynhans

DAGGAFONTEIN 125 IR 125 IR 114 Alternative 1 Fondagtuin Landgoed CC

DAGGAFONTEIN 125 IR 125 IR 159 Alternative 1 RAPPA Resources (Pty) Ltd Mr Gary Kenneth Bickerton & Mr Darryl Allcock

DAGGAFONTEIN 125 IR 125 IR 184 Proposed Pipeline from TCTA

South African National Roads Agency Limited

Ms Victoria Bota - Environmentalist

DAGGAFONTEIN 125 IR 125 IR 199 Proposed Pipeline to TCTA

STI Consulting Services (Pty) Ltd Mr Ferdi Theo Kleynhans

2



DAGGAFONTEIN 125 IR 125 IR 197 Proposed Pipeline to TCTA



East Rand Water Care Company ZIMASA ZODWA HARRIET SOCIKWA (Company Secretary)



DAGGAFONTEIN 125 IR 125 IR 127 (RE) Proposed Pipeline from TCTA

PROPERTY AND MINERAL RIGHTS CONSULTANTS EIENDOMS- EN MINERALEREGTE KONSULTANTE

Mr Johann Minnaar


CLPF Property Investment (Pty) Ltd Mr Franco Darrigo


CLPF Property Investment (Pty) Ltd Mr Franco Darrigo


East Rand Water Care Company ZIMASA ZODWA HARRIET SOCIKWA (Company Secretary)

DAGGAFONTEIN 125 IR 125 IR 104 Alternative 1 No windeed info



DAGGAFONTEIN 125 IR 125 IR 146 Alternative 1 Ekurhuleni Metropolitan Municipality

Mr Thabang Mokoena: Division Head: Legislative Governance and Compliance, Environmental Resource and Waste Management Department

DAGGAFONTEIN 125 IR 125 IR 113 (RE) Alternative 1 CONSOLIDATED MODDERFONTEIN MINES 1979 LTD

MURDOCH EATON, ANTHONY JAMES

3



GROOTFONTEIN 165 IR 10 Alternative 2 Transnet Ltd Mr Qatjha Ramokhothoane

GROOTFONTEIN 165 IR 99 Alternative 2 Gauteng Provincial Government

GROOTFONTEIN 165 IR 0 (RE) Alternative 2 Gauteng Provincial Government

GROOTFONTEIN 165 IR 85 Alternative 2 Ekurhuleni Metropolitan Municipality


GROOTFONTEIN 165 IR 82 Alternative 2 Ekurhuleni Metropolitan Municipality


GROOTFONTEIN 165 165 IR 29 Alternative 1 Inyanga Trading 102 (Pty) Ltd Ms Charmaine Joubert

GROOTVALY 124 IR 124 IR 1 (RE) Proposed Pipeline from TCTA

No windeed info

KWA THEMA 210 IR 35 Alternative 1 No windeed info

KWA THEMA 210 IR 210 IR 4 Alternative 1 No windeed info

KWA THEMA 210 IR 210 IR 33 Alternative 1 Ekurhuleni Metropolitan Municipality




4



MARIEVALE 282 IR 282 IR 282 Alternative 2 Marievale Nature Reserve Mr Rhulani Maluleke, Manager

RIETFONTEIN 128 IR 0 (RE) Alternative 1 Ekurhuleni Metropolitan Municipality


RIETFONTEIN 128 IR 81 (RE) Alternative 1 Vereeniging Property and Investments (Pty) Ltd

Mr Gavin Yeats or Mr Sam Hancock (Financial Manager)

RIETFONTEIN 128 IR 127 Alternative 1 Ekurhuleni Metropolitan Municipality


RIETFONTEIN 128 IR 128 IR 175 Alternative 1 Ekurhuleni Metropolitan Municipality


VLAKFONTEIN 130 IR 10 Alternative 1 Eskom Mr Jan Mitchell, Land Development

VLAKFONTEIN 130 IR 92 Alternative 1 First Trade & Invest 4 (Pty) Ltd Mr Harold Mauritius Spies

VLAKFONTEIN 130 IR 96 Alternative 1 Shell Downstream South Africa (Pty) Ltd Mr James William Alderslade

VLAKFONTEIN 130 IR 85 Alternative 1 First Trade & Invest 4 (Pty) Ltd Mr Harold Mauritius Spies

VLAKFONTEIN 281 IR 281 IR 0 (RE) Alternative 1 Scarlet Sun 33 (Pty) Ltd Ms Elsie Parkin

VLAKFONTEIN 281 IR 281 IR 9 Alternative 2 National Government of the Republic of South Africa

5



VOGELSTRUISBULT 127 IR 0 (RE) Alternative 1 Ekurhuleni Metropolitan Municipality


VOGELSTRUISBULT 127 IR

127 IR 3 Alternative 1 Ekurhuleni Metropolitan Municipality


WITKLIP (VULCANIA) 279 IR 0 (RE) Alternative 1 IPROP (Pty) Ltd Ms Jeanie Pelser

WITPOORTJE 117 IR 183 Alternative 1 ERGO Mining (Pty) Ltd ERGO Mining (Pty) Ltd

WITPOORTJE 117 IR RE/1 Alternative 1 No windeed info

WITPOORTJE 117 IR 150 Alternative 2 No windeed info

Indirectly Affected






I&W Van Der Merwe Boerdery (Pty) Ltd Mr Harry Olpherman Van Der Merwe


I&W Van Der Merwe Boerdery (Pty) Ltd Mr Harry Olpherman Van Der Merwe

6



DAGGAFONTEIN 125 IR 125 IR 133 Alternative 1 South African National Roads Agency Limited


DAGGAFONTEIN 125 IR 165 IR 35 Alternative 2 Sharon Park Township

DRAAIKRAAL 166 2 Alternative 2 Republic of South Africa

GROOTFONTEIN 165 IR 52 (RE) Alternative 2 Ekurhuleni Metropolitan Municipality


GROOTFONTEIN 165 165 IR 81 Alternative 1 Ekurhuleni Metropolitan Municipality


KWA THEMA 210 IR 27 Alternative 1 Ekurhuleni Metropolitan Municipality








7




RIETFONTEIN 128 IR 166 Alternative 1 No windeed info

RIETFONTEIN 128 IR 167 Alternative 1 South African National Roads Agency Limited


RIETFONTEIN 128 IR 96 (RE) Alternative 1 Ekurhuleni Metropolitan Municipality


RIETFONTEIN 128 IR RE/135 Alternative 1 Alstonville Investment (Pty) Ltd Mr Philip Du Plessis & Mr Ferdi Willemse (Project Manager)

RIETFONTEIN 128 IR 137 Alternative 1 Rand Water Board Mr Marc de Fontein - Senior Water Quality Advisor & Blesbokspruit to Forum Member

RIETFONTEIN 128 IR 46 Alternative 1 Rand Water Board Mr Marc de Fontein - Senior Water Quality Advisor & Blesbokspruit to Forum Member

RIETFONTEIN 128 IR 128 IR 151 Alternative 1 Ekurhuleni Metropolitan Municipality


RIETFONTEIN 128 IR 128 IR 7 Alternative 1 No windeed info

RIETFONTEIN 128 IR 128 IR 153 Alternative 1 South African National Roads Agency Limited


RIETFONTEIN 128 IR 128 IR 168 Alternative 1 No windeed info

8




127 IR 1 Alternative 2 Transnet Ltd Mr Qatjha Ramokhothoane

WITHOK 131 131 0 Alternative 1 Not registered

WITPOORTJE 117 IR 442 Alternative 1 Ebisimoe Investment (Pty) Ltd




WITPOORTJE 117 IR 108 Alternative 1 Ekurhuleni Metropolitan Municipality



1


Stakeholder Database

I&AP Sector Organisation Mr/Ms First Name Last Name Position Province

Agricultural Union AFGRI SA Mr Botha Ernst Afgri-Attorney Gauteng Province

Agricultural Union AFGRI SA Ms Nadia Hetzel Legal Representative (Afgri) Gauteng Province

Agricultural Union AFGRI SA Mr Johan Smuts Legal Representative (Afgri) Gauteng Province

Agricultural Union Agri South Africa (National) Mr Janse Rabie Head of Natural Resources Gauteng Province

Agricultural Union TAU SA Central Region Mrs Lynette Du Plessis TAU SA Central Region Gauteng Province

Agricultural Union TAU SA Northern Region Ms Wilma Prinsloo Regional Secretary Gauteng Province

Agricultural Union Transvaal Agricultural Union of South Africa (TAUSA)

Mr Louis Meintjies President Gauteng Province

Business & commerce Andrew Barker Development Consultant

Mr Andrew Barker Development Consultant Gauteng Province

Business & commerce Chamber of Mines Mr Nikisi Lesufi Senior Executive Gauteng Province

Business & commerce Chamber of Mines Ms Stephinah Mudau Head: Environmental Advisor Gauteng Province

Business & commerce Eskom Ms Lungile Motsisi Tx - Land Management Gauteng Province

2


Business & commerce Eskom Ms Ziyanda Mdoda Tx - AME Gauteng Province

Business & commerce Eskom Mr Sbu Nkalanga Land & Rights Officer Gauteng Province

Business & commerce Eskom Mr Wikus Snyman Land & Rights Investigations Gauteng Province

Business & commerce Eskom Mr Jan Mitchell Land Development Gauteng Province

Business & commerce Eskom Mr Godfrey Phala Land & Rights: Land Development

Gauteng Province

Business & commerce Eskom Mr Percy Motlhabi Admin Support / JHB Gauteng Province

Business & commerce Eskom Mr Jason Kasper Land and Rights Manager Gauteng Province

Business & commerce Eskom Ms Priscilla Mogomotsi Senior Advisor Land & Rights Land Development

Gauteng Province

Business & commerce Eskom Transmission Land and Rights (National)

Mr John Geeringh

Senior Consultant Environmental Management Group Capital Division: Land Development and Management

Gauteng Province

Business & commerce Klipwas Mr Dennis Jane Gauteng Province

Business & commerce Transnet Freight Rail Mr Vhonani Mulondo Engineering Technician Gauteng Province

Business & commerce Transnet Freight Rail Ms Mamothena Mothupi Engineering Technician Gauteng Province

Business & commerce Transnet Freight Rail Mr Joseph Molautsi Chief Admin officer Gauteng Province

3


Business & commerce Transnet Ltd Ms Cynthia Nong Gauteng Manager Gauteng Province

Business & commerce Transnet Ltd Ms Pumelela Ndyawe Environmental Manager Gauteng Province

Business & commerce Iprop Ms Jeanie Pelser Gauteng Province

Business & commerce iProp Mr Richard Bennet Managing Directlor Gauteng Province

Business & commerce Waste Product Utilization (WPU) Mr Darryl Allcock EHS Officer Gauteng Province

Business & commerce Passenger Rail Agency of SA (PRASA) Gauteng Province

Business & commerce Johannesburg Chamber of Commerce & Industry

Ms Joan Warburton-McBride

Chief Executive Gauteng Province

Business & commerce SANRAL Ms Victoria Bota Environmentalist Gauteng Province

Business & commerce SANRAL Mr Izak van der Linde PM: Traffic & Transport Gauteng Province

Business & commerce Envas - Ilangabi Prospecting Application Mr Corrie Retief Gauteng Province

Business & commerce Totapix (Pty) Ltd - Bloemendal Open Cast Coal Mine

Mr Bjorn Goosen Gauteng Province

Business & commerce Enviro - Insight CC - Bloemendal Open Cast Coal Mine

Mr Corne Niemandt Gauteng Province

Business & commerce Ilangabi Coal / Brikor Ltd Mr Murray Reid Manager Gauteng Province

Business & commerce Ilangabi Coal / Brikor Ltd Ms Marguerite Lubbe Environmental Officer Gauteng Province

4


Business & commerce Ilangabi Coal / Brikor Ltd Mr JC Le Grange Geologist Gauteng Province

Business & commerce Ilangabi Coal / Brikor Ltd Ms Lebepa Komape SLP Gauteng Province

Business & commerce Community Law for Happiness Village Ms Louise du Plessis Gauteng Province

Business & commerce Ilangabi Coal / Brikor Ltd Ms Taryn De Beer Secretary Gauteng Province

Business & commerce Transnet Freight Rail Ms Juliet Modipa Gauteng Province

Business & commerce Transnet Freight Rail Mr Mfundiso Mabungela Gauteng Province

Business & commerce Transnet Freight Rail Mr Xolisa Kilani Gauteng Province

Business & commerce Transnet Freight Rail Ms Linda Skarupke Gauteng Province

Business & commerce Transnet Freight Rail Mr Qatjha Ramokhothoane Gauteng Province

Business & commerce Scarlet Sun 33 (Pty) Ltd Mrs Marinda Newton Accountant Gauteng Province

Business & commerce Scarlet Sun 33 (Pty) Ltd Ms Elsie Parkin Owner Gauteng Province

Business & commerce E B M PROJECT PTY LTD Mr Niel West CEO Gauteng Province

Business & commerce E B M PROJECT PTY LTD Mr Mduduzi Cebekhulu Gauteng Province

Business & commerce Dalmar (Alstonville Investment (Pty) Ltd)

Mr Ferdi Willemse Project Manager Gauteng Province

5


Business & commerce Alstonville Investment (Pty) Ltd Mr Philip Du Plessis Gauteng Province

Community Member Marievale Community Mr Chris Koitsoe Gauteng Province

Community Member Marievale Community Ms Nocks Gauteng Province

Community Member Community Member Mr Alfred Mokofane Gauteng Province

Community Member Mr Khutso Mashabela Gauteng Province

Community Member DTTP Mr Trevor Dimane Gauteng Province

Community Member Mr Lesrica Mathake Gauteng Province

Community Member Mr Ronny Mashabela Gauteng Province

Community Member Ms Semakaleng Maimela Gauteng Province

Community Member Mr Emmanuel Mohlafe Gauteng Province

Directly Affected Landowner

Vereeniging Property and Investments (Pty) Ltd

Mr Sam Hancock Financial Director Gauteng Province


PROPERTY AND MINERAL RIGHTS CONSULTANTS EIENDOMS- EN MINERALEREGTE KONSULTANTE

Mr Johann

Minnaar

Gauteng Province


Randex Gauteng Province

Directly Affected Landowners

Waste Product Utilization (WPU) Mr Darryl Allcock EHS Officer Gauteng Province

6


Environmental NGO's African Wattle Crane Programme Ms Kerryn Morrison Manager Gauteng Province

Environmental NGO's Benchmarks Foundation Mr David van Wyk Member Gauteng Province

Environmental NGO's Benchmarks Foundation (BMF) Dr Johan Capel Gauteng Province

Environmental NGO's Birdlife South Africa Mr Jonathan Booth Advocacy Officer Policy & Advocacy Programme

Gauteng Province

Environmental NGO's Birdlife South Africa (BLSA) Mr Simon Gear Policy & Advocacy Manager Gauteng Province

Environmental NGO's Centre for Environmental Rights (CER) Ms Robyn Hugo Programme Head: Pollution & Climate Change

Gauteng Province

Environmental NGO's Council of Geosciences Mr Henk Coetzee Gauteng Province

Environmental NGO's Earthlife Africa Ms Judith Taylor Member Board Gauteng Province

Environmental NGO's East Ekurhuleni Environmental Forum Ms Shelley Owens Gauteng Province

Environmental NGO's Endangered Wildlife Trust (EWT) Ms Emily Taylor Urban Conservation Project Coordinator

Gauteng Province

Environmental NGO's Federation for Sustainable Environment (FSE)

Ms Mariette Liefferink Chief Executive Officer Gauteng Province

Environmental NGO's Groundwork Mr Bobby Peek Gauteng Province

Environmental NGO's Johannesburg Heritage Foundation Ms Flo Bird Gauteng Province

Environmental NGO's Johannesburg Mining Forum of South Africa

The Chairman Gauteng Province

7


Environmental NGO's Klip River Catchment Forum Mr Mogale Matseba Chairperson Gauteng Province

Environmental NGO's Legal Resources Centre (LRC) Mr Lucien Limacher Gauteng Province

Environmental NGO's Legal Resources Centre (LRC) Ms Lauren Nel Gauteng Province

Environmental NGO's IEC Head Office PTA Ms Janet Love Gauteng Province

Environmental NGO's South African Human Rights Commission

Prof Tracy-Lynn Humby Gauteng Province


Mr Buang Jones Provincial Manager Gauteng Province

Environmental NGO's South African National Biodiversity Institute (SANBI)

Gauteng Province

Environmental NGO's Wildlife and Environmental Society of South Africa (WESSA)

Mr John Wesson Manager: Conservation Specialist

Gauteng Province

Environmental NGO's South African National Biodiversity Institute (SANBI)

Gauteng Province

Environmental NGO's Johannesburg Heritage Foundation Ms Flo Bird Gauteng Province

Environmental NGO's WESSA (Wildlife & Environmental Society of South Africa) Springs & Nigel branch

Mr Peter Law Gauteng Province

Environmental NGO's Mr Alan Madden Gauteng Province

Environmental NGO's Mr Stan Madden Gauteng Province


Ms Judy Hollenbach CEO PA Gauteng Province

8


Environmental NGO's WESSA (Wildlife & Environmental Society of South Africa) Springs & Nigel branch

Mr Peter Law Gauteng Province

Environmental NGO's Eastern Gauteng CPF Mr Mike Du Toit President Gauteng Province

Farmers Association National African Farmers’ Union (NAFU) Mr Motsepe Matlala President Gauteng Province

Indirectly Affected Landowner

Patcon Sales (Pty) Ltd Mr John Duncan Gauteng Province

Interested Party Interested Party Mr Matthew Havinga Gauteng Province

Interested Party Interested Party Mr Ronnie Newby Gauteng Province

Interested Party Mr Garith Newby Gauteng Province

Interested Party Ms Deborah Newby Gauteng Province

Interested Party Mr Bill Ross-Adams Gauteng Province

Interested Party Private Property Owner Mr Philip De Jager Private Gauteng Province

Interested Party Community Member Mr Alfred Mokofane Gauteng Province

Interested Party Mr Derrick Sphiwe Gauteng Province

Interested Party Interested Party Mr Matthew Havinga Gauteng Province

Interested Party Interested Party Mr Ronnie Newby Gauteng Province

9


Interested Party Private Property Owner Mr Philip De Jager Private Gauteng Province

Interested Party Mr Duncan Du Toit Gauteng Province

Interested Party TBC Mr Ivan Baker Gauteng Province

Interested Party Selpark CFP Ms Bev Caldwell Gauteng Province

Labour Union Congress of South Africa Trade Union (COSATU)

Mr Sizwe Pamla National Spokesman Gauteng Province

Labour Union National Union of Metal Workers of South Africa (NUMSA)

Mr Woody Aroun Gauteng Province

Labour Union National Union of Mine Workers (NUM) Mr Tafa Moya National Co-Ordinator Gauteng Province

Labour Union National Union of Mine Workers (NUM) Mr Thenji Phoko NUM National Gauteng Province

Libraries Dunnottar Public Library Mr Shelton Mmisi Liberian Gauteng Province

Libraries Kwa-Thema Public Library Ms Portia Mosetlhe Liberian Gauteng Province

Mining & Industry Impala Platinum Limited – Springs Ms Carina Burger Safety & Environmental Manager

Gauteng Province

Mining & Industry Exxaro Ms Igna Dougal Gauteng Province

Mining & Industry

Exxaro Mr Johannes Van Der Bijl Gauteng Province

10


Municipality City of Ekurhuleni Metropolitan Municipality

Mr Thabang Mokoena

Division Head: Legislative Governance and Compliance, Environmental Resource and Waste Management Department

Gauteng Province


Ms Cecilia Rakgoale EAP Gauteng Province


Ms Regina Gosebo Senior Admin Gauteng Province


Ms Refiloe Selahle Gender Officer Gauteng Province


Mr Thabo Mphuthi Customer Relations Officer Gauteng Province


Mrs Adri Venter Municipal Managers PA Gauteng Province


Ms Rebotile Motau CRM Manager Brakpan Gauteng Province


Mr Dudu Twala Area Manager: Brakpan CCA: City Planning

Gauteng Province


Mr Christopher Munyai Brakpan Economic Development

Gauteng Province


Ms Dorcus Modiba Gauteng Province


Mr Vincent Nkosi Gauteng Province


Mr Nomonde Jacobs Gauteng Province


Mr Thabo Mphuthi Gauteng Province

11



Ms Pheta P. Mokoena Waste Manager: EMM Gauteng Province


Mr Mauchly Makhanthisa Gauteng Province


Mr Johan Crafford City Planning: Chief Building Inspector

Gauteng Province


Mr Vusi Mashile Gauteng Province


Ms Goodness Nokulunga

Nhlapho Divisional Head: Operations Customer Relations Management

Gauteng Province


Mr Moses Gafane Brakpan Health & Social Department

Gauteng Province


Ms Lillian Kwakwa Environmental Assessment Practitioner

Gauteng Province


Ms Rebotile Motau CRM Manager Brakpan Gauteng Province


Mr Mzwandile Masina Mayor Gauteng Province


Dr Imogen Mashazi Municipal Manager Gauteng Province


Mr Katlego Mokwena IDP Manager Gauteng Province


Mr Sthembiso Garane LED Manager: (HOD: Economic Development)

Gauteng Province


Mr Pieter Rudolph DEMS:ES - SDM:EP Gauteng Province


Mr Petrus Brits DEMS:ES - SDM: CODES Gauteng Province

12



Cllr Shadow Shabangu Ward Councillor: Ward 74 Gauteng Province


Cllr Simelane Thulani Ward Councillor: Ward 76 Gauteng Province


Cllr Dean Stone Ward Councillor: Ward 75 Gauteng Province


Cllr Wollaston Labuschagne Ward Councillor: Ward 88 Gauteng Province


Mr Gerhard Mac Carron Ekurhuleni Spatial Planning Gauteng Province


Ms Maggy Hadebe City Planning Spatial Planning Gauteng Province


Mr Bafana Mazibuko Disaster & Emergency Services Department

Gauteng Province


Mr Hennie Croucamp Emergency Services Codes Gauteng Province


Mr Makhudu Molepo Snr Environmental Health Practitioner

Gauteng Province


Mr Ndivhuwo Mutondwa Intern Gauteng Province


Ms Lerato Moloto Intern Gauteng Province


Mr Johan Koekemoer Manager Environmental Health Gauteng Province

Municipality

City of Ekurhuleni Metropolitan Municipality: Department of Environmental Resource and Waste Management

Ms Anél Hietbrink Environmental Assessment Practitioner & Waste Management

Gauteng Province

13


Municipality City of Ekurhuleni Metropolitan Municipality: Health

Mr Jerry Chaka Executive Director: Health Gauteng Province

National Government Department of Agriculture, Forestry and Fisheries (DAFF)

Ms Portia Khumalo ROC - Environmental Gauteng Province


Ms Mashudu Mukwevho Dir: Land Use & Soil Management

Gauteng Province


Ms Mulalo Sundani Environmental Impact Management

Gauteng Province


Ms Portia Khumalo ROC - Environmental Gauteng Province


Ms Mashudu Marubini Deputy Director Gauteng Province


Mr Themba Dlamini Gauteng Regional Office Gauteng Province


Ms Mulalo Sundani Environmental Impact Management

Gauteng Province

National Government Department of Environmental Affairs (DEA)

Mr Obed Baloyi Environmental Impact Evaluation

Gauteng Province


Mr Lucas Mahlangu Control Environmental Officer: Waste Licensing

Gauteng Province


Ms Pumeza Skepe Deputy Director Gauteng Province


Dr Mpho Tshitangoni Chief Director Gauteng Province

National Government Department of Mineral Resources (DMR)

Ms Mashudu Maduka Assistant Director Gauteng Province


Mr Musa Mangobe Gauteng Environment Gauteng Province

14



Mr Nkosinathi Mahlaba Ergo Project Case Officer Gauteng Province


Mr Rudzani Mabogo Head of Environment: Assistant Director

Gauteng Province


Mr Jimmy Sekgale Assistant Director Gauteng Province


Mr Joel Raphela DDG Gauteng Province


Mr Andre Cronje Chief Director Gauteng Province


Ms Suzan Malebe Regional Manager Gauteng Province


Mr Dimakatso Ledwaba Acting Regional Manager Gauteng Province


Ms Moleseng Tlaila Assistant Director Gauteng Province

National Government Department of Public Works (DPW) Ms Jeanette Monare Regional Manager Gauteng Province

National Government Department of Rural Development and land Reform (DRDLR)

Mr Harry Maphutha Regional Land Claims Commissioner

Gauteng Province

National Government Department of Rural Development and Land Reform (DRDLR)

Mr Solomon Maruma Land Claims Gauteng Regional Officer

Gauteng Province

National Government Department of Rural Development and Land Reform (DRDLR)

Ms Cindy Benyane Land Claims Commissioner: Gauteng Regional Office

Gauteng Province

National Government Department of Water and Sanitation (DWS)

Mr Marius Keet Acting Provincial Head Gauteng Province


Mr Victor Nkuna Environmental Officer Gauteng Province

15



Mr Bashan Govender Water Quality Manager (National)

Gauteng Province


Mr Londolani Mutshekwa National Gauteng Province


Mr Divan Van Niekerk National Gauteng Province


Ms Candace Enoch Environmental Officer Gauteng Province


Mr Ayanda Mtetwa National Gauteng Province


Mr Desmond Mutshaine Geochemistry Gauteng Province


Mr Kevin Koketso

Aphane GT Gauteng Province


Ms Malalo Sidogi Environmental Officer Gauteng Province


Mr Andrew Mbedzi Instream Gauteng Province


Mr Phillimon Khwinana Control Environmental Officer and Blesbokspruit to Forum Chairman

Gauteng Province

National Government Gauteng Department of Agriculture and Rural Development (GDARD)

Mr Loyiso Mkwana Chief Director Gauteng Province


Mr Jacob Legadima Director - Air Quality Management

Gauteng Province


Mr Eric Mulibana Air Quality Gauteng Province


Mr Marcelle Johnson Mining and Energy Unit: Air Quality

Gauteng Province

16



Mr Dan Motaung Deputy Director: EIA Gauteng Province


Mr Joshua Quinton PSG B Gauteng Province


Ms Anga Yaphi PS Gauteng Province


Ms Albertina Setsiba PS Gauteng Province

National Government National Department of Health Ms Belinda Makhafola Directorate: Environmental Health

Gauteng Province

National Government National Nuclear Regulator (NNR) Mr Patle Mohajane Programme Manager: NORM Gauteng Province

National Government National Nuclear Regulator (NNR) Mr Elmond Lekota Senior Analyst: NORM Gauteng Province

National Government National Nuclear Regulator (NNR) Ms Malebo Makgale Manager: Assessments: NORM Gauteng Province

National Government National Nuclear Regulator (NNR) Ms Veronica Ditsi Gauteng Province

National Government National Nuclear Regulator (NNR) Mr Maduvha Mauba Intern: Assessments Gauteng Province

Nature Reserve Marievale Bird Sanctuary Provincial Nature Reserve

Mr Rhulani Maluleke Manager Gauteng Province

Nature Reserve Suikerbosrand Nature Reserve Mr Mpere Mokoka Manager Gauteng Province

Nature Reserve Suikerbosrand Nature Reserve Mr Talfryn Harris Chairperson

Gauteng Province

Provincial Government Department of Health Johannesburg District

Ms Crystal Rosenburg Environmental Health Practitioner

Gauteng Province

17


Provincial Government Department of Health Johannesburg District

Ms Vonani Nkuna Environmental Health Practitioner

Gauteng Province

Provincial Government Department of Health: Gauteng Ms Mary Madaure Acting Environmental Manager Gauteng Province

Provincial Government Department of Water and Sanitation (DWS)

Ms Barbara Kalembo Gauteng Regional Environmental Officer

Gauteng Province


Ms Faith Fulufhelo

Khosa Gauteng Regional Representative

Gauteng Province


Mr Khathutshelo Mudau Gauteng Regional Representative

Gauteng Province


Mr Mabona (Rodney)

Lesiba Gauteng Regional Representative

Gauteng Province

Provincial Government Gauteng Department of Agriculture and Rural Development (GDARD)

Mr Tendani Rambuda Gauteng Province


Mr Mokutu Nketu Gauteng Province


Mr Erick Moletsane Gauteng Province


Mr Tjatja Mosia Gauteng Province


Mr Steven Mukhola Gauteng Province

Provincial Government Gauteng Department of Labour Gauteng Province

Provincial Government Johannesburg Roads Agency (JRA) Mr Andre Nel Operations Manager Gauteng Province

Provincial Government South African Heritage Resources Agency

Gauteng Province

18


Provincial Government South African Heritage Resources Agency

Mr Philip Hine Heritage Officer Gauteng Province

Residents Association Sharon Park Residents Association Mr Tony Tony Dodd Chairman Gauteng Province

Water Bodies -Institution Johannesburg Water (Pty) Ltd Mr William Bedser Engineer Gauteng Province

Water Bodies -Institution Randwater Mr Marc de Fontein Senior Water Quality Advisor & Blesbokspruit to Forum Member

Gauteng Province

Water Bodies -Institution Water Research Commission Dr Schafic Adams Gauteng Province

Page | 5

APPENDIX C:


❖ Appendix C2 – Land Claims Letters

1

Kongiwe Stakeholder Engagement

From: Kongiwe Stakeholder Engagement <[email protected]>Sent: Thursday, 17 October 2019 09:19To: '[email protected]'Cc: 'Sibongile Bambisa'Subject: LAND CLAIMS ENQUIRY: The Reclamation of Marievale TSFs Attachments: Marievale_Landclaims_Let_17 Oct_2019.pdf

Dear Mr Solomon Maruma Kongiwe Environmental (Pty) Ltd (Kongiwe) has been appointed as an independent Environmental Assessment Practitioner to undertake an Environmental Impact Assessment (EIA) process for Ergo Mining (Pty) Ltd (Ergo). Ergo Mining (Pty) Limited (hereafter Ergo), intends to reclaim and reprocess gold residues from the Marievale tailings storage facilities (TSFs) Nos. 7L5, 7L6 and 7L7, through its subsidiary Ergo. These TSFs are historical mineral deposits (slimes dams), situated 6 km north-east of Nigel and about 10 km south-east of Springs, in the Ekurhuleni Metropolitan Municipality (EMM), and were created prior to the promulgation of the Mineral and Petroleum Resources Development Act, 2002 (Act No 28 of 2002) (MPRDA) and are accordingly not regulated by the MPRDA. We would appreciate it if you could assist us with the attached enquire. Kind Regards,

The Stakeholder Engagement Team | Kongiwe Environmental (Pty) Ltd. Tel: +27 (12) 003 6627 | Fax: +27 (86) 476 6438 | Email: [email protected] Spaces, Byls Bridge Office Park, Building 14, Block B, Corner of Olievenhoutbosch & Jean Ave, Centurion, 0157, South Africa. PostNet Suite no 163, Private Bag X21, Bryanston, 2021, South Africa. www.kongiwe.co.za

Disclaimer: The provisions of Section 11 of the Electronic Communications and Transactions Act 25 of 2002 apply to this email notice and make it enforceable and binding on the recipient/addressee. This email message (including attachments) contains information which may be confidential and/or legally privileged. Unless you are the intended recipient, you may not use, copy or disclose to anyone the message or any information contained in the message or from any attachments that were sent with this email, and If you have received this email message in error, please advise the sender by email, and delete the message. Unauthorised disclosure and/or use of information contained in this email may result in civil and criminal liability. Everything in this e-mail and attachments relating to the official business of Kongiwe Environmental (Pty) Ltd is proprietary to the company. Caution should be observed in placing any reliance upon any information contained in this e-mail, which is not intended to be a representation or inducement to make any decision in relation to Kongiwe Environmental (Pty) Ltd. Any decision taken based on the information provided in this e-mail, should only be made after consultation with appropriate legal, regulatory, tax, technical, business, investment, financial, and accounting advisors. The e-mail address of the sender may not be used, copied, sold, disclosed or incorporated into any database or mailing list for spamming and/or other marketing purposes without the prior consent of Kongiwe Environmental (Pty) Ltd. Unless the intention to contract has been expressed in this message, this message cannot be regarded as a solicitation to contract, nor be seen as an offer or acceptance of contractual agreement. Neither the sender of the e-mail, nor Kongiwe Environmental (Pty) Ltd shall be liable to any party for any direct, indirect or consequential damages, including, without limitation, loss of profit, interruption of business or loss of information, data or software or otherwise. No warranties are created or implied that an employee of Kongiwe Environmental (Pty) Ltd and/or a contractor of Kongiwe Environmental (Pty) Ltd is authorised to create and send this e-mail.

Ergo Mining Operations (Pty) Ltd: The Reclamation of Marievale TSFs Land Claims Letter © 2019 Kongiwe Environmental (Pty) Ltd

Kongiwe Environmental (Pty) Ltd. Reg No 2016 / 135562 / 07 Directors: MJ Hennessy, BJ Thornton (CEO), GI Wilreker Tel: +27 (10) 140 6508 | Email: [email protected] 150 Bryanston Drive, Bryanston, Sandton, 2191, South Africa. PostNet Suite no 163, Private Bag X21, Bryanston, 2021, South Africa. www.kongiwe.co.za

Date: Thursday, 17 July 2019

Attention: Mr Solomon Maruma

Gauteng Department of Rural Development and Land Reform (DRDLR)

Office of the Regional Land Claims Commissioner: Gauteng Province

Email: [email protected]

Environmental Authorisation and an Integrated Water Use Licence Application for the

Reclamation of the Marievale Tailings Storage Facilities, Ekurhuleni Metropolitan Municipality -

Gauteng Province

LAND CLAIMS ENQUIRY

Kongiwe Environmental (Pty) Ltd (Kongiwe) has been appointed as an independent Environmental Assessment

Practitioner to undertake an Environmental Impact Assessment (EIA) process for Ergo Mining (Pty) Ltd (Ergo).

Ergo Mining (Pty) Limited (hereafter Ergo), intends to reclaim and reprocess gold residues from the Marievale

tailings storage facilities (TSFs) Nos. 7L5, 7L6 and 7L7, through its subsidiary Ergo. These TSFs are historical

mineral deposits (slimes dams), situated 6 km north-east of Nigel and about 10 km south-east of Springs, in

the Ekurhuleni Metropolitan Municipality (EMM), and were created prior to the promulgation of the Mineral

and Petroleum Resources Development Act, 2002 (Act No 28 of 2002) (MPRDA) and are accordingly not

regulated by the MPRDA.

The project area is made up of 50 farm portions all falling within the City of Ekurhuleni Metropolitan

Municipality. The affected farms are listed in Table 1 below.

Table 1: Directly Affected property details

Farm Name Farm ID Farm Portion

VOGELSTRUISBULT 127 IR 0 (RE)

VOGELSTRUISBULT 127 IR 3

DAGGAFONTEIN 125 IR 125 IR RE/154

MARIEVALE 282 IR 282

VLAKFONTEIN 281 IR 0 (RE)

VLAKFONTEIN 281 IR 9

GROOTFONTEIN 165 IR 52 (RE)

GROOTFONTEIN 165 IR 85

mailto:[email protected]

http://www.kongiwe.co.za/

2




GROOTFONTEIN 165 IR 0 (RE)







RIETFONTEIN 128 IR 81 (RE)

RIETFONTEIN 128 IR 0 (RE)

KWA THEMA 210 IR 35

KWA THEMA 210 IR 27

KWA THEMA 210 IR 28

KWA THEMA 210 IR 29

WITPOORTJE 117 IR 150

WITPOORTJE 117 IR 1558

WITKLIP (VULCANIA) 279 IR 0 (RE)

WITPOORTJE 117 IR RE/1

DAGGAFONTEIN 125 IR 125 IR 1 (RE)

DAGGAFONTEIN 125 IR 125 IR 123






3

















GROOTVALY 124 IR 124 IR 1 (RE)

Kongiwe would like to enquire if there are any land claims on any of the farms listed above. Please could you

revert to us as a matter of urgency.

Kind regards,

Sibongile Bambisa

Stakeholder Engagement Consultant

Kongiwe Environmental (Pty) Ltd

Tel: +27 (012) 003 6627 | Cell: +27 (72) 468 9584 |Email: [email protected]

Page | 6

APPENDIX C:


❖ Appendix C3 – Background Information Document

Ergo Mining Operations (Pty) Ltd: The Reclamation of Marievale TSFs Background Information Document

© 2019 Kongiwe Environmental (Pty) Ltd

Page | 1

PURPOSE OF THE DOCUMENT

This Background Information Document aims to provide you with important information regarding:

Ergo Mining Operations Proprietary Limited (Ergo)’s intention to reprocess and reclaim goldresidues of the Marievale (7/L/5; 7/L/6 and 7/L/7);

The Environmental Impact Assessment and the Public Participation Process to be undertaken insupport of the proposed project;

An Integrated Water Use Licence Application process; How you can register as an Interested and Affected Party (I&APs) and be kept informed about the

project developments; The public review and comment period for the Draft Scoping Report; and An invitation to an open day.

PROJECT BACKGROUND AND CONTEXT

Ergo Mining (Pty) Limited (hereafter Ergo), intends to reclaim and reprocess gold residues from the Marievale tailings storage facilities (TSFs) Nos. 7L5, 7L6 and 7L7. These TSFs are historical mineral deposits (slimes dams), situated 6 km north-east of Nigel and about 10 km south-east of Springs, in the Ekurhuleni Metropolitan Municipality (EMM), and were created prior to the promulgation of the Mineral and Petroleum Resources Development Act, 2002 (Act No 28 of 2002) (MPRDA) and are accordingly not regulated by the MPRDA.

Surface gold retreatment is a largely mechanised process with a risk profile that is significantly lower than that of conventional mining. The slimes dams will be reclaimed by hydraulic mining. During Hydraulic mining, the used process water mixes with the unconsolidated material of the slimes dams, resulting in what is known as a ‘slurry’. This slurry will be conveyed to the Ergo Processing Plant (hereafter Ergo Plant) for reprocessing using a newly constructed pipeline. Final deposition of reprocessed slurry will be on the licenced Brakpan/Withok TSF.

LOCALITY

The combined spatial extent of the four dumps is approximately 140 Ha. In terms of regional locality, the dumps are situated approximately 6 km north-east of Nigel and about 10 km south-east of Springs, in the

Environmental Authorisation and an Integrated Water Use Licence Application for the Reclamation of the Marievale Tailings Storage

Facilities, Ekurhuleni Metropolitan Municipality - Gauteng Province

Background Information Document October 2019

Ergo Mining Operations (Pty) Ltd: The Reclamation of Marievale TSFs

Background Information Document © 2019 Kongiwe Environmental (Pty) Ltd

Page | 2

Ekurhuleni Metropolitan Municipality (EMM). The three dumps are positioned as follows:

Site 1: This site consists of two dumps. Dumps 7L5 and 7L6. Dumps 7L5 and 7L6 fall within Ward 88, covering just over 80 Ha.

Site 2: Dump 7L7 is located approximately 1 km south of Site 1, also in Ward 88 and covers roughly 60 Ha.

The area is predominantly surrounded by other mine dumps, active mining operations, agricultural lands, scattered settlements, bare ground and several water bodies.

Table 1: Directly Affected property details

FARM NAME FARM ID FARM PORTION

INFRASTRUCTURE

Vogelstruisbult 127 IR 0 (RE) Proposed Pipeline to Daggafontein

Vogelstruisbult 127 IR 3 Proposed Pipeline from 7L5 and 7L6 to

Daggafontein Daggafontein 125 IR 1 (RE) Proposed Pipeline to TCTA

Daggafontein 125 IR 93 (RE) Proposed Pipeline to TCTA

Daggafontein 125 IR 108 Proposed Pipeline from Daggafontein to Ergo Plant




Daggafontein 125 IR 122 Proposed Pipeline from 7L5 and 7L6 to Daggafontein

Daggafontein 125 IR 123 Proposed Pipeline to TCTA






Page | 3


INFRASTRUCTURE




Daggafontein 125 IR 154 (RE) Proposed Pipeline to Daggafontein








Grootvaly 124 IR 1 (RE) Proposed Pipeline to TCTA

Marievale 282 IR 282 7L7 and Proposed Pipeline

Vlakfontein 281 IR 0 (RE) 7L7 and Proposed Pipeline

Vlakfontein 281 IR 9 Proposed Pipeline from 7L7 to Ergo Plan

Grootfontein 165 IR 0 (RE) Proposed Pipeline from 7L7 to Ergo Plan

Grootfontein 165 IR 10 Proposed Pipeline from 7L7 to Ergo Plan


Grootfontein 165 IR 52 (RE) Proposed Pipeline from 7L7 to Ergo Plan




Page | 4


INFRASTRUCTURE



Table 2: Indirectly Affected property details


INFRASTRUCTURE

Vogelstruisbult 127 IR 1 Proposed Pipeline from Daggafontein to Ergo Plant


















Page | 5


INFRASTRUCTURE

Draaikraal 166 IR 2 Proposed Pipeline




Rietfontein 128 IR 0 (RE) Proposed Pipeline

Rietfontein 128 IR 46 Proposed Pipeline

Rietfontein 128 IR 96 (RE) Proposed Pipeline

Rietfontein 128 IR 135 (RE) Proposed Pipeline to Daggafontein



Witpoortje 117 IR 1 (RE) Proposed Pipeline

Witpoortje 117 IR 91 Proposed Pipeline





PROJECT DESCRIPTION

Ergo Mining (Pty) Limited (hereafter Ergo), intends to reclaim and reprocess gold residues from the Marievale tailings storage facilities (TSFs) Nos. 7L5, 7L6 and 7L7. These TSFs are historical mineral deposits (slimes dams), situated 6 km north-east of Nigel and about 10 km south-east of Springs, in the Ekurhuleni Metropolitan Municipality (EMM), and were created prior to the promulgation of the Mineral and Petroleum Resources Development Act, 2002 (Act No 28 of 2002) (MPRDA) and are accordingly not regulated by the MPRDA.



Page | 6

Surface gold retreatment is a largely mechanised process with a risk profile that is significantly lower than that of conventional mining. The slimes dams will be reclaimed by hydraulic mining. During Hydraulic mining, the used process water mixes with the unconsolidated material of the slimes dams, resulting in what is known as a ‘slurry’. This slurry will be conveyed to the Ergo Processing Plant (hereafter Ergo Plant) for reprocessing using a newly constructed pipeline. Final deposition of unprocessed slurry will be on the licenced Brakpan/Withok TSF.

The Proposed Project will investigate two pipeline routes to convey slurry from the TSFs to the Ergo Plant for reprocessing; and return process water to the project site for reclamation.

PIPELINE ALTERNATIVES

First alternative: The pipeline route is approximately 25 km long and consists of two separate 500 mm diameter slurry and return water pipeline pairings. The first pair would be a 7 km extension from the project site to the Daggafontein Plant; while the second pair would be a 17 km extension from the Daggafontein Plant to the Ergo Plant.

Second alternative: The pipeline route would be a 19 km, 500 mm diameter slurry and return water pipeline pairing that extends from the proposed project site to the Ergo Plant.

ACCESS

Major routes around the mine TSFs are the N17 which runs parallel to and north of the TSFs and the R51 which runs west of and perpendicular to the TSFs. As far as possible, existing access roads will be utilised, and where this is not possible, these will be constructed as a two-by-two roadway, operating in both directions. Where access roads are to be constructed, these will be 4m wide gravel road with storm water earth channels and mitre drains to protect the road structure from flood damage. Intersections will be properly designed to provide safe entry and exit in and out of the mining area. Approvals from the provincial roads’ authorities will be obtained where necessary.

WATER SUPPLY

Potable water will be purchased from Rand Water or the municipality, with a contingency for portable JoJo tanks or connection to existing water pipeline infrastructure. In terms of process water, the water cycle operates as a closed circuit, meaning that limited make-up water will be required for the reclamation of the Marievale TSFs. Water required for the reclamation activities will be sourced from the existing central water storage facility located in Germiston and conveyed through existing and proposed process water pipelines to the project site for reuse in a closed-circuit system.

INFRASTRUCTURE

The following infrastructure will be utilised on site:



Page | 7

Overland slurry pipelines of 500 mm in diameter; Overland return water pipelines of 500 mm in diameter; Reclamation pump stations, which include:

o Slurry storage tank; o Linear screen o Water tank; o Motor control centre; and

Water infrastructure, stormwater systems and spillage handling systems; Electricity reticulation; Administration buildings, including change houses and ablution facilities; Access roads, routed from existing entry points; and Construction contractors’ yards (temporary facilities

LIFE OF MINE

The life of mine for the Proposed Project is expected to be approximately 20 years. An estimated amount of 500 000 tons/month ramping up to 1.2 million tons/month of slurry is expected to be pumped from the Marievale TSFs to the Ergo Plant for beneficiation.

REHABILITATION

Once reclamation is completed, the area will then be assessed for contamination (particularly in terms of radiation), contaminated soils will be removed, and the land levelled to its original functioning topography levels and revegetated. Following reclamation and rehabilitation, it is anticipated that the land will be levelled and vegetated to fit the surrounding environment.

LEGISLATIVE FRAMEWORK

Prior to proceeding with the reclamation process, the applicant is required to obtain various licences and an Environmental Authorisation from the relevant Competent Authorities. The required licences and the environmental authorisation will be undertaken in accordance with the following legislation:

Application for an Environmental Authorisation for listed activities triggered in Listing Notices GN R327, GN R325 and GN R324 in terms of the Environmental Impact Assessment (EIA) Regulations, 2017, as promulgated in terms of the National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA);

Application for listed waste activities in terms of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008), as amended (NEM:WA). The Competent Authority responsible for assessing the abovementioned applications is the Department of Mineral Resources and Energy- (DMRE)- Gauteng Region.



Page | 8

An Integrated Water Use Licence Application (IWULA) will be undertaken in accordance with the National Water Act, 1998 (Act No.36 of 1998) (NWA). The Department of Human Settlements, Water and Sanitation will be the Competent Authority to assess the IWULA for the proposed project.

Please refer to Table 2 below for a list of activities to be authorised under the NEMA, NEM:WA and NWA.

Table 2: List of Activities to be authorised in accordance with NEMA, NEM:WA and NWA

Applicable listing notice in terms of NEMA

Waste management authorisation in terms of NEM:WA

Water Use Licence Authorisation in terms of the NWA

GNR 324: Activity: 2; 4 and 14 GNR 921

21(c) & (i)

GNR 325: Activity 6; and 7 None None

GNR 327 – 10; 12; 13; 9 and 19 None

SCOPING AND ENVIRONMENTAL IMPACT ASSESSMENT PROCESS

Kongiwe Environmental (Pty) Ltd has been appointed as an independent Environmental Assessment Practitioner to conduct the EIA process for the proposed project. In accordance with the provisions of the EIA 2014 Regulations (as amended), the EIA process for the proposed project will be carried out in the following phases:

Figure 1: EIA process and the associated timeline

Scoping phasePurpose: Identify potential impacts and project alternatives toguide the EIAProcessTimeline: October 2019 -February 2020

Impact Assessment PhasePurpose: Conduct detailed specialist studies to assess both positive and negative impacts. Consolidate impact assessments and provide recommendations on how to enhance positive impacts and mitigate negative impactsTime line: February 2020 -May 2020

Decision making phasePurpose : Competent Authority evaluates findings from the EIA process and grants/rejects the Environmental Authorisation.Time line: September 2020



Page | 9

INTEGRATED WATER USE LICENCE

An Integrated Water Use Licence Application will be conducted for water uses associated with Section 21 of the NWA. The IWULA process will be undertaken concurrently with the EIA process for the proposed Marievale TSFs reclamation project.

SPECIALIST STUDIES

Various specialist studies will be undertaken as part of the EIA process to assess the potential impacts associated with the proposed project. Specialist studies to be undertaken include:

PUBLIC PARTICIPATION PROCESS

The public participation process will form part of the Integrated Environmental Authorisation, Waste Management Licence Application and the IWULA process. The public participation process offers stakeholders a fair opportunity to be informed about the proposed project, to raise issues of concern and to make suggestions for enhanced project benefits. The project team will consider relevant issues and suggestions during the EIA and IWULA (at a later stage) process.

AVAILABILITY OF THE SCOPING REPORT FOR PUBLIC REVIEW AND COMMENT

The Draft Scoping Report for the Marievale project will be made available for public review and comment for a period of 30 days, from 23 October 2019 – 21 November 2019. The report can be accessed at the following locations:

Location Physical Address Contact person Hard copies Dunnottar Public Library 47 Rhodes Avenue, Dunnottar Mr Shelton Mmisi (Librarian)

(011) 999 9118 Kwa-Thema Public Library 7019 Nkosi Street, Kwa-Themba, Springs Ms Portia Mosetlhe (Librarian)

(011) 999 8494 Electronic copies Kongiwe Environmental website

www.kongiwe.co.za/public documents Sibongile Bambisa / Vanessa Viljoen

For a CD copy please contact the stakeholder engagement team (Sibongile Bambisa/ Vanessa Viljoen), Tel: (012) 003 6627, Email: [email protected]

Biodiversity and Wetlands; Social;

Surface Water; Heritage and Archaeology; and

Groundwater; Noise.

Air quality;





Page | 10

A technical report in support of the IWULA process will be made available for public review and comment for a period of 60 days. Information regarding the availability of the IWULA report and how stakeholders can provide their comments will be communicated to all stakeholders at a later stage.

INVITATION TO AN OPEN DAY

Interested and Affected Parties are invited to attend an open day which will be held on Saturday, 09 November 2019 at the Grootvaly Blesbokspruit Wetland Reserve in Welgadacht Road in Springs from 10H00 - 15H00. The purpose of the open day is to discuss the proposed project, contents of the Scoping Report and also to provide I&APs with an opportunity to raise their concerns/comments and interact with the project team.

HOW TO BECOME INVOLVED

Any person affected by or who may be interested in the proposed project is asked to register as an Interested and Affected Party (I&AP) by contacting the stakeholder engagement team. Contact person: Sibongile Bambisa/Vanessa Viljoen Tel: (010) 140 6508, Email: [email protected]

Our team welcomes your participation and looks forward to your involvement throughout this process.

COMMENTS AND QUERIES:

Should you have any comments/queries, please contact the stakeholder engagement team.

Contact persons: Sibongile Bambisa/Vanessa Viljoen

Tel: 010 140 6508

Email: [email protected]


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Project Name : Marievale Reclamation ProjectCoordinateSystem : WGS84 Decimal DegressDate : 10 October 2019 v3

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Proposed Pipeline to TCTA

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District Municipality

Formal Protected Areas

Mine Dumps Outlines

7L5

7L7

7L6

Ergo Plant

Daggafontein Plant

Ergo Mining Operations (Pty) Ltd: The Reclamation of Marievale TSFs Stakeholder Registration and Reply Form


1

Environmental Authorisation and an Integrated Water Use Licence Application for the Reclamation of the Marievale Tailings Storage Facilities,

Ekurhuleni Metropolitan Municipality - Gauteng Province

Stakeholder Registration and Reply Form Please return a completed reply form to the Stakeholder Engagement team:

Sibongile Bambisa / Vanessa Viljoen

Phone: 012 003 6627 or E-mail: [email protected] Postal Address: PostNet Suite no 163, Private Bag X21, Bryanston, 2021

Please provide your complete contact details:

If you are a landowner or you are occupying land, please indicate property details

I intend attending the Open Day Saturday, 09 November, starting at 10:00 and ending at 15:00 at Grootvaly Blesbokspruit Wetland Reserve in Welgadacht Road in Springs.

Yes No

To assist us with the specialist studies please answer the questions below. Should you require any assistance with filling in the questions please contact the abovementioned persons from the stakeholder engagement team.

1. How do you think the project might affect / impact you?

2. How do you think these effects/impacts can be managed, avoided and / or fixed should they happen?

Landowner Property Land occupier Property Property

owner

Title Mr Mrs Ms Dr Prof Other First Name Surname Organisation/Farm/ Business/ Village. Etc.

Position in organisation Contact Numbers

Cell phone Fax Tel

Email address Postal address Please indicate your preferred method of communication

Email SMS Post Fax




2

3. What is the land currently being used for?

4. Where are these land uses taking place?

5. Are there any natural environmental/ ecological aspects which we need to be aware of?

(water, heritage sites, grave sites, special plants or animals)

6. Where are these aspects found?

7. Do you think the project could affect / impact any structures you might have? (e.g. houses, buildings, roads, dams)

8. If so, how can these effects/ impacts be managed, avoided or fixed should they happen? Any other comments



3

Please provide contact details of any other stakeholders we should consult. Title Mr Mrs Ms Dr Prof Other First name Surname Organisation/ Property / Business

Cell phone Email Title Mr Mrs Ms Dr Prof Other First name Surname Organisation/ Farm / Business

Cell phone Email

Signature: Date:

Page | 7

APPENDIX C:


❖ Appendix C4 – Newspaper Advert

Environmental Authorisation and an Integrated Water Use Licence Application for the Reclamation of

the Marievale Tailings Storage Facilities, Ekurhuleni Metropolitan Municipality - Gauteng Province

Applicant: Ergo Mining Operations Proprietary Limited (Ergo)

Project Name: Marievale TSF Reclamation Project

Notice is hereby given that Ergo Mining (Pty) Limited (hereafter Ergo), intends to reclaim and reprocess gold residues from the Marievale tailings storage facilities (TSFs): 7L5, 7L6 and 7L7. These TSFs are historical mineral deposits (slimes dams) which were created prior to the promulgation of the Mineral and Petroleum Resources Development Act, 2002 (Act No 28 of 2002) (MPRDA) and are accordingly not regulated by the MPRDA. The combined spatial extent of the TSFs is approximately 140 Ha. The TSFs are located within City of Ekurhuleni Metropolitan Municipality (EMM) and are adjacent to the towns of Nigel and Springs in the Gauteng province.

The TSFs are positioned as follows:• Site 1: This site consists of a cluster of 7L5 and 7L6 and fall within Ward 88, covering just over 80 Hectares (Ha);• Site 2: TSF 7L7 is located approximately 1 km south of Site 1, also in Ward 88 and covers roughly 60 Ha.

In terms of the environmental legislation, Ergo is required to obtain the necessary licences and an Environmental Authorisation prior to proceeding with the reclamation process. The required licences and the Environmental Authorisation will be undertaken in accordance with the following legislation:

• Application for an Environmental Authorisation for listed activities triggered in Listing Notices GNR R983 (Activity 24 ); GNR R984 (Activity 6) and GNR 985 (Activity 4) in terms of the Environmental Impact Assessment (EIA) Regulations, 2017, as promulgated in terms of the National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA);• Application for listed waste activities in terms of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008), as amended (NEM: WA) for listed activities under GNR 921– B (2).• An Integrated Water Use Licence Application (IWULA) will be undertaken at a later stage in accordance with the National Water Act, 1998 (Act No.36 of 1998) (NWA) for water uses in terms of Section 21(c) & (i).

AVAILABILITY OF THE DRAFT SCOPING REPORT FOR PUBLIC REVIEW AND COMMENTThe Draft Scoping Report for the Marievale TSF’s reclamation and reprocessing project will be made available for public review and comment for a period of 30 days, from Wednesday, 23 October 2019 to Thursday, 21 November 2019. The report can be accessed at the following locations:

Location Physical Address Contact PersonHard copies

Dunnottar Public Library 47 Rhodes Avenue, Dunnottar Mr Shelton Mmisi (Librarian)(011) 999-9118

Kwa-Thema Public Library 7019 Nkosi Street, Kwa-Themba, Springs Ms Portia Mosetlhe (Librarian)

(011) 999 8494

Kongiwe Environmental website www.kongiwe.co.za/ public documents

Sibongile Bambisa/ Vanessa Viljoen)

For a CD copy please contact the stakeholder engagement team (Sibongile Bambisa / Vanessa Viljoen), Tel: (012) 003 6627, Email: [email protected]

INVITATION TO AN OPEN DAYInterested and Affected Parties are invited to attend an open day which will be held on Saturday, 09 November 2019, starting at 10H00 and ending at 15H00 at the Grootvaly Blesbokspruit Wetland Reserve in Welgadacht Road in Springs. The purpose of the meeting is to discuss the proposed project, contents of the Scoping Report, to provide I&APs with an opportunity to raise their concerns/comments and to interact with the project team.

To register as an I&AP please contact: Kongiwe Environmental

Contact person: Sibongile Bambisa / Vanessa Viljoen, Tel: 012 0036627, Email: [email protected]

Please ensure you submit your comments before Thursday, 21 November 2019.

SPRINGS ADVERTISER / NEWS www.springsadvertiser.co.za \ Donderdag, 24 Oktober, 20196

Rand Water has confirmed the Victor Khanye Local Municipality has signed a new payment agreement with the water supplier.

It revealed that this municipality owes Rand Water over R127-million.

Of this amount, R119-m is outstanding and the municipality must pay over R7-m by October 30.

The new payment agreement comes after the

municipality missed the September deadline, resulting in Rand Water reducing the water pressure by 40 per cent.

When asked what would happen if the municipality continued to miss its payment deadline, Rand Water spokesperson Justice Mohale says: “In terms of the Water Services Act, Rand Water cannot completely cut off water supply to a municipality.

“Therefore, the munici-pality will be kept at the basic water supply level.”

The Victor Khanye Local Municipality includes a Sundra, Delmas and Rietkol.

Residents and businesses have suffered greatly as a result of the reduced water pressure and are desperate to have their supply fully restored.

The municipality failed to respond.

Rand Water owed R127-million by Victor Khanye Local Municipality

In response to an article the Addie wrote concerning the hyacinth problem in Alexander Dam, titled Alexander Dam in a sorry state, Agnes Masilo of the metro states the following:

“The Alexander Dam is part of the City operational plans to manage and control excessive hyacinth growth.

“It should be understood that due to hyacinth reproductive behaviour, it becomes almost impossible to eradicate it completely.

“In ideal conditions, the invasive plant can double in a period of two weeks.

“In the coming weeks, spraying of the hyacinth will be done to manage the growth.

“In addition, the Watermaster machine will be deployed to undertake physical removal.”

She adds: “No contractor has currently been hired.

“Currently, the received bids are being evaluated and the process has not yet been concluded.”

Regarding the allegations of sewage being dumped in the dam, Masilo says: “We are not aware of the alleged sewage dumping at Alexander Dam.

“We, however, appeal to the community to take pictures, which could identify the trucks that may be involved.”

Masilo concludes: “The major challenge with the hyacinth is that it is a category one plant that needs to be controlled wherever it occurs.

“This means the metro is obliged to intervene wherever the plant occurs.

“Currently, there are a number of water bodies where the problem is prevalent and it becomes a challenge to attend to all the areas at the same time.”

Metro addresses Alexander Dam problems

New community hall opened in Welgedacht

The communities of Welgedacht, Payneville and Slovo Park, have a new meeting place after the Welgedacht community hall was officially opened last Thursday morning.

The hall comes after a three-year wait by the communities who initially petitioned for it in 2016.

One of the things the communities complained about was the lack of sporting facilities in the area.

What is now the hall had been taken over by vagrants, and after the metro evicted them, the Department of Sport, Arts and Recreation thought it would be the perfect meeting spot for people in the community.

“The renovations

started in June and the plan was to give it back to the community to use as necessary.

“For now there is no charge to use the hall, but it is regulated for use by our by-laws.

“The hall is just the beginning of what we hope to do with this space (which includes netball courts).

“We will do some profiling in the area to find out what sporting activities take place in the area.

“We will look at what their needs are in terms of sports and recreation, and find out what the community wants, instead of us just planning for them because if we do that, they won’t take ownership of the place,”

says Matshidiso Mohlabane, the divisional head: sport, culture and recreation.

Mohlabane says they hope to cater for all groups in the community.

Community leader Kutlwano Strawberry Ngema says the community is happy to have the hall and grateful to the metro.

“We can now have indoor sports for our children such as karate and aerobics which we have already started using the hall for,” says Ngema.

Alderman Dean Stone was also impressed by what he saw and says the people of Welgedacht, Slovo and Payneville really needed the hall as they have no communal meeting place.

The new hall in Welgedacht was opened for business last Thursday morning. Seen here are members of the Ward committee, ��Department of Sports, Culture and Recreation and community leaders.

Victor Khanye Local Municipality must pay Rand Water R7-million by October 30



Notice is hereby given that Ergo Mining (Pty) Limited (hereafter Ergo), intends to reclaim and reprocessgold residues from the Marievale tailings storage facilities (TSFs): 7L5, 7L6 and 7L7. These TSFs arehistorical mineral deposits (slimes dams) which were created prior to the promulgation of the Mineraland Petroleum Resources Development Act, 2002 (Act No 28 of 2002) (MPRDA) and are accordinglynot regulated by the MPRDA. The combined spatial extent of the TSFs is approximately 140 Ha. TheTSFs are located within City of Ekurhuleni Metropolitan Municipality (EMM) and are adjacent to thetowns of Nigel and Springs in the Gauteng province.

The TSFs are positioned as follows:• Site 1: This site consists of a cluster of 7L5 and 7L6 and fall within Ward 88, covering just over 80Hectares (Ha);

• Site 2: TSF 7L7 is located approximately 1 km south of Site 1, also in Ward 88 and covers roughly 60 Ha.

In terms of the environmental legislation, Ergo is required to obtain the necessary licences and anEnvironmental Authorisation prior to proceeding with the reclamation process. The required licencesand the Environmental Authorisation will be undertaken in accordance with the following legislation:

• Application for an Environmental Authorisation for listed activities triggered in Listing NoticesGNR R983 (Activity 24); GNR R984 (Activity 6) and GNR 985 (Activity 4) in terms of theEnvironmental Impact Assessment (EIA) Regulations, 2017, as promulgated in terms of the NationalEnvironmental Management Act, 1998 (Act No. 107 of 1998) (NEMA);

• Application for listed waste activities in terms of the National Environmental Management: WasteAct, 2008 (Act No. 59 of 2008), as amended (NEM:WA) for listed activities under GNR 921– B (2).

• An IntegratedWater Use Licence Application (IWULA) will be undertaken at a later stage inaccordance with the National Water Act, 1998 (Act No. 36 of 1998) (NWA) for water uses in terms ofSection 21(c) & (i).

AVAILABILITY OF THE DRAFT SCOPING REPORT FOR PUBLIC REVIEW AND COMMENTThe Draft Scoping Report for the Marievale TSF’s reclamation and reprocessing project will be madeavailable for public review and comment for a period of 30 days, from Wednesday, 23 October 2019 toThursday, 21 November 2019. The report can be accessed at the following locations:

Location Physical Address Contact PersonHard copies

Dunnottar Public Library 47 Rhodes Avenue, Dunnottar Mr Shelton Mmisi (Librarian)(011) 999-9118

Kwa-Thema Public Library 7019 Nkosi Street,Kwa-Themba, Springs

Ms Portia Mosetlhe (Librarian)(011) 999 8494

Electronic copies

Kongiwe Environmental website www.kongiwe.co.za/ publicdocuments

Sibongile Bambisa/Vanessa Viljoen)

For a CD copy please contact the stakeholder engagement team (Sibongile Bambisa /Vanessa Viljoen), Tel: (012) 003 6627, Email: [email protected]

INVITATION TO AN OPEN DAYInterested and Affected Parties are invited to attend an open day which will be held on Saturday, 09November 2019, starting at 10H00 and ending at 15H00 at the Grootvaly Blesbokspruit WetlandReserve in Welgadacht Road in Springs. The purpose of the meeting is to discuss the proposedproject, contents of the Scoping Report, to provide I&APs with an opportunity to raise their concerns/comments and to interact with the project team.

To register as an I&AP please contact:Kongiwe Environmental

Contact person: Sibongile Bambisa / Vanessa Viljoen, Tel: 012 003 6627,Email: [email protected]

Please ensure you submit your comments before Thursday, 21 November 2019.

Environmental Authorisation and an Integrated Water Use Licence Application for the Reclamation of the

Marievale Tailings Storage Facilities, C ity of Ekurhuleni Metropolitan Municipality - Gauteng Province



Kongiwe Environmental (Pty) Ltd (Kongiwe) hereby gives notice that the Draft Environmental Impact Assessment Report (EIA) and the Draft Environmental Management Programme (EMPr) reports for the proposed Reclamation of the Marievale Tailings Storage Facilities (TSF) Project will be made available for public review and comment. The Draft EIA/EMPr reports have been compiled and will be made available for a 30-day public review and comment period from Thursday, 19 March 2020 to Tuesday, 21 April 2020.

The abovementioned reports will be made available at the following places:

LOCATION PHYSICAL ADDRESS CONTACT PERSON

Hard copies

Dunnottar Public Library 47 Rhodes Avenue, Dunnottar Mr Shelton Mnisi (Librarian) (011) 999 9118

Kwa-Thema Public Library 7019 Nkosi Street, Kwa-Thema, Springs

Ms Portia Mosetlhe (Librarian) (011) 999 8494


R42 Delmas Road, Marievale Nature Reserve, Nigel

Mr Rhulani Maluleke, Manager (071) 258 6518

Electronic copies

Kongiwe Environmental website

www.kongiwe.co.za/ public documents

Sibongile Bambisa/Vanessa Viljoen

For a CD copy please contact the stakeholder engagement team (Sibongile Bambisa / Vanessa Viljoen), Tel: (012) 003 6627, Email: [email protected]

CANCELLATION OF THE OPEN DAY

In light of the announced ban on public gatherings to curb the spread of COVID-19 and in line with the Presidential address of 15 March 2020, we would like to inform you that the proposed open day for the Marievale project has been cancelled indefinitely. Stakeholders are encouraged to review the reports and submit written comments to Kongiwe’s stakeholder engagement team.

For any queries please contact our stakeholder engagement team:

Kongiwe Environmental (Pty) LtdContact person: Sibongile Bambisa / Vanessa Viljoen, Tel: (012) 003 6627, Email: [email protected]

Jonti 1 2493

Thursday 19 March, 2020 \ www.springsadvertiser.co.za 17NEWS \ SPRINGS ADVERTISER

These events have been postponed or cancelledFollowing president Cyril Ramaphosa’s speech on Sunday, in which he said: “The world is in the throes of a public health emergency on a scale not witnessed in over a century”, a number of planned events have either been cancelled or postponed.

• Caxton Local Media, of which Springs Advertiser is part, has taken the decision to postpone our fi rst car boot sale.

While we were very excited to see what you all had to off er from the boot of your cars, we will be heading the president’s prohibition of gatherings involving more than 100 people.

We will, however, let our readers know as soon as a new date has been set and we look forward to seeing you all at our fi rst car boot sale.

• Craig Newman, CEO Johannesburg Expo Centre and Rand Show director, announced on Monday, “in the best interest of our community, we have decided to postone the (Rand) show.

“The event will be rescheduled at a later stage and will be done in consensus with government.”

• Lefra announced on Tuesday that they have decided to postpone the Smokie In South Africa concerts.

The concerts were due to be held at the end of this month and Lefra has announced, tentatively, that they hope to host the group in June this year instead.

Ticketholders will have their tickets validated for the concert when the group does come to South Africa.

If you have purchased a ticket visit www.smokie.co.za for any updates.

• Big Concerts has announced that

the Lighthouse Family tour has been postponed and tickets will remain valid for the rescheduled dates which will be announced in due course.

• The 2020 Pink Loerie Mardi Gras has been postponed, tentatively, to September 24 to 27.

Depending on the trajectory of the virus, the organisers will confi rm these dates on their website www.pinkloerie.co.za

Soth ̀ Africa s D een, S elle, as d e to be at this ear.s and Sho

SINGLE: R8 450 PER PERSONSHARING: R6 450 PER PERSON prices including VAT

FIND OUT MORE AT:farmersweekly.co.za/tour-and-eventsBOOKINGS CLOSE ON 17 APRIL 2020.

TOUR SPONSOR

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NAMPO HARVEST DAY, BOTHAVILLE, FREE STATE, SOUTH AFRICAJoin the Farmer’s Weekly tour to Nampo Harvest Day, Africa’s premieragricultural show, to experience the best that South African agriculture has tooffer. The tour includes farm visits to two commercial producers, and presentsdelegates with the perfect opportunity to network with other like-mindedbusiness and farming role players.

Environmental Authorisation and an Integrated WaterUse Licence Application for the Reclamation of the

Marievale Tailings Storage Facilities, City of EkurhuleniMetropolitan Municipality - Gauteng Province



Kongiwe Environmental (Pty) Ltd (Kongiwe) hereby gives notice that the Draft Environmental

Impact Assessment Report (EIA) and the Draft Environmental Management Programme (EMPr)

reports for the proposed Reclamation of the Marievale Tailings Storage Facilities (TSF) Project

will be made available for public review and comment. The Draft EIA/EMPr reports have been

compiled and will be made available for a 30-day public review and comment period from

Thursday, 19 March 2020 to Tuesday, 21 April 2020.

The abovementioned reports will be made available at the following places:


Hard copies

Dunnottar Public Library 47 Rhodes Avenue, DunnottarMr Shelton Mnisi (Librarian)

(011) 999 9118

Kwa-Thema Public Library7019 Nkosi Street,

Kwa-Thema, SpringsMs Portia Mosetlhe (Librarian)

(011) 999 8494

Marievale Bird SanctuaryProvincial Nature Reserve

R42 Delmas Road, MarievaleNature Reserve, Nigel

Mr Rhulani Maluleke, Manager(071) 258 6518

Electronic copies

Kongiwe Environmentalwebsite

www.kongiwe.co.za/public documents

Sibongile Bambisa/Vanessa Viljoen

For a CD copy please contact the stakeholder engagement team (Sibongile Bambisa / Vanessa Viljoen),Tel: (012) 003 6627, Email: [email protected]


In light of the announced ban on public gatherings to curb the spread of COVID-19 and in line with

the Presidential address of 15 March 2020, we would like to inform you that the proposed open day

for the Marievale project has been cancelled indefinitely. Stakeholders are encouraged to review

the reports and submit written comments to Kongiwe’s stakeholder engagement team.

For any queries please contact our stakeholder engagement team:

Kongiwe Environmental (Pty) Ltd

Contact person: Sibongile Bambisa / Vanessa Viljoen,

Tel: (012) 003 6627, Email: [email protected]

onti

CORON AHow it spreads:

Page | 8

APPENDIX C:


❖ Appendix C5 – Site Notice Report and Map

Ergo Mining Operations (Pty) Ltd: The Reclamation of Marievale TSFs Site Notice Report

2019 Kongiwe Environmental (Pty) Ltd

1

Environmental Authorisation and an Integrated Water Use Licence Application for the Reclamation of the Marievale Tailings

Storage Facilities, Ekurhuleni Metropolitan Municipality - Gauteng Province

Site Notice Placement Report – Marievale

Tuesday, 29 October 2019

Site

Notice

Number

Location Co-ordinates Photo

1. Dunnottar Public

Library, 47 Rhodes

Avenue, Dunnottar.

S: 26° 20’ 50.633"

E: 28° 25’ 41.293"

2. Kwa-Thema Public

Library, 7019 Nkosi

Street, Kwa-

Themba, Springs.

S: 26° 17' 43.32"

E: 28° 23' 23.50"

3. Marievale Nature

Reserve Bird

Sanctuary, Nigel

Delmas Rd, Greater

Nigel, Nigel, 1590.

S: 26°21'27.36"

E: 28°30'55.799"

Ergo Mining Operations (Pty) Ltd: The Reclamation of Marievale TSFs Site Notice Report

2019 Kongiwe Environmental (Pty) Ltd

2

Site

Notice

Number

Location Co-ordinates Photo

4. Cnr of Nigel

Marievale Rd and

Unnamed Road,

Marievale.

S: 26° 21' 12.88 "

E: 28° 29' 7.21"

5. Blesbok Shooting

Range, Plover St,

Struisbult, Springs,

1560.

S: 26° 19' 7.79 "

E: 28° 29' 36.01"

6. Oasis Café, 7

Fluoride Street,

Daggafontein,

Springs, 1559.

S: 26° 17' 49.73"

E: 28° 28' 34.13"

Page | 9

APPENDIX C:


❖ Appendix C6 – Announcement Notifications

1

Vanessa Viljoen

From: Kongiwe Stakeholder Engagement <[email protected]>Sent: Wednesday, 16 October 2019 15:31To: [email protected]: Environmental Authorisation and an Integrated Water Use Licence Application for the

Reclamation of the Marievale Tailings Storage Facilities, Ekurhuleni Metropolitan Municipality

Attachments: Ergo_BID_Marievale_15102019_Combined_Final.pdf

Dear Stakeholders

This email serves to inform you that Ergo Mining (Pty) Limited (hereafter Ergo), intends to reclaim and reprocess gold residues from the Marievale tailings storage facilities (TSFs): 7L5, 7L6 and 7L7. These TSFs are historical mineral deposits (slimes dams) which were created prior to the promulgation of the Mineral and Petroleum Resources Development Act, 2002 (Act No 28 of 2002) (MPRDA) and are accordingly not regulated by the MPRDA. The combined spatial extent of the TSFs is approximately 140 Ha. The TSFs are located within City of Ekurhuleni Metropolitan Municipality (EMM) and are adjacent to the towns of Nigel and Springs in the Gauteng province.

AVAILABILITY OF THE SCOPING REPORT FOR PUBLIC REVIEW AND COMMENT The Draft Scoping Report will be made available for public review and comment for a period of 30 days, from Wednesday, 23 October 2019 to Thursday, 21 November 2019. INVITATION TO AN OPEN DAY Interested and Affected Parties (I&APs) are invited to attend an Open Day which will be held on Saturday, 09 November 2019, starting at 10H00 and ending at 15H00 at the Grootvaly Blesbokspruit Wetland Reserve in Welgadacht Road in Springs. The purpose of the open day is to discuss the proposed project, contents of the Scoping Report and also to provide I&APs with an opportunity to raise their concerns/comments. Any person affected by or who may be interested in the proposed project is asked to register as an I&AP by completing the attached reply sheet or by contacting the stakeholder engagement team. Contact person: Sibongile Bambisa/Vanessa Viljoen, Email: [email protected], Tel: (012) 003 6627. For more information, please refer to the attached Background Information Document. Kind Regards,



1


From: Kongiwe Stakeholder Engagement <[email protected]>Sent: Monday, 04 November 2019 16:00To: 'Sibongile Bambisa'; 'Bradly Thornton'Subject: REMINDER: Environmental Authorisation and an Integrated Water Use Licence

Application for the Reclamation of the Marievale Tailings Storage Facilities, Ekurhuleni Metropolitan Municipality

Attachments: Ergo_BID_Marievale_15102019_Combined_Final.pdf

TrackingTracking: Recipient Read

'Sibongile Bambisa'

'Bradly Thornton'

Sibongile Bambisa Read: 2019/11/04 16:19

Dear Stakeholders

This email serves as an reminder that Ergo Mining (Pty) Limited (hereafter Ergo), intends to reclaim and reprocess gold residues from the Marievale Tailings Storage Facilities (TSFs): 7L5, 7L6 and 7L7. These TSFs are historical mineral deposits (slimes dams) which were created prior to the promulgation of the Mineral and Petroleum Resources Development Act, 2002 (Act No 28 of 2002) (MPRDA). The combined extent of the TSFs is approximately 140 Ha. The TSFs are located within City of Ekurhuleni Metropolitan Municipality (EMM) and are adjacent to the towns of Nigel and Springs in the Gauteng province.

AVAILABILITY OF THE SCOPING REPORT FOR PUBLIC REVIEW AND COMMENT The Draft Scoping Report is available for public review and comment for a period of 30 days, from Wednesday, 23 October 2019 to Thursday, 21 November 2019. INVITATION TO AN OPEN DAY Interested and Affected Parties (I&APs) are invited to attend an Open Day which will be held on Saturday, 09 November 2019, starting at 10H00 and ending at 15H00 at the Grootvaly Blesbokspruit Wetland Reserve in Welgadacht Road in Springs. The purpose of the open day is to discuss the proposed project, contents of the Scoping Report and also to provide I&APs with an opportunity to raise their concerns/comments. Any person affected by or who may be interested in the proposed project is asked to register as an I&AP by completing the attached reply sheet or by contacting the stakeholder engagement team. Contact person: Sibongile Bambisa/Vanessa Viljoen, Email: [email protected], Tel: (012) 003 6627. For more information, please refer to the attached Background Information Document. Kind Regards,


2


1


From: Kongiwe Stakeholder Engagement <[email protected]>Sent: Friday, 13 March 2020 10:02To: '[email protected]'Subject: Reclamation of the Marievale Tailings Storage Facilities Project: Availability of the Draft

EIA/EMPrAttachments: Marievale_DEIR Notification Letter_13 March 2020.pdf

TrackingTracking: Recipient Read

'[email protected]'

'[email protected]'

'[email protected]'

'[email protected]'

'[email protected]'

'[email protected]'

'[email protected]'

'[email protected]'

'[email protected]'

'[email protected]'

'[email protected]'

'[email protected]'

'[email protected]'

'[email protected]'

'[email protected]'

'[email protected]'

Vanessa Viljoen Read: 2020/03/13 10:27

Victoria Bota (HO) Read: 2020/03/13 11:05

Dear Stakeholders Kongiwe Environmental (Pty) Ltd (Kongiwe) hereby gives notice that the Draft Environmental Impact Assessment (EIA) report / Draft Environmental Management Programme report (DEIR/EMPr) for the proposed Reclamation of the Marievale Tailings Storage Facilities Project will be made available for public review and comment. The Draft EIA/EMPr reports have been compiled and will be made available for a 30-day public review and comment period from Thursday, 19 March 2020 to Tuesday, 21 April 2020. INVITATION TO AN OPEN DAY Stakeholders are invited to attend an Open day which will be held on Saturday, 04 April 2020 from 10:00 to 14:00 at the Marievale Bird Sanctuary Nature Reserve. The purpose of the Open day is to discuss the Draft EIA and EMPr, present findings from the specialist studies, provide stakeholders with a platform to raise comments/concerns on the Draft EIA and EMPr reports and interact with the project team. Please confirm your attendance at the meeting by Monday, 30 March 2020.

2

Any person affected by or who may be interested in the proposed project is asked to register as an I&AP by contacting the stakeholder engagement team. Contact person: Sibongile Bambisa/Vanessa Viljoen: [email protected], Tel: (012) 003 6627. Kind Regards,




Friday, 13 March 2020

Environmental Authorisation and an Integrated Water Use Licence Application for the Reclamation of the Marievale Tailings Storage Facilities, City of Ekurhuleni Metropolitan

Municipality - Gauteng Province

DMR Reference number: GP 30/5/1/1/2 (000007BP) BAR

Availability of the Draft Environmental Impact Assessment Report and Environmental Management Programme

Dear Stakeholder

Kongiwe Environmental (Pty) Ltd (Kongiwe) hereby gives notice that the Draft Environmental Impact

Assessment (EIA) report / Draft Environmental Management Programme report (DEIR/EMPr) for the

proposed Reclamation of the Marievale Tailings Storage Facilities Project will be made available for public

review and comment.

The purpose of this document is to provide you with important information regarding the following:

❖ The availability of the Draft EIA Report and Draft EMPr Reports.

❖ How you can provide comments on the Draft EIA/EMPr, and

❖ An invitation to an Open Day.

AVAILABILITY OF THE DRAFT EIA AND EMPr

The Draft EIA/EMPr reports have been compiled and will be made available for a 30-day public review and

comment period from Thursday, 19 March 2020 to Tuesday, 21 April 2020.

The above-mentioned reports will be made available at the following places:


Hard copies

Dunnottar Public Library 47 Rhodes Avenue, Dunnottar Mr Shelton Mnisi (Librarian)

(011) 999 9118


Ms Portia Mosetlhe (Librarian)

(011) 999 8494




Electronic copies

Kongiwe Environmental website www.kongiwe.co.za/ public

documents

Sibongile Bambisa/ Vanessa Viljoen,

Tel: (012) 003 6627

For a CD copy please contact the stakeholder engagement team (Sibongile Bambisa/ Vanessa Viljoen), Tel: (012) 003

6627, Email: [email protected]





2

YOU CAN COMMENT ON THE DRAFT EIA AND EMPr IN ANY OF THE FOLLOWING WAYS:

❖ By providing comments at the Open day-please see details below;

❖ By writing a letter or sending an email to [email protected];

❖ By contacting our stakeholder engagement team on (012) 003 6627, (contact person: Sibongile

Bambisa/ Vanessa Viljoen).

INVITATION TO AN OPEN DAY

Stakeholders are invited to attend an Open day which will be held on Saturday, 04 April 2020 from 10:00 to

14:00 at the Marievale Bird Sanctuary Nature Reserve. The purpose of the Open day is to discuss the Draft

EIA and EMPr, present findings from the specialist studies, provide stakeholders with a platform to raise

comments/concerns on the Draft EIA and EMPr reports and interact with the project team. Please confirm

your attendance at the meeting by Monday, 30 March 2020.

Any person affected by or who may be interested in the proposed project is requested to register as an

Interested and Affected party by sending an email to [email protected] alternatively you can

contact Sibongile Bambisa/Vanessa Viljoen on (012) 003 6627. Our team welcomes your participation and

looks forward to your involvement throughout this process.

Yours faithfully,

Sibongile Bambisa

Stakeholder Engagement / Social Consultant




Monday, 17 March 2020





Cancellation of the proposed Open day Dear Stakeholder

Kongiwe Environmental (Pty) Ltd (Kongiwe) hereby gives notice that the Draft Environmental Impact

Assessment (EIA) report / Draft Environmental Management Programme report (DEIR/EMPr) for the

proposed Reclamation of the Marievale Tailings Storage Facilities Project will be made available for public

review and comment.

AVAILABILITY OF THE DRAFT EIA AND EMPr

The Draft EIA/EMPr reports have been compiled and will be made available for a 30-day public review and

comment period from Thursday, 19 March 2020 to Tuesday, 21 April 2020.



Hard copies


(011) 999 9118



(011) 999 8494




Electronic copies


documents


Tel: (012) 003 6627










2

❖ By writing a letter and mail it to: PostNet Suite no 163, Private Bag X21, Bryanston, 2021, South Africa.




In light of the announced ban on public gatherings to curb the spread of COVID-19 and in line with the

Presidential address of 15 March 2020, we would like to inform you that the proposed open day for the

Marievale project has been cancelled indefinitely. Stakeholders are encouraged to review the reports and

submit written comments to Kongiwe’s stakeholder engagement team, please refer to the abovementioned

methods on how you can comment on the Draft EIA/EMPr.

For any queries please contact our stakeholder engagement team: Sibongile Bambisa/Vanessa Viljoen on

(012) 003 6627, Email: [email protected], Tel: (012) 003 6627. Our team welcomes your

participation and looks forward to your involvement throughout this process.

Yours faithfully,

Sibongile Bambisa




Wednesday, 01 April 2020





Extension of the public review and comment period Dear Stakeholder

Kongiwe Environmental (Pty) Ltd (Kongiwe) hereby gives notice that the public review and comment period

of the Draft Environmental Impact Assessment report / Draft Environmental Management Programme report

(DEIR/EMPr) for the proposed Reclamation of the Marievale Tailings Storage Facilities Project has been

extended.

In accordance with Regulation GN R439 of 31 March 2020, the Minister of Forestry, Fisheries and the

Environment, acting in terms of the Regulations issued in terms of section 27(2) of the Disaster Management

Act, 2002, has extended the timeframes prescribed in terms of the Environmental Impact Assessment

Regulations 2014, the National Environmental Management: Waste Act, 2008 and National Environmental

Management: Air Quality Act, 2004, by the number of days of the duration of the lockdown period of the

national state of disaster declared for the COVID-19 pandemic, including any extensions to such duration, with

effect from 27 March 2020 until the termination of the lockdown period.

Availability of the Draft EIA/EMPr reports: Revised public review and comment period

In light of the above, the Draft EIA/EMPr reports for the proposed Marievale project will be made available for

public review and comment until Thursday, 14 May 2020.



Hard copies


(011) 999 9118

Kwa-Thema Public Library

7019 Nkosi Street, Kwa-Thema, Springs


(011) 999 8494






2

Electronic copies


documents


Tel: (012) 003 6627











Yours faithfully,

Sibongile Bambisa







16 April 2020





Extension of the public review and comment period: COVID-19 Dear Stakeholder

Kongiwe Environmental (Pty) Ltd (Kongiwe) hereby gives notice that the public review and comment period

of the Draft Environmental Impact Assessment report / Draft Environmental Management Programme report

(DEIR/EMPr) for the proposed Reclamation of the Marievale Tailings Storage Facilities Project has been further

extended.

In accordance with Regulation GN R439 of 31 March 2020, the Minister of Forestry, Fisheries and the

Environment, acting in terms of the Regulations issued in terms of section 27(2) of the Disaster Management

Act, 2002, has extended the timeframes prescribed in terms of the Environmental Impact Assessment

Regulations 2014, the National Environmental Management: Waste Act, 2008 and National Environmental

Management: Air Quality Act, 2004, by the number of days of the duration of the lockdown period of the

national state of disaster declared for the COVID-19 pandemic, including any extensions to such duration, with

effect from 27 March 2020 until the termination of the lockdown period. In light of the extension of the

lockdown Kongiwe needs to extend the comment period by an additional 14 days.

Availability of the Draft EIA/EMPr reports: Revised public review and comment period

In light of the above, the Draft EIA/EMPr reports for the proposed Marievale project will be made available for

public review and comment until Thursday, 28 May 2020.



Hard copies


(011) 999 9118


7019 Nkosi Street, Kwa-Thema, Springs


(011) 999 8494






2

Electronic copies


documents


Tel: (012) 003 6627











Yours faithfully,

Sibongile Bambisa






Page | 10

APPENDIX C:


❖ Appendix C7 – Organs of State Correspondence

1


Distribution of the Draft Scoping Report Organisation Physical address and contact details Number of copies to be delivered Delivery Method

Department of Mineral Resources and Energy

78 De Korte Street, 1st Floor Mineralia Building, Braamfontein. Contact person: Ms Nkosinathi Mahlaba/ Ms Mashudu Maduka (011) 358 9741 (Environmental Division)

3 hard copies of the Draft Scoping Report 1 Electronic copy (CD)

Hand delivery

Department of Human Settlements, Water and Sanitation

285 Francis Baard Street Bothongo Plaza East, Pretoria Contact person: Ms Barbara Kalembo (082) 896 8221

1 Electronic copy (CD) Online submission & Courier

National Nuclear Regulator Eco Glades 2, Block G, 420 Witch-Hazel Avenue, Centurion. Contact person: Mr Patle Mohajane (012) 674 7130

1 Electronic copy (CD) Hand delivery (VV will deliver in Centurion)

Department of Environmental Affairs

Cnr. Steve Biko (previously Beatrix Street) and Soutpansberg Road, Environment House 473 Steve Biko, Arcadia, Pretoria Contact person: Ms Phumeza Skepe

1 Electronic copy (CD) Courier

Gauteng Department of Agriculture and Rural Development (GDARD)

Admin, Ground Floor-Annex Building, 56 Eloff Street, Johannesburg CBD, Contact person: Administration Unit

1 hard copy of the Draft Scoping Report 2 Electronic copies (CD)

Courier

City of Ekurhuleni Metropolitan Municipality

Edenvale Customer Care Centre Cnr Hendrick Potgieter and Van Riebeeck Avenue Edenvale Office no. 201/205/214 First Floor Attention: Mr Thabang Mokoena / Ms Cecilia Rakgoale Division Head: Legislative Governance and Compliance Environmental Resource and Waste Management Department Tel: (011) 999 3316/3376/2006

1 hard copy of the Draft Scoping Report 3 Electronic copy (CD)

Courier

2

SAHRA SAHRIS Online submission Online submission (SB)

National Department of Health

P1 Public and Health, 45 Commissioner Street, Johannesburg Contact person: Ms Mary Madaure Acting Environmental Manager (072) 230 2849



R42, Marievale Road, Extension, Nigel, Gauteng, 1590 Contact person: Mr Rhulani Maluleke (071) 258 6518



Plot 42 A, Newby Street, Grootvaly, Agricultural Holdings, Springs Contact person: Mr Philip De Jager Cell: (083) 454 8868 Email: [email protected]


JHB Health District

Hillbrow Community Health Centre, Admin Block FF1, Cnr Klein street and Smit street, Hillbrow, Johannesburg Contact person: Ms Crystal Rosenberg Environmental Health Practitioner Cell: (082) 384 5191


Department of Public Works and Infrastructure (DPWI)

78 Dekorte Street, Braamfontein Contact person: Ms Jeanette Monare, Regional Manager Cell: (083) 635 0760


Department of Agriculture, Forestry and Fisheries (DAFF)

Cnr Annie Botha & Union Street, Pretoria Contact person: Ms Mulalo Sundani Environmental Impact Management (076) 021 6115


Dunnottar Public Library

47 Rhodes Avenue, Dunnottar Mr Shelton Mmisi (Librarian) (011) 999 9118

1 hard copy of the Draft Scoping Report Hand delivery


7019 Nkosi Street, Kwa-Themba, Springs

1 hard copy of the Draft Scoping Report

Hand delivery

3

Ms Portia Mosetlhe (Librarian) (011) 999 8494

Kongiwe Website

- Upload onto website Upload onto website

Hard copies to be printed and distributed: 7 Hard copies of the Draft Scoping Report and 15 CDs.

Tasmin Van Rensburg TAX INVOICE / ePOD 1Fetch (Pty) Ltd0723395354 INV-050389 Registration No: 2015/067029/07Company: Kongiwe Environmental PtyLtd

22 October 2019 VAT No: 4780273993Morningside Corner Office ParkCnr 3rd Avenue & Rivonia Road2196Tel No: 086 111 2710Email: [email protected]

Order Number 1F52452 Gross (Exclusive) R 384.87Order Date 22 October 2019 13:26 Discount - R 0.00Payment Type Cash Total (Exclusive) R 384.87Service Type On-demand Delivery Services VAT R 57.73Total Distance 25.7km Total (ZAR) R 442.60

Address 1 Detail

Location 150 Bryanston Dr, Bryanston, Sandton, 2191, South Africa

Contact Name TasminContact Number (072) 339-5354

Notes Please come to Kongiwe

Collected From/Delivered To TasminDate 22 October 2019Time 14:40Driver AndileNumber of Packages 1Barcode(s) Scanned NoCoordinates at collection/delivery -26.0475231, 28.0214828Address at collection/delivery 150 Bryanston Dr, Bryanston, Sandton, 2191, South Africa

Proof of Collection/Delivery Signature

Photo

Address 2 Detail

Location GAUTENG DEPARTMENT OF AGRICULTURE AND RURALDEVELOPMENT, 56 Eloff St, Johannesburg, 2000, South Africa

Contact Name Administration UnitContact Number (011) 240-2500

Notes

Please hand to administration unit. 1 hard copy of the Draft Scoping Report 2 Electronic copies (CD)

Collected From/Delivered To ZaneleDate 22 October 2019Time 15:19Driver AndileNumber of Packages 1Barcode(s) Scanned NoCoordinates at collection/delivery -26.2061714, 28.0444065Address at collection/delivery Elloff & Market, Marshalltown, Johannesburg, 2107, South Africa


Photo

Address 3 Detail

Location 45 Commissioner St, Johannesburg, 2000, South Africa

Contact Name Ms Mary Madaure, Acting Environmental ManagerContact Number (072) 230-2849

Notes

P1 Public and Health, 45 Commissioner Street, Johannesburg Contact person: Ms Mary Madaure Acting Environmental Manager (072) 230 2849 1 Electronic copy (CD)

Collected From/Delivered To dimakatsoDate 22 October 2019Time 15:40Driver AndileNumber of Packages 1Barcode(s) Scanned NoCoordinates at collection/delivery -26.2058307, 28.036369Address at collection/delivery 52 Commissioner St, Marshalltown, Johannesburg, 2107, South Africa


Photo

Address 4 Detail

Location Hillbrow Community Health Centre, Klein St, Johannesburg, 2000,South Africa

Contact Name Crystal RosenbergContact Number (082) 384-5191

Notes

Contact person: Ms Crystal RosenbergEnvironmental Health Practitioner Cell: (082) 384 5191 1 Electronic copy (CD)

Collected From/Delivered To DumisoDate 22 October 2019Time 16:12Driver AndileNumber of Packages 1Barcode(s) Scanned NoCoordinates at collection/delivery -26.1942921, 28.045745Address at collection/delivery 268 Smit St, Johannesburg, 2000, South Africa


Photo

Address 5 Detail

Location 78 De Korte St, Johannesburg, 2000, South Africa

Contact Name Ms Jeanette MonareContact Number (083) 635-0760

Notes

Department of Public Works and Infrastructure (DPWI)78 DekorteStreet, Braamfontein Contact person: Ms Jeanette Monare, Regional Manager Cell: (083) 635 0760 1 Electronic copy (CD)

Collected From/Delivered To FloraDate 22 October 2019Time 16:31Driver AndileNumber of Packages 1Barcode(s) Scanned NoCoordinates at collection/delivery -26.1937024, 28.0352461Address at collection/delivery 82 De Korte St, Johannesburg, 2000, South Africa


Photo

Tasmin Van Rensburg TAX INVOICE / ePOD 1Fetch (Pty) Ltd0723395354 INV-050391 Registration No: 2015/067029/07Company: Kongiwe Environmental PtyLtd

22 October 2019 VAT No: 4780273993Morningside Corner Office ParkCnr 3rd Avenue & Rivonia Road2196Tel No: 086 111 2710Email: [email protected]

Order Number 1F52454 Gross (Exclusive) R 199.66Order Date 22 October 2019 13:36 Discount - R 0.00Payment Type Cash Total (Exclusive) R 199.66Service Type On-demand Delivery Services VAT R 29.95Total Distance 20.7km Total (ZAR) R 229.61

Address 1 Detail

Location 150 Bryanston Dr, Bryanston, Sandton, 2191, South Africa

Contact Name Ashleigh BlackwellContact Number (079) 895-1456

Notes Please come to Kongiwe

Collected From/Delivered To tasminDate 22 October 2019Time 14:28Driver IrvineNumber of Packages 4Barcode(s) Scanned NoCoordinates at collection/delivery -26.0475264, 28.0214876Address at collection/delivery 150 Bryanston Dr, Bryanston, Sandton, 2191, South Africa


Photo

Address 2 Detail

Location Van Riebeeck Avenue, Van Riebeeck Ave, Edenvale, South Africa

Contact Name Mr Thabang Mokoena / Ms Cecilia RakgoaleContact Number (011) 999-3316

Notes

City of Ekurhuleni Metropolitan MunicipalityCnr Hendrick Potgieterand Van Riebeeck Avenue Edenvale Office no. 201/205/214 First Floor Attention: Mr Thabang Mokoena / Ms Cecilia Rakgoale Division Head: Legislative Governance and Compliance Environmental Resource and Waste Management Department Tel: (011) 999 3316/3376/2006 1 hard copy of the Draft Scoping Report 3 Electronic copy (CD)

Collected From/Delivered To Cecilia rakgoaleDate 22 October 2019Time 16:03Driver IrvineNumber of Packages 4Barcode(s) Scanned NoCoordinates at collection/delivery -26.1398236, 28.1530663Address at collection/delivery 79 10th Ave, Edenvale, 1609, South Africa


Photo

1

Environmental Authorisation and an Integrated Water Use Licence Application for the Reclamation of the Marievale Tailings Storage Facilities, City Ekurhuleni Metropolitan Municipality - Gauteng Province

Distribution of the Final Scoping Report Organisation Physical address and contact details Number of copies to be delivered Delivery Method


78 De Korte Street, 1st Floor Mineralia Building, Braamfontein. Contact person: Mr Musa Mangobe (Environmental Division) Contact number: (011) 358 9700

3 hard copies of the Final Scoping Report 1 Electronic copy (CD)

Hand delivery


285 Francis Baard Street Bothongo Plaza East, Pretoria Contact person: Ms Barbara Kalembo Contact number: (082) 896 8221

1 Electronic copy (CD) Online submission & Hand delivery

National Nuclear Regulator

Eco Glades 2, Block G, 420 Witch-Hazel Avenue, Centurion. Contact person: Mr Patle Mohajane Contact number: (012) 674 7130

1 Electronic copy (CD) Hand delivery (VV will deliver in Centurion)

Department of Environment Forestry and Fisheries (Previously known as the Department of Environmental Affairs)

Cnr. Steve Biko (previously Beatrix Street) and Soutpansberg Road, Environment House 473 Steve Biko, Arcadia, Pretoria Contact person: Dr Mpho Tshitangoni, Chief Director Contact number: (012) 399 9793 Or Contact person: Mr Lucas Mahlangu Contact number: (012) 399 9791

1 Electronic copy (CD) Hand delivery


Admin, Ground Floor-Annex Building, 56 Eloff Street, Johannesburg CBD, Contact person: Administration Unit Mr Dan Motaug Contact number: (073) 563 4175

1 hard copy of the Final Scoping Report 2 Electronic copies (CD)

Hand delivery


Edenvale Customer Care Centre Cnr Hendrick Potgieter and Van Riebeeck Avenue

1 hard copy of the Final Scoping Report

Hand delivery

2

Edenvale Office no. 201/205/214 First Floor Contact person: Ms Cecilia Rakgoale Division Head: Legislative Governance and Compliance Environmental Resource and Waste Management Department Contact number: (011) 999 3316/3376/2006

3 Electronic copy (CD)

SAHRA SAHRIS Online submission Online submission (SB)

National Department of Health

P1 Public and Health, 45 Commissioner Street, Johannesburg Contact person: Ms Mary Madaure Acting Environmental Manager Contact number: (072) 230 2849



R42, Marievale Road, Extension, Nigel, Gauteng, 1590 Contact person: Mr Rhulani Maluleke Contact number: (071) 258 6518



Plot 42 A, Newby Street, Grootvaly, Agricultural Holdings, Springs Contact person: Mr Philip De Jager Contact number: (083) 454 8868


JHB Health District

Hillbrow Community Health Centre, Admin Block FF1, Cnr Klein street and Smit street, Hillbrow, Johannesburg Contact person: Ms Crystal Rosenberg Environmental Health Practitioner Contact number: (082) 384 5191


Department of Public Works and Infrastructure (DPWI)

78 Dekorte Street, Braamfontein Contact person: Ms Jeanette Monare, Regional Manager Contact number: (083) 635 0760


Department of Environment Agriculture, Forestry and Fisheries (Previously known as

Cnr Annie Botha & Union Street, Pretoria Contact person: Ms Mulalo Sundani


3

the Department of Agriculture Forestry and Fisheries (DAFF)

Environmental Impact Management Contact number:(076) 021 6115

Environmental NGO

44 Broadlands, Corner of Rosewood and Cedar Roads, Broadacres, Fourways, Sandton. I shall appreciate it if the courier can leave the document with the guards at the entrance. Ms Mariette Liefferink Contact number :(073) 231 4893


Kongiwe Website

- Upload onto website Upload onto website

Hard copies to be printed and distributed: 3 Hard copies, 2 just the Report of the Final Scoping Report and 16 CDs.

Page | 11

APPENDIX C:


❖ Appendix C8 – Minutes of Meetings and

Presentations

1


Stakeholder Meetings

DATE TIME MEETING VENUE ORGANISATON PERSONS ATTENDING TYPE OF

MEETING TEAM MEMBERS

Thursday, 10 October 2019

10:00 Springs Civic Centre 3rd floor boardroom


Mr Dean Stone (Ward Cllr 75) Local Government Ms Sibongile Bambisa Ms Vanessa Viljoen

Tuesday, 15 October 2019

14:00 Eco Glades 2, Block G, 420 Witch-Hazel Avenue, Centurion

National Nuclear Regulator

Mr Patle Mohajane, Programme Manager: NORM Ms Malebo Makgale, Manager: Assessments: NORM Mr Maduvha Mauba, Intern: Assessment

Authority Meeting

Ms Ashleigh Blackwell Ms Vanessa Viljoen Ms Rina Myburgh

Friday, 18 October 2019

11:00 Nigel Golf Club, Springs Road


Cllr Wollaston Labuschagne (Ward 88), Cllr Shadow Shabangu (Ward 76), Cllr Simelane Thulani (Ward 74)

Local Government Ms Sibongile Bambisa Ms Vanessa Viljoen

Wednesday, 6 November 2019

11:00

Cnr Hendrick Potgieter and Van Riebeeck Avenue, Edenvale Office no. 201/205/214 1st Floor Boardroom, Edenvale Customer Care Centre


Ms Cecilia Rakgoale, Environmental Assessment Practitioner, Mr Gerhard Mac Carron, Ekurhuleni Spatial Planning, Ms Maggy Hadebe, City Planning Spatial Planning, Mr Bafana Mazibuko, Disaster & Emergency Services Department, Mr Hennie Croucamp, Emergency Services Codes, Mr Makhudu Molepo, Snr Environmental Health Practitioner, Ms Anél Hietbrink, Environmental Assessment Practitioner & Waste Management, Mr Ndivhuwo Mutondwa, Intern, Ms Lerato Moloto, Intern, Mr Johan Koekemoer, Manager Environmental Health,

Local Government

Ms Vanessa Viljoen Mr Bradly Thornton Mr Siphesihle Dambuza

2



Ms Lillian Kwakwa, Environmental Assessment Practitioner

Saturday, 9 November 2019

10:00 to 15:00

Grootvaly Blesbokspruit Wetland Reserve in Welgadacht Road in Springs

All Sectors All Stakeholders Open Day

Ms Ashleigh Blackwell Ms Vanessa Viljoen Mr Siphesihle Dambuza Mr Bradly Thornton Ms Sibongile Bambisa Ms Gerlinde Wilreker Mr Greg Ovens

Mr Henry Phoko

Wednesday, 5 February 2020

10:00 56 Eloff Street, Johannesburg


Mr Mokutu Nketu, GDARD Mr Erick Moletsane, GDARD Mr Tjatja Mosia, GDARD

Authority Meeting Ms Vanessa Viljoen Mr Siphesihle Dambuza Mr Michael Hennessy


13:30 R42 Delmas road, Marievale Nature Reserve, Nigel


Mr Rhulani Maluleke, Manager Mr Joshua Quinton, PSG B Ms Anga Yaphi, PS Ms Albertina Setsiba, PS

Landowner Meeting

Ms Vanessa Viljoen Mr Siphesihle Dambuza Mr Michael Hennessy

Friday, 7 February 2020

12:00 Brikor Plant 1 - Nigel IIangabi Mining

Mr Corrie Retief, Consultant Mr Murray Reid, Manager Ms Marguerite Lubbe, Environmental Officer Mr JC Le Grange, Geologist Ms Lebepa Komape, SLP

Landowner Meeting


Tuesday, 11 February 2020

13:30 Isando offices Transnet, 1 Anvil Road, Isando. (Boardroom B, 7th Floor)

Transnet Freight Rail

Ms Mamothena Mothupi, Engineering Technician Mr Qatjha Ramokhothoane, Isando Mr Joseph Molautsi, Chief Admin officer

Landowner Meeting

Ms Vanessa Viljoen Mr Siphesihle Dambuza


10:00 08 Lakeview Crescent, Kleinfontein Office Park, Benoni

Eskom

Mr Jan Mitchell, Land & Rights Development Mr Sbu Nkalanga, Land & Rights Development

Landowner Meeting


Thursday, 13 February 2020

10:00

Nigel Brick and Clay (PTY) Ltd, No 2 Nigel Marievale Road, Vorsterskroon, Nigel

Scarlet Sun 33 (Pty) Ltd

Mrs Marinda Newton, Accountant Landowner Meeting

Mr Bradly Thornton Ms Vanessa Viljoen Mr Siphesihle Dambuza Mr Greg Ovens

3




12:30

cnr Plover & Vogelstruisbult str, Struisbult, Springs, Gauteng, 1559

EBM Project (Pty) Ltd

Mr Niel West, CEO Mr Mduduzi Cebekhulu, SHE

Landowner Meeting

Mr Bradly Thornton Ms Vanessa Viljoen Mr Siphesihle Dambuza Mr Greg Ovens

Friday, 14 February 2020

11:00

Room 385 Ndinaye House 394 Ndinaye House 178 Francis Baard Street

Department of Human Settlements, Water and Sanitation (DHSWS)

Mr Bashan Govender, Water Quality Manager (National) Mr Divan Van Niekerk, National Ms Candace Enoch, Environmental Officer Mr Ayanda Mtetwa, National

Authority Meeting



10:00 Skype Call Vereeniging Property and Investments (Pty) Ltd

Mr Sam Hancock, Financial Manager Landowner Meeting


Thursday, 19 March 2020

10:00 Skype Call INSA Coal

Mr Bjorn Goosen, Project Manager, INSA Coal Mr Davide Bishop, Attorney, Bishop Fraser Attorneys Mr DuToit Wilken, Environmental Consultant, Elemental Sustainability

Landowner Meeting

Mr Bradly Thornton Ms Vanessa Viljoen Ms Gerlinde Wilreker Mr Michael Hennessy

Crown Gold Recoveries and Ergo Mining: Soweto Cluster, Valley Silts and Marievale Projects

Meeting Minutes © 2019 Kongiwe Environmental (Pty) Ltd


Reclamation of the Soweto Cluster, Valley Silts and Marievale TSFs, Ekurhuleni

Metropolitan Municipality - Gauteng Province

Stakeholder Meeting – Marievale / Valley Silts / Soweto Cluster

Date Tuesday, 15 October 2019

Time: 14:00

Venue: National Nuclear Regulator, Eco Glades 2, Block G, 420 Witch-Hazel Avenue, Centurion

List of attendees:

Organisation Name of attendee Designation

Kongiwe Environmental (Pty) Ltd Ms Ashleigh Blackwell Environmental Consultant

Kongiwe Environmental (Pty) Ltd Ms Vanessa Viljoen

Stakeholder Engagement Consultant

National Nuclear Regulator Mr Patle Mohajane, Programme Manager: NORM

National Nuclear Regulator Ms Malebo Makgale Manager: Assessments: NORM

National Nuclear Regulator Mr Maduvha Mauba Intern: Assessment

Ergo Mining /Crown Gold Recoveries Ms Rina Myburgh RPO for Ergo Mining /Crown Gold Recoveries

1. Welcome and Introductions

1.1. Ms Ashleigh Blackwell welcomed all present at the meeting. Please refer to Appendix A, for

a copy of the attendance register.

2. Agenda

❖ Purpose of the Meeting; ❖ Important Notice; ❖ Introductions; ❖ Project Description; ❖ Project Infrastructure; ❖ Specialist Studies; ❖ Baseline Information; ❖ Legislative Framework; ❖ Project Progress to date; ❖ Stakeholder Engagement; and ❖ Question & Answers.

3. The purpose of the Meeting was to:

❖ Discuss the proposed Marievale / Soweto Cluster & Valley Silts Projects; ❖ Provide an overview of the Processes; ❖ Provide Stakeholders with an opportunity to raise comments/ seek clarity and provide input ❖ Record comments raised and include in the Comments and Responses Report.

For a copy of the presentation, please refer to Appendix B.

Crown Gold Recoveries and Ergo Mining: Soweto Cluster, Valley Silts and Marievale Projects Meeting Minutes


4. Discussion

STAKEHOLDER COMMENT RESPONSE

Soweto Cluster

Mr Patle Mohajane Mr Mohajane explained what the mandate of the NNR is. He elaborated the NNR’s interest on the Soweto Cluster project, and asked if this project had already been authorised? Mr Mohajane stated that the NNR seeks to establish whether the work happening within the project area is in line with the NNR mandate, and to ensure that the Applicant does not start activities without authorisation from the NNR. The application must include the relevant impact assessment that will go with the reclamation for the NNR approval.

Ms Rina Myburgh said the Soweto Cluster project has not yet been authorised, however the Central Processing Plant at the Regional Tailings Storage Facility has been authorised under COP 281, (the new Far West Gold Recoveries). All required authorisations need to be in place prior to commencement of the project.

Mr Patle Mohajane NNR needs to get more information on the Soweto Cluster Project, as far as NNR are aware, it was formally licensed under Mintails licences?

Ms Ashleigh Blackwell indicated that as it stands the Mintails company is in liquidation, the Soweto Cluster dumps currently are unmanaged and Crown Gold Recoveries is looking to take over the responsibility of removing and reprocessing the dumps as Mintails no longer can.

Mr Patle Mohajane Is the liquidation finalised and done? Ms Ashleigh Blackwell indicated that as far as we are aware the process is ongoing.

Ms Rina Myburgh Should Crown Gold Recoveries consider excluding these sites from the COR due to the levels being below 0.5? Or, will a safety assessment exclusion with further assessment be sufficient? Valley silts is included in COR 57 but Soweto Cluster and Marievale dumps are not in the COR 57 or COR 228. Crown Gold Recoveries wishes to be exempt from applying for a COR, what would the NNR require in order to do so?

Mr Patle Mohajane indicated that applicant must decide if it wishes to place the Soweto Cluster dumps into an existing COR (such as COR 57) or apply for a new one.

Mr Patle Mohajane Is it not applicable that you apply for a Mining Right from DMR for the Soweto Cluster?

Ms Ashleigh Blackwell indicated that the actual reclamation of the Soweto Cluster dumps will be done in terms of the NEMA, since the removal of historic mineral deposits does not trigger any mining activity at all under the MPRDA.

Crown Gold Recoveries and Ergo Mining: Soweto Cluster, Valley Silts and Marievale Projects Meeting Minutes


Ms Ashleigh Blackwell Would the NNR be satisfied with the EIA/EMP and specialist to make a decision on whether or not to include Soweto Cluster in a COP or not?

Mr Patle Mohajane indicated that since the site is already authorised by the NNR and Mintails is liquidated, if there are issues there, NNR would need to liaise with the liquidator. However, if this applicant (Crown Gold Recoveries) is going to take liability of the Soweto Dumps, then the dumps will be authorised by NNR.

Mr Patle Mohajane Has Crown Gold Recoveries conducted an in depth profile sample to prove to the NNR that the source radiation is below 0.5?

Ms Rina Myburgh: If this is required, Crown Gold Recoveries can conduct the study.

Mr Patle Mohajane It would be important to give the NNR the history of the source and the methodology used to reach the representative sample for the whole dump.

Ms Rina Myburgh: Crown Gold Recoveries should have the information from the current survey conducted on site, this will be verified.

Valley Silts

Ms Malebo Makgale Is the Ezekiel sand dump authorised? Ms Rina Myburgh indicated that all the Ezekiel dumps are authorised within the Knights mining right.

Mr Patle Mohajane Which department are you in consultation with at the city of Johannesburg?

Ms Ashleigh Blackwell indicated that Kongiwe is consulting with different departments within the municipality such as the Environmental, Land Development and Planning Departments.

Mr Patle Mohajane Does this property only belong to the City of Johannesburg? Ms Vanessa Viljoen indicated that some of the properties belong to the City of Johannesburg, however there are other property owners which includes stakeholders like Transnet and Eskom etc.

Mr Patle Mohajane Have you had meetings for Valley Silts yet? NNR is aware that Riverlea is a difficult area.

Ms Vanessa Viljoen said that meetings have been held with the relevant authorities and the other stakeholders and are ongoing.

Marievale

Mr Patle Mohajane Asked if the public have raised questions about radiation in the meetings that Kongiwe have conducted.

Ms Ashleigh Blackwell indicated that stakeholders have asked about radiation in the meetings that have been held. She said that the questions asked where more towards the impacts related to the health associated with the radiation.

Ms Rina Myburgh In terms of Marievale, it was never authorised by NNR. Mr Patle Mohajane indicated that it was authorised under the COR 52 in Nigel. Marievale is still seen under the license and must be managed in accordance under the NNR.

The meeting was adjourned at 15:00, Ms Ashleigh Blackwell thanked all present for their attendance and input.



Appendix A

Attendance Register



Appendix B

Presentation

Environmental Authorisation Process for the Soweto Cluster , Valley Silts and Marievale

Projects.

Focus Group Meeting with the NNR

15 October 2019

‘To solve environmental challenges for a world driven towards a sustainable future.’

Introductions

• Rina Myburg – Radiation Specialist DRDGold

• Ashleigh Blackwell – Project Manager

• Vanessa Viljoen – Stakeholder Engagement

© 2019

Meeting Agenda

❖ Important Notice;❖ Project Background;❖ Project Infrastructure;❖ Specialist Studies;❖ Legislative Framework;❖ Project Progress to date;

and❖ Question & Answers.

© 2019

Important Notice

This meeting is a formal consultation in terms of the requirements as stipulated in the:

o National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA) for anApplication for an Environmental Authorisation (EA) for listed activities triggered inListing Notices GN R983, GN R984 and GN R985 in terms of the Environmental ImpactAssessment (EIA) Regulations, 2014 (as amended). The Department of Mineral Resourcesand Energy (DMRE) will be the Competent Authority to assess the EA for the proposedproject.

o National Water Act, 1998 (Act No.36 of 1998) (NWA) for an Integrated Water Use LicenceApplication (IWULA) in accordance with the Act. The Department of Water andSanitation will be the Competent Authority to assess the IWULA for the proposed project.

© 2019

Soweto Cluster Dumps

Soweto, Johannesburg

Project Background: Soweto Cluster❖Applicant: Crown Gold Recoveries (Pty) Ltd

❖Reclamation: The project will reclaim slimes dams 2L24; 2L20; 2L21; 2L16; 2L17 and 2L18, as well assand dumps 2A6 and 2A8.

❖Mining Method: Hydraulic for Slimes Dams and Front-end Loader for Sand Dumps

❖LOM: 20 years

❖Alternative 1: Soweto Cluster is reclaimed, and slurry is transported through new pipelines from2L24 to the Cooke Plant, south of the Soweto Cluster. Deposition will take place on the CookeTailings Storage Facility (TSF) which is adjacent to the plant.

❖Alternative 2: Soweto Cluster is reclaimed, and slurry is transported though new pipelines to theCooke Plant (as per Alternative 1), and then to the CPP (with the option to bypass the Cooke Plantin the future). The pipeline from Cooke Plant to CPP has been authorised already but is not existing.Deposition will then take place on the Regional Tailings Storage Facility, which is authorised but notyet constructed.

❖Rehabilitation: The end land use of the site is at the discretion of the landowner.

© 2019

© 2019

Project Description: The Process

❖ It is envisioned that the tailings material of the Soweto Cluster will be reclaimed by using:

❖ High-pressure water jets (slimes dams) or

❖ Mechanical removal by front-end loaders (sand dumps)

❖Three existing authorised processing plants, each with a capacity to process 500 000 tons to 1.2 million tons of

slurry per month, will be investigated as alternatives for this project.

❖The plants include Ergo Plant, Cooke Plant and the yet to be constructed Central Processing Plant (CPP).

❖Final deposition of the processed slurry from the plants will be at the associated authorised deposition site,

namely the Brakpan/Withok TSF, the Cooke TSF or Pits, and/or the Regional TSF (which is still to be

constructed).

❖Three 500 mm slurry pipelines and three 500 mm return water pipelines will be investigated as alternatives for

the project. These pipelines are linked to the plant alternatives considered above.

© 2019


© 2019

Proposed InfrastructureThe Soweto Cluster is well serviced by existing roads and infrastructure; however the following infrastructure is proposed:

❖Overland slurry pipelines of 500 mm in diameter;

❖Overland return water pipelines of 500 mm in diameter;

❖Reclamation pump stations, which include:

❖Water infrastructure, stormwater systems and spillage handling systems;

❖Electricity reticulation;

❖Administration buildings, including change houses and ablution facilities;

❖Access roads, routed from existing entry points; and

❖Construction contractors’ yards (temporary facilities).

Specialist Studies

© 2019

Proposed Specialist Studies

Traffic Health Impact Assessment

Wetlands Surface Water

Heritage Social Impact Assessment

Fauna and Flora Noise Screening

Air Quality Groundwater

The Valley Silts Project

Riverlea, Johannesburg

Project Background

© 2019

❖Applicant: Ergo Mining (Pty) Ltd.

❖The project falls within an existing Mining Right GP 184 MR.

❖Currently, the Russell Stream is highly polluted and heavily silted.

❖Ergo will aim to remove and reclaim the gold bearing silts from the Russell Stream (otherwise referred to as theKlipspruit), situated north of Nasrec near Booysens Reserve.

❖The silt will be removed from specific target areas, thereby improving the water flow dynamics and assisting inameliorating current flooding issues experienced in the area of Riverlea.

❖After removal of the silt from the target areas, Ergo aims to rehabilitate the Valley Silts area by shaping the areaswhere silt was removed and make the area free draining.

❖ Thereafter, appropriate species will be planted to stabilise the soil.

❖The proposed extent and viability of the target areas as well as plans for rehabilitation will need to be evaluatedthrough specialist studies during the EIA phase, in consultation with the City of Johannesburg (CoJ) andDepartment of Human Settlements, Water and Sanitation (DWS).

❖ It has been found that the goldbearing silts originated fromlocalised erosion on thesurrounding slime dams and sanddumps from the surroundingmining areas,

❖ Unconsolidated material wasaccordingly transported into theValley Silts area via surface runoffand stream flow.

Project Infrastructure

Existing infrastructure to be utilised at stages duringthe project include:

❖The Ezekiel Dump footprint;

❖Pre-processing infrastructure, scrubber and pumpstation at Ezekiel;

❖Existing site access roads;

❖The Knights Plant;

❖Existing pipelines;

❖The Brakpan/Withok TSF;

❖Electricity and water reticulation; and

❖Hauling road: access roads and main roads.

© 2019

The following infrastructure and vehicles will beutilised on site:

❖Mechanical excavation equipment (Backhoes orExcavators);

❖6 X 30 ton Articulated Dump Trucks (ADT’s);

❖25 X 30 ton Dump Trucks;

❖Water Bowser Truck;

❖Temporary administration buildings, ablutionfacilities; and

❖Additional site access roads (only if required).

Specialist Studies

© 2019




Fauna and Flora Social Impact Assessment

Groundwater Heritage Impact Assessment

The following studies will be undertaken during the EIA phase of the project and will beused to inform the final decision making capacity of the EAP.

The Marievale TSFReclamation Project

Nigel and Springs, Johannesburg

Project Background: Marievale TSF

❖Applicant: Ergo Mining (Pty) Ltd

❖Reclamation: The project will reclaim slimes dams 2L5, 2L6 and 2L7

❖Mining Method: Hydraulic Reclamation

❖LOM: 20 years

❖The first alternative pipeline route is approximately 25 km long and consists of two separate 500mm diameter slurry and return water pipeline pairings. The first pair would be a 7 km extensionfrom the project site to the Daggafontein Plant; while the second pair would be a 17 km extensionfrom the Daggafontein Plant to the Ergo Plant.

❖The second alternative route would be a 19 km, 500 mm diameter slurry and return water pipelinepairing that extends from the proposed project site to the Ergo Plant


© 2019

© 2019


❖It is envisioned that the tailings material of the Marievale TSF will be reclaimed by

using:

❖High-pressure water jets (slimes dams) or

❖Reprocessing will take place at the Ergo authorised processing plant.

❖Approximately 500 000 tons to 1.2 million tons of slurry per month will be

reprocessed

❖Final deposition of the processed slurry from the plants will be at the associated

authorised deposition site, namely the Brakpan/Withok TSF

❖Two 500 mm slurry pipelines and three 500 mm return water pipelines will be

investigated as alternatives for the project.

© 2019

Proposed InfrastructureThe Marievale TSF’s are well serviced by existing roads and infrastructure; however the following infrastructure is proposed:


❖Overland return water pipelines of 500 mm in diameter;

❖Reclamation pump stations, which include:

❖Water infrastructure, stormwater systems and spillage handling systems;

❖Electricity reticulation;

❖Administration buildings, including change houses and ablution facilities;

❖Access roads, routed from existing entry points; and

❖Construction contractors’ yards (temporary facilities).

Specialist Studies

© 2019





Fauna and Flora Noise Screening


Kongiwe Environmental (Pty) LtdReg 2017/135562/07Directors: B. Thornton, G. Wilreker, & M. Hennessey150 Bryanston Drive, Bryanston, Sandton, 2191, South Africa.PostNet Suite no 163, Private Bag X21, Bryanston, 2021, South Africa.

[email protected]

Contact: Sibongile BambisaTel: 012 003 [email protected]@kongiwe.co.za

Environmental Authorisation Process for the Marievale TSF Reclamation Project.

Focus Group Meeting: City of Ekuhruleni

06 November 2019


Purpose of the Meeting

© 2019

❖ Discuss the proposed Marievale TSF Reclamation Project;❖ Provide an overview of the Environmental Impact Assessment

process;❖ Provide the City of Ekurhuleni with an opportunity to raise

comments/ seek clarity and provide input; and❖ Record comments raised and include in the Comments and

Responses Report.

Introductions

• Bradly Thornton – Chief Executive

• Siphesihle Dambuza – Environmental Assessment Practitioner


© 2019

Meeting Agenda

❖ Important Notice of the meeting;❖ Kongiwe’s Role as an Independent EAP;❖ Project Background;❖ Project Infrastructure;❖ Specialist Studies;❖ Legislative Framework;❖ Project Progress to date; and❖ Question & Answers.

© 2019

Important NoticeThis meeting is a formal consultation in terms of the requirements as stipulated in the:



© 2019

Kongiwe’s Role

As an independent Environmental Assessment Practitioner, it is our

role to perform an objective assessment of what the positive and

negative environmental impacts of the proposed project may be, to

quantify these, describe possible mitigations, collect public

comment and supply the Department of Minerals and Energy (DME)

with the documentation so that they can determine if the project

should proceed or not.

© 2019





❖LOM: 20 years

❖The Proposed Project will investigate two pipeline routes to convey slurry from the TSFs to the ErgoPlant for reprocessing; and return process water to the project site for reclamation. The pipelineconfiguration would consist of two, 600 mm diameter, slurry pipelines and one, 600 mm diameter,process water pipeline.

❖The first alternative pipeline route is approximately 25 km long and is made up of a two parts. Thefirst part would be a 7 km extension from the project site to the Daggafontein Plant; while thesecond part would be a 17 km extension from the Daggafontein Plant to the Ergo Plant.

❖The second alternative route would be a 19 km extension from the Proposed Project site, directlyto the Ergo Plant.


© 2019

© 2019


❖It is envisioned that the tailings material of the Marievale TSF will be reclaimed by using:

❖High-pressure water jets (slimes dams)

❖Reprocessing will take place at the Ergo processing plant.

❖Approximately 500 000 tons to 1.2 million tons of slurry per month will be reprocessed

❖Final deposition of the processed slurry from the plants will be at the associated


❖Two 600 mm slurry pipelines and three 600 mm return water pipelines will be

investigated as alternatives for the project.

❖Process water will operate as a closed circuit, meaning that limited make-up water will be

required for the reclamation

© 2019



❖Overland return water pipeline of 600 mm in diameter;

❖Reclamation pump stations;

❖Water infrastructure including stormwater systems and spillage handling systems;

❖Electricity reticulation; and

❖Administration buildings, including change houses and ablution facilities.

❖Routed access will only be designed if necessary.

Specialist Studies

© 2019


Traffic Surface Water


Fauna / Flora and Wetlands Noise Screening


Legislative Framework

❖An integrated Environmental Authorisation (EA) application has beensubmitted to the Department of Mineral Resources and Energy (DMRE) asthe Competent Authority for the proposed project.

❖The applicable applicationsto be assessed by the DMRE are as follows:

o Application for an Environmental Authorisation for listed activitiestriggered in Listing Notices GN R327, GN R325 and GN R324 in termsof the Environmental Impact Assessment (EIA) Regulations, 2017, aspromulgated in terms of the National Environmental ManagementAct, 1998 (Act No. 107 of 1998) (NEMA);

o An Integrated Water Use Licence Application (IWULA) will beundertaken in accordance with the National Water Act, 1998 (ActNo.36 of 1998) (NWA). The Department of Water and Sanitation willbe the Competent Authority to assess the IWULA for the proposedproject

❖The Application was lodged with the DMRE on the 15th October 2019.

© 2019

© 2019

The Project Progress to date:

❖The Application was submitted to the Department of Mineral Resources & Energy on 15th

October 2019.

❖The Draft Scoping Report was submitted to the DMRE and released to the public for 30-days

from 22nd October to 21st November 2019.

❖ Comments from Interested and Affected Parities (I&AP’s) due on the 21st November 2019.

❖A Public meeting is arranged for the 09 November 2019 at 10H00 to 15H00.

❖Landowner and stakeholder meetings are ongoing.

❖The Final Scoping report will be submitted on the 26th November 2019.

❖IWULA report will be subjected to 60 days public participation and will be submitted to the

DWS for their consideration during the EIA phase.


[email protected]


Ergo Mining (Pty) Limited: Marievale Reclamation Project Consultation meeting: Minutes



Reclamation of the Marievale Tailings Storage Facilities, Ekurhuleni Metropolitan


Stakeholder Meeting – Marievale

Date Wednesday, 6 November 2019

Time: 11H00

Venue: City of Ekurhuleni Metropolitan Municipality 1st Floor Boardroom, Edenvale Customer Care Centre, 37 Van Riebeeck, Edenvale

List of attendees:


Kongiwe Environmental (Pty) Ltd Mr Bradly Thornton Environmental Consultant

Kongiwe Environmental (Pty) Ltd Ms Vanessa Viljoen Stakeholder Engagement Consultant

Kongiwe Environmental (Pty) Ltd Mr Siphesihle Dambuza Environmental Consultant


Ms Cecilia Rakgoale Environmental Assessment Practitioner


Ms Lillian Kwakwa Environmental Assessment Practitioner


Mr Johan Koekemoer Manager Environmental Health


Mr Gerhard Mac Carron Ekurhuleni Spatial Planning


Ms Maggy Hadebe City Planning Spatial Planning,


Mr Bafana Mazibuko Disaster & Emergency Services Department


Mr Hennie Croucamp Emergency Services Codes


Mr Makhudu Molepo Snr Environmental Health Practitioner


Ms Anél Hietbrink, Environmental Assessment Practitioner & Waste Management


Ms Lerato Moloto Intern


Mr Ndivhuwo Mutondwa Intern


1.1. Ms Cecilia Rakgoale welcomed all present at the meeting. Please refer to Appendix A, for a

copy of the attendance register.

2. Agenda

❖ Important Notice of the meeting; ❖ Kongiwe’s Role as an Independent EAP; ❖ Project Background; ❖ Project Infrastructure; ❖ Proposed specialist Studies;



❖ Legislative Framework; ❖ Project Progress to date; and ❖ Question & Answers


❖ Discuss the proposed Marievale Reclamation Project; ❖ Provide details on how the reclamation process will be undertaken; ❖ Provide stakeholders with an opportunity to raise comments/ seek clarity and provide input; ❖ Record comments raised and include in the Comments and Responses Report.




4. Discussion


Mr Makhudu Molepo City of Ekurhuleni Metropolitan Municipality Snr Environmental Health Practitioner

Asked if the proposed project will pose any negative impacts on the groundwater?

Mr Bradly Thornton said that that a groundwater impact assessment will be undertaken to investigate any impact on groundwater.

Ms Anél Hietbrink City of Ekurhuleni Metropolitan Municipality Environmental Assessment Practitioner & Waste Management

Indicated that there seems to be a lot of Tailings Storage Facilities (TSFs) reclamation projects and all the applicants state that that the slimes will go to the Brakpan/Withok TSF. As indicated in the presentation, the average life of mine is 20 years, asked if Brakpan/Withok TSF does not have enough capacity where the applicant will dispose the slurry.

Mr Bradly Thornton said that Brakpan/Withok TSF has enough capacity there is also an updated design submitted to DWS for the facility .

Mr Hennie Croucamp City of Ekurhuleni Metropolitan Municipality Emergency Services Codes

Asked if the pipeline routes will be included as part of the Environmental Authorisation process.

Mr Bradly Thornton indicated that the pipelines are part of the authorisation process for the proposed Marievale project.


Mr Croucamp stated that one of the problems the Municipality has had in Boksburg (Sunward Park) specifically, was several pipes burst over the last 10 years which make a big mess of slurry everywhere in the suburbs as part of the reclamation of the Elsburg Complex. How does the applicant intend to prevent the pipelines from bursting? Enquired if the possibility of pipeline spillages will be considered in the Environmental Impact Assessment process?

Kongiwe cannot comment on Elsburg, but Kongiwe will raise the issue

with Ergo Mining.

Ergo has environmental incident prevention measures in place that

include monitoring for and reporting on incidents according to:

❖ The categories set out in the NNR Certificate of Registration;

❖ Chapter 23 of the Mine Health and Safety Act which sets out

Regulations for the Reporting of Accidents and Dangerous

Occurrences; and

❖ GN 704, Regulation 2 with respect to any possible effect on a

watercourse.

Emergency response plans are incorporated in the EIA/ EMPr

documents.



Mr Johan Koekemoer City of Ekurhuleni Metropolitan Municipality Manager Environmental Health

Asked if the pipelines will be traversing residential areas. Mr Bradly Thornton indicated that it is a mixture of rural and residential areas. Mr Thornton said that the impacts of the pipelines will be investigated.


Ms Hietbrink asked if a new pipeline will be constructed or the applicant will use existing pipelines.

Mr Bradly Thornton said that there are no existing pipelines and the applicant intends to construct only new pipelines. The project team will assess the overall impacts of new pipelines.


Asked if there are servitudes in place for these pipelines

Mr Bradly Thornton said that the project team is currently assessing existing servitude and surface right permits records to see where additional rights of way are required.


Mr Croucamp requested clarity in terms of the colour coding for the different pipeline routes indicated in the map.

Mr Siphesihle Dambuza referred to the locality map and indicated

the pipeline routes.


Mr Molepo asked if the project team has identified environmental liabilities regarding pipeline spillages. Concerned that should there be spillages, cyanide will be released to the surrounding environment. Mr Molepo enquired about the procedures to be followed should there be measures in place.

Mr Bradly Thornton indicated Mr Molepo’s concern will be relayed to the applicant and will also be addressed as part of the EIA process. Emergency response plans are incorporated in the EIA/ EMPr documents.


Enquired if the project team has a list of hazardous materials associated with the slurry. If there is such a list, Mr Molepo requested for such a list to be included in the Scoping Report. Mr Molepo added that it is the responsibility of the Municipality to safeguard the public therefore it is important to know about the risks associated with the proposed project.

Comment noted. Mr Bradly Thornton said that an Emergency response plan will be developed as part of the EIA process.

Ms Cecilia Rakgoale Asked if the pipelines are crossing through urban areas, will there be enough space for the pipelines.

Mr Bradly Thornton said that the project team will assess three alternatives from an environmental point of view.



City of Ekurhuleni Metropolitan Municipality Environmental Assessment Practitioner

Ms Rakgoale asked if pipeline route alternatives be considered as part of the EIA process.

Mr Thornton said that in accordance with the EIA regulations, alternatives should be assessed. The project team will investigate the best route and take specialist studies into consideration.


Ms Hietbrink asked if there are connections for sewage disposals. If not, what alternatives will the applicant be looking at for sewage disposal and capacity etc. Ms Hietbrink added that the Municipality capacity constraints on wastewater treatment works as well as the sewage works. If the applicant will be using portable toilets, the Municipality needs to be informed about where the toilets will be placed. If it is within the city sewage system, the applicant, needs to indicate where will the sewage from the honey suckers be disposed and effluent permits should be obtained.

Mr Bradly Thornton said that will be investigated. As far as the project team is aware, the applicant will be using portable toilets through an appropriate contractor.

Ms Cecilia Rakgoale City of Ekurhuleni Metropolitan Municipality Environmental Assessment Practitioner

Ms Rakgoale asked if the pipelines will be constructed above or below ground?

Mr Bradly Thornton indicated that the pipelines will be constructed above ground.


Concerned about the bottom section where the slurry to be processed is connected at the lowest point which is close to a wetland. Ms Hietbrink enquired about the mitigation measures to prevent impacts on the wetland.

Mr Bradly Thornton said that groundwater and surface water assessments will be undertaken and will investigate adequate mitigation measures.


Mr Koekemoer asked if the Daggafontein plant is used, where will the slurry go?

Mr Bradly Thornton indicated that all slurry materials will be taken to the Ergo Plant and residue will be disposed of on the Brakpan / Withok TSF. The Daggafontein Plant is not owned by Ergo Mining and will not be used.




With the increase of the slurry on the Brakpan / Withok TSF, there will be an increase in dust, the dust from that site also needs to be reduced. Mr Koekemoer asked if there are processes in place to address this concern.

Mr Bradly Thornton indicated that the Brakpan / Withok TSF is a licenced and managed facility which has active dust management activities taking place.


Asked what happens to pipelines over a long period of time, they become radioactive active? You also get scavengers who cut the pipes and take it to scrap yards, causes a huge problem with radioactive waste ending up at scrap yards/ Requested clarity in terms of how pipelines will be rehabilitated.

Mr Bradly Thornton said that pipelines need to be removed when they are no longer operational . Radioactivity will be assessed on the pipeline routes before they are sold to registered scrap dealers.


Asked if all the mine dumps are on privately owned land. Ms Rakgoale said that the end land use should be guided by specialists, so that it is not just used for residential purposes. The cleaned-up areas should be compatible with the current systems.

Mr Bradly Thornton indicated the TSFs are on publicly and privately owned land and that the specialist will be advising on the potential end land use.

Ms Lillian Kwakwa City of Ekurhuleni Metropolitan Municipality Environmental Assessment Practitioner

As per your presentation you are removing 3 tailings dumps, will these dumps be removed at the same time?

Mr Bradly Thornton indicated that the dumps are likely to be removed one at a time.


Asked if Kongiwe is aware of the new development of a mall, across phase 1 open land behind Corobrik. The municipality has received an application.

Mr Hennie Croucamp said it is the same application that was rejected by the municipality as far as he is aware.


Ms Rakgoale indicated that the proposed pipelines traverse wetlands, this needs to be adequately addressed as part of the EIA.

Mr Bradly Thornton said that this matter will be investigated in the impact assessment phase.




The movement of the slurry from Ergo plant to Brakpan/Withok TSF you say is an existing pipeline, must also be included into your report, because there might also be risk, it is to end use, you have to look at your process from start to end. Suggested that the project team should identify risks associated with moving the slurry from Ergo plant to the Withok TSF.

Mr Thornton said thank you for the comment it is noted. The Brakpan/Withok TSF and the pipeline thereto from the Ergo Plant are authorised and managed activities.


Indicated that the Military Base west of the dumps is the new PRASA Gibela Rail Consortium Dunnottar Factory, which is a huge piece of land which appears on the Municipality’s Arial photos, but that Springs/Nigel road is running next to that. The location of the pipeline-Wall of that land on the west of Springs/Nigel road running right down has already got an approved residential township from the Gauteng Department of Human Settlements. We do not want to sterilise the land with a pipeline going through that area.

Mr Bradly Thornton indicated that the project team consults with PRASA. Mr Thornton indicated that the project team will consult with Gauteng Department of Human Settlements on this matter.


The EIA needs to consider the Municipality’s future developments such as housing etc. The consideration of future developments will ensure that there is no sterilization of land etc.

Mr Bradly Thornton said that the Applicant attempts to place pipelines on existing servitudes, surface right permits and wayleaves as far as possible.


East of military base all of that is outside of the Municipality’s urban edge. That urban edge basically runs around the back of the Dunnottar Factory, down below 7L5, 7L6, the urban boundary runs around that. This has implications for future land uses. What should be considered; the dump to the south cannot really be considered for anything else but agriculture. The two dumps to the north the applicant can consider using the land for a cemetery.

Mr Bradly Thornton thanked Mr Croucamp for the suggestion.


Requested to be sent shape files / KMZ. Mr Croucamp indicated that the project team can get information from the GIS department, they have updated Arial Photos.

Post meeting note: Ms Nokuthula Ndala from Kongiwe Environmental emailed Mr Croucamp the requested KMZ files. the KMZ and requested information.




Asked if land has been identified where the infrastructure e.g. offices, change houses will be constructed for the proposed project.

Mr Bradly Thornton said that usually these are constructed at the lowest topographical point of the dump footprint. This is where the applicant is likely to place the pump station, offices and the change house. Generally, the applicant will try to stay within the dump footprint, so they remove a bit of material and work within the dump footprint. There is not a lot of infrastructure.


Requested that for infrastructure to be clearly marked on the maps.

Mr Bradly Thornton said infrastructure will be marked on the maps in the EIA phase.


What stops the dumps from giving way, like with Merriespruit. The wall just gives way like a dam and washes into the spruit.

Mr Bradly Thornton indicated that if the dumps are dry, they are safer, it is when the dumps have lots of water on top of them, that there is a danger of the walls can break.

The meeting was adjourned at 13:00, Mr Bradly Thornton thanked all present for their attendance and input.



Appendix A

Attendance Register



Appendix B

Presentation

Ergo Mining (Pty) Limited: Proposed Marievale Reclamation Project Open Day Minutes



Reclamation of the Marievale Tailings Storage Facilities, Ekurhuleni Metropolitan


Marievale Open Day

Date Saturday, 9 November 2019

Time: 10:00 to 15:00

Venue: Grootvaly Blesbokspruit Wetland Reserve in Welgadacht Road in Springs


1.1. Stakeholders were welcomed on arrival and introduced to the project team to take them

through the poster presentation. Please refer to Appendix A, for a copy of the attendance

register.

2. Poster Display

❖ Introductions;

❖ Project Description;

❖ Project Infrastructure;

❖ Specialist Studies; and

❖ Question & Answers.

3. The purpose of the Open Day was to:

❖ Discuss the proposed Marievale Reclamation Project;

❖ Provide an overview of the Scoping Process;

❖ Provide Stakeholders with an opportunity to raise comments/ seek clarity and provide input

❖ Record comments raised and include in the Comments and Responses Report.

For a copy of the poster presentation and executive summary, please refer to Appendix B.



4. Discussion


Mr Darryl Allcock

EHS Officer

Waste Product Utilization

(WPU)

Indicated that it is good that the dumps are being removed.

Asked whether there any endemic animal Species of Special

Concern (SSC)? Would SCC have to be relocated?

A biodiversity specialist assessment is currently in progress which will

inform the existence of any SCC and any mitigation measures

required.

Mr Darryl Allcock

EHS Officer

Waste Product Utilization

(WPU)

Asked if there are any heritage sites?

A heritage specialist assessment is currently in progress which will

inform the existence of any heritage sites and any mitigation

measures required.

Ms Bev Caldwell

Selpark CFP

Asked whether the project area would be rehabilitated as a

conservation area?

The specialist studies currently being undertaken will inform us to

what the most appropriate end land use will be. The proximity to the

Marievale Bird Sanctuary must be considered when making these

recommendations.

Ms Bev Caldwell

Selpark CFP

Concerned about resident’s health. Indicated that people are

being tested for uranium poisoning. Asked, how much of the

chemicals are going into the water system?

Comment noted. The Marievale TSF sites are currently a pollution

source and the removal of them will aid in abating future

environmental impacts.

A surface water specialist assessment is currently in progress which

will assess this risk and inform mitigation measures required.

Ms Bev Caldwell

Selpark CFP

Indicated that there are illegal miners that are hacking into

sewer lines. There is a big risk that they may damage pipelines.

Wants to know who will watch over that and make sure that

there are not spillages.

Ergo has a SCADA system that will alert them of any leakages. If

alerted Ergo investigates the reason for the leakages and repairs the

leakages. The Ergo team has security personel that patrol the

pipeline routes, therefore reducing the number of criminal related

activities along these routes.

Ms Bev Caldwell

Selpark CFP Will runoff pollute the Blesbokspruit (BBS)?



Ms Bev Caldwell

Selpark CFP

The ground under the dumps is unsafe for human health. Is

also concerned that it will not be rehabilitated properly.




recommendations.



Ms Bev Caldwell

Selpark CFP

Why is there a need to remove the tailings? What is the

purpose of this project and why is it being done?

Mr Bradly Thornton said that the project is being done for economic

and environmental reasons.

Ms Bev Caldwell

Selpark CFP What will happen to the wetlands in the area?




recommendations.

Ms Bev Caldwell

Selpark CFP

Concerned about what will happen to the animals and plants

after rehabilitation.




recommendations.

Ms Bev Caldwell

Selpark CFP Hopes that the end land use will be ecologically inclusive.




recommendations.

Ms Bev Caldwell

Selpark CFP Asked where the water for the project will be sourced from?

Further investigation during the impact assessment phase on where

the water will be sourced from for the project and any secondary

impacts.

Mr Alfred Makofane

Community Member Will we be notified when the project begins?

Stakeholders have to be notified before the project begins if

authorised.

Mr Alfred Makofane

Community Member Will there be jobs created?

These projects typically do not create many additional employment

opportunities.

Mr Peter Law

Wildlife & Environmental

Society of South Africa Springs

& Nigel branch

There is an adjacent application for golf course to be turned

into a coal mine. Noted.

Mr Peter Law



& Nigel branch

There are several coal mine applications around the area. Noted.

Mr Peter Law How much water will be needed per day? Can water from the

Marievale 1 & 2 shafts be used? This option will be investigated in the impact assessment phase.





& Nigel branch

Mr Peter Law



& Nigel branch

Why is the Ergo plant going to be used and not Daggafontein as

it is closer? Water control is crucial. Daggafontein plant is in abeyance and not Ergo Mining’s property.

Mr Peter Law



& Nigel branch

Is not too concerned about the dust. Has seen from other

projects how dust has been reduced. Noted.

Mr Peter Law



& Nigel branch

Maybe take water from East Rand Basin. It will drop the

decant level through 1 shaft and 3 shaft. These shafts are

owned by Randex.

It will depend on the quality of this water, it will be investigated in

the EIA phase.

Mr Peter Law



& Nigel branch

Indicated that he has monitoring data along the East Rand

which he can share with Kongiwe. That it would be appreciated.

Mr Peter Law



& Nigel branch

Indicated that water levels in the area need to be monitored.

Levels drop by 15cm in the winter. TCTA water not making a

big difference to water levels in Blesbokspruit.

Comment noted.

Mr Philip De Jager

Private Property Owner

How high will the Brakpan dump be raised? What will the

water use be?

The Brakpan/Withok TSF is an authorised facility capable of

accommodating this project. The exact height which this project will

add to the dump is not determined. Water sources are being

investigated.

Mr Matthew Havinga


Mr Philip De Jager


What is the track record of DRDs rehabilitation? What will

happen to the land after it has been rehabilitated. Wants

something to support the ecology of the wetland i.e. Would




recommendations.



like to see the rehabilitated land donated to Marievale Bird

Sanctuary.

Mr Matthew Havinga


Mr Philip De Jager


There is a township which will cross the TCTA pipeline, it will

need to be investigated. Noted.

Mr Philip De Jager

Private Property Owner How many litres per day would be used? Approximately 20Ml/day.

Mr Philip De Jager


Concerned about water flow reduction volumes, and how this

will affect quality of the Blesbokspruit. Rather take water from

sewerage farms.



Ronnie Newby What is the project’s duration going to be? The life of mine will be approximately 20 years.

Ronnie Newby Will water be taken from the Blesbokspruit? Concerned that

this will cause problems in the Blesbokspruit.

Water sources are being investigated, but it is not expected that

water is to be extracted from the Blesbokspruit. This is an

environmental consideration.

Ronnie Newby How will Ego prevent the slurry from flowing into the

Blesbokspruit.



Mr Mike Du Toit

President Chamber of

Commerce

Have they removed the pipelines from Daggafontein to Ergo?

Our concern is spillages. Ergo Mining has a spillage response procedure in place.

Mr Ronny Mashabela

Community Member Asked what the employment opportunities will be?


opportunities.

Mr Ronny Mashabela

Community Member

The local community must be used for procurement of

services. Noted.

Mr Ronny Mashabela

Community Member Indicated that the dust coming of the dumps impact are high.

Noted. The removal of these TSF’s should lessen this environmental

impact in the long term.

Mr Trevor Dimane

Community Member Asked what the employment opportunities will be?


opportunities.

Mr Trevor Dimane

Community Member

Dust from similar experience with Fraser Alex, dust impacts

were felt.

Noted. The removal of these TSF’s should lessen this environmental

impact in the long term.



Mr Trevor Dimane

Community Member

How will the water resources be affected? The Blesbokspruit is

used for drinking purposes.



Mr Trevor Dimane

Community Member

Once construction begins the impacts begin, how will this be

mitigated

The Environmental Management Programme must be implemented

if the project is approved by the DMRE.



Appendix A

Attendance Register



Appendix B

Presentation

Ergo Mining (Pty) Ltd: The Marievale TSFs Reclamation Project Executive Summary


1

PURPOSE OF THE DOCUMENT

The purpose of this document is to provide a concise explanation of the main features and findings of the Draft Scoping Report (DSR), in a manner that is understandable for all Interested and Affected Parties (I&APs).

This document will provide an overview of the Proposed Project.

This document aims to provide the reader with the possible positive and negative impacts that may arise from the Proposed Project.

INTRODUCTION

Kongiwe has been appointed, by Ergo Mining (Pty) Limited, as the Independent Environmental Service Provider and tasked with conducting the Scoping and Environmental Impact Assessment (S&EIA) process which is aimed at critically evaluating the potential environmental and social impacts of the proposed Reclamation of Marievale Tailings Storage Facilities (hereafter, Proposed Project).

PROJECT BACKGROUND

Ergo Mining (Pty) Limited (hereafter Ergo), a subsidiary of DRDGold, intends to reclaim and reprocess gold residues from the Marievale tailings storage facilities (TSFs) Nos. 7L5, 7L6 and 7L7. These TSFs are historical mineral deposits (slimes dams), situated 6 km north-east of Nigel and about 10 km south-east of Springs, in Ward 88 of the Ekurhuleni Metropolitan Municipality (EMM).

Surface gold retreatment is a largely mechanised process with a risk profile that is significantly lower than that of conventional mining. The slimes dams will be reclaimed by hydraulic mining. During Hydraulic mining, the used process water mixes with the unconsolidated material of the slimes dams, resulting in what is known as a ‘slurry’. This slurry will be conveyed to the Ergo Processing Plant (hereafter Ergo Plant) for reprocessing using a newly constructed pipeline. Final deposition of reprocessed slurry will be on the licenced Brakpan/Withok TSF.

The following alternatives were considered during the scoping assessment phase:

Application for an Environmental Authorisation and Integrated Water Use Licence for the Proposed Reclamation of the

Marievale Tailings Storage Facilities, in Ekurhuleni Metropolitan Municipality - Gauteng Province

Executive Summary



2

The Proposed Project will investigate two pipeline routes to convey slurry from the TSFs to the Ergo Plant for reprocessing; and return process water to the project site for reclamation. The pipeline configuration would consist of two, 600 mm diameter, slurry pipelines and one, 600 mm diameter, process water pipeline. See Figure 1 below.

The first alternative pipeline route is approximately 25 km long and is made up of a two parts. The first part would be a 7 km extension from the project site to the Daggafontein Plant; while the second part would be a 17 km extension from the Daggafontein Plant to the Ergo Plant.

The second alternative route would be a 19 km extension from the Proposed Project site, directly to the Ergo Plant.

The proposed reclamation site will be situated in Zone 3 of the Gauteng Provincial Environmental Management Framework (GPEMF) (2018); and even though some parts of the proposed pipelines may be laid in Zones 1 and 5, they may require authorisation in terms of the National Water Act (Act No. 36 of 1998) (NWA) for Section 21 water uses. An Integrated Water Use Licence Application (IWULA) will be prepared and submitted in accordance with the Water Use Licence Application and Appeals Regulations 2017 published in GNR 267 on 24 March 2017 and will be supported by a Technical Report and other necessary supplementary report.



3

Figure 1: Locality map of the Proposed Project



4

ENVIRONMENTAL IMPACT OF THE MARIEVALE TSF PROJECT

The table below provides a scoping-level identification of proposed potential environmental impacts (physical, biological and social) associated with the Project. The identified preliminary environmental impacts will be further refined, calculated and assessed for all the feasible alternatives identified in the Environmental Impact Assessment (EIA) phase. Mitigation and management measures will also be suggested by the specialists for all impacts identified.

Ergo Mining (Pty)Ltd: The Marievale TSFs Reclamation Project Executive Summary


5

ENVIRONMENTAL COMPONENT COMPONENT TYPE POTENTIAL IMPACT SPECIALIST STUDY PLANNED FOR EIA

Physical Environment (non-living) Hydrology (including wetlands, surface water and ground water)

Potential for further acid mine drainage (AMD), increased heavy metal concentrations and increased sulphate concentrations in the adjacent Blesbokspruit and local groundwater if runoff from operations is not adequately managed through efficient storm water management structures;

Improved surface and ground water quality around the project area due to the removal of the TSFs;

Changes in natural surface water flow parameters due to the removal of the TSFs; Potential impact on drainage lines from access runoff during the operational phase of the project; Improved visual aesthetics of the area after the removal of the TSFs.

Surface Water Impact Assessment

Groundwater Impact Assessment

Wetland Impact Assessment

Biological Environment (living) Ecology and Biodiversity (including fauna and flora)

Disturbance of sites and species of ecological importance; Loss of migration corridors, and access to nesting and refuge areas, watering points, food supplies

for faunal species by removing the TSFs; Displacement of animal habitat by removing the TSFs; Removal of invasive species from the TSFs; Improvement of species diversity in the Blesbokspruit Wetland System by removing a pollution

source in the form of the TSFs; Long-term improvement of ecosystem health and functioning of the project area following

rehabilitation.

Biodiversity Impact Assessment

Cultural Environment Heritage Resources Should heritage resources be present in the area, the reclamation project could potentially impact these;

Destruction of a heritage resource, if the TSFs are older than 60 years, by reclaiming the TSFs.

Heritage Impact Assessment

Social and Economic Environment Employment Continued employment and job security; Continued investment in local economy; Removal of the dumps could eliminate the attraction of illegal/informal miners who seek gold.

Social Impact Assessment

Land-use Land use will change to an active reclamation site; Restoration and unlocking of land for future land uses. The removal of TSFs could result in the

extension of the Blesbokspruit Wetland System footprint; Better management and control of the area against illegal/informal mining.

Social Impact Assessment

Noise Increase in ambient noise levels during the operational phase; Disturbances to faunal species during the operational phase.

Noise Impact Assessment

Air Quality Possible increase in dust levels in some areas during operations; Overall removal of an air pollution source after the removal of the TSFs; Health impacts on livestock and people in proximity to the project site due to fine particulate

emissions during operational phase.

Air Quality Impact Assessment



6

CONCLUSION

At this stage, the findings of this scoping assessment indicate that the Proposed Project and its associated infrastructure would pose minimal and short-term negative environmental impacts if adequate and appropriate mitigation measures are implemented; and positive long-term environmental impacts when the project has been completed. Most importantly, the removal of these TSFs would assist with the alleviation of a major pollution source to the Blesbokspruit and Marievale Bird Sanctuary Nature Reserve (Ambani and Annegarn, 2015; McKay et al., 2018).

The impacts associated with the Proposed Project need to be considered further during the EIA Phase. It is important to take note of the current conditions of the Proposed Project area and the sensitive environment around it. The TSFs are a source of pollution and cause other direct and indirect nuisances to the surrounding environment. The Proposed Project is also in line with the Gauteng Mine Residue Area Strategy (2012), Ekurhuleni Metropolitan Spatial Development Framework (2011) and the Ekurhuleni Environmental Management Framework’s (2014) objectives to remove the TSFs littering Gauteng’s landscape, especially in ecologically sensitive areas.

In conclusion, the overall objective of this project is to recover residual gold from the Marievale TSFs and consequently allowing for the rehabilitation and clearance of the land currently occupied by these TSFs. Therefore, the land being cleared could be seen as a secondary or consequential product.

The clearing of this land is an extremely important and positive benefit, as the removal of the TSFs would result in the removal of a water, land and dust pollution source to a highly sensitive surrounding environment, as well as costs associated with TSF maintenance. When the TSFs have been reclaimed, rehabilitated and cleared of radiation, a closure certificate will be obtained, and the land will be levelled and revegetated to match the surrounding environment. This could result in the reinstatement of the natural drainage lines of the Blesbokspruit and the subsequent expansion of the Blesbokspruit Wetland System, as well as an improvement in the biodiversity of the Marievale Bird Sanctuary Nature Reserve (McKay et al., 2018).

The Proposed Project would also directly and indirectly contribute to the country’s Growth Domestic Product (GDP), while providing continued employment to current employees of Ergo.

ObjectiveTo evaluate the impact of the hydraulic reclamation process of the Marievale Tailings Storage Facilities (TSFs) on ambient air quality of the surrounding areas.

Method• Air dispersion modelling will be undertaken using AERMOD, the United States Environmental

Protection Agency’s preferred regulatory model for both simple and complex terrain. • Dispersion modelling simulations will be undertaken for three scenarios:

Current, undisturbed emissions.Emissions during the reclamation process.Emissions once the TSFs have been cleared and bare ‘red earth’ soil is exposed.

• Emissions will be included from clearing of vegetation and wind erosion.• PM2.5 and PM10 will be simulated because they are criteria pollutants and are associated with health

risks.• The result of the modelling will be evaluated against the National Ambient Air Quality Standards.

These standards prescribe the maximum ambient concentrations of pollutants permitted during a specified time period. If the air quality standards are exceeded, the ambient air quality is poor and the potential for health effects is greatest.

Position of the TSFs and wind rose based on WRF modelled wind data for the years 2016 – 2018.

Sources of Particulate Air PollutionDust emissions, due to wind erosion in exposed areas, occur when the threshold wind speed is exceeded (Cowherd, Muleski, & Kinsey, 1988; US EPA, 1995). Current Undisturbed Emissions

Low levels of organic matter and available nutrients, and unfavorable texture and structure are limitations to revegetation of most tailings (Hossner & Hons, 1992). The composition of TSFs makes exposed areas more susceptible to wind erosion than exposed soil - approximately 29% of TSF particles are smaller than 10 µm, as opposed to approximately 10% for soil. Aerial images show that the TSFs proposed for reclamation are sparsely vegetated. It is likely that the air quality of the areas surrounding the TSFs is already impacted by emissions from the tailings.

Emissions During the Reclamation ProcessThe reclamation process starts with clearing a band, approximately 15 metres wide, of all vegetation by means of graders. This increases the amount of material susceptible to wind erosion. Reclamation of the tailings by means of high-pressure water monitors (hydraulic cannons) will also create areas of ‘disturbed’ particles. However, the increase in moisture introduced by the hydraulic reclamation process will increase the cohesion of the particles and hence reduce the erodibility of the material. Areas over which the slurry runs can be expected to have no emissions while they are wet. Furthermore, these areas tend to form a crust as they dry out.

Emissions After the Reclamation ProcessAlthough bare soil will be exposed after the reclamation process, the particle size distribution will be less susceptible to wind erosion than tailings material. Therefore, in the long term, removal of these TSFs is expected to improve the air quality of the surrounding areas.

Health effects associated with exposure to Particulate Matter (WHO, 2004).

Short-term exposure Long-term exposure

• Lung inflammatory reactions.• Respiratory symptoms.• Adverse effects on the cardiovascular system.• Increase in medication usage.• Increase in hospital admissions.• Increase in mortality.

• Increase in lower respiratory symptoms.• Reduction in lung function in children.• Increase in chronic obstructive pulmonary

disease.• Reduction in lung function in adults.• Reduction in life expectancy.• Reduction in lung function development.

0,00

1,00

2,00

3,00

4,00

5,00

6,00

7,00

0.41 0.77 1.45 2.75 5.21 9.86 18.7 35.3 66.9 127 240 454

Volu

me

Den

sity

(%)

Particle Size Classes (µm)

Tailings Soil

Effects of Suspended Particulate Matter on Vegetation and CropsUnlike in the health sector, it is the coarser particles that have an effect on vegetation. Direct effects of dust deposition at the leaf and plant level include: • Blockage of stomata. • Alteration of energy exchange and light absorption which leads to reduced photosynthesis. • Changes in transpiration. • Reduced growth and production. Indirect effects include: • Reduced effectiveness of sprays (e.g. herbicides, insecticides) and, therefore, an increase in

incidence of pests. • Hindrance to pollination which results in yield loss. • Exacerbation of secondary stresses (e.g. drought, insects and pathogens). (Doley, 2006; Farmer, 1993; Grantz, Garner, & Johnson, 2003; Prajapati, 2012; Seyyednejad, Niknejad, & Koochak, 2011) It is, however , not only the rate of dust deposition that will determine whether plants are affected by dust. Leaf orientation, leaf morphology, leaf age, leaf wettability (Beckett, Freer-Smith, & Taylor, 2000; Prajapati & Tripathi, 2008) and environmental conditions such as wind and rain (Raupach, Woods, Dorr, Leys, & Cleugh, 2001) affect the dust loading of the leaves and, therefore, also influence whether vegetation will be affected by dust deposition.

Effects of Suspended Particulate Matter on Game and LivestockAccording to Stevens (Stevens, 2012), there is very little experimental evidence for the impacts of dust on pastures and livestock. Dust can cause respiratory and other health problems in animals as in humans, for example, ovine pneumonia and pinkeye. However, it is difficult to link possible impacts directly to one dust source as there are other sources of dust, such as the livestock themselves, on farms and in nature. Furthermore, most of the larger particles generally fall out within 300 m from the source (Greening, 2011; McCrea, 1984).

Effects of Suspended Particulate Matter on BirdsIn 2017, Sanderfoot and Holloway conducted a literature review of findings regarding avian responses to air pollution published since 1950 (Sanderfoot & Holloway, 2017). Their review found consistent evidence that birds are affected by exposure to a range of reactive gases and particles in the air. Avian responses to air pollution include:• Respiratory distress and illness.• Increased detoxification effort.• Elevated stress levels.• Immunosuppression.• Behavioural changes.• Impaired reproductive success. As a result, air pollution may reduce population density, species diversity, and species richness in bird communities. These demographic consequences are a result of both the direct, toxic effect of exposure to air pollution as well as habitat degradation resulting from poor air quality. However, there are knowledge gaps relating to quantitative measures of pollutants characterising the sensitivity of avian responses to specific contaminants. Therefore, based on current research, quantification of the impacts is not possible.

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Marievale Bird Sanctuary Provincial Nature ReserveDuduza

Lodeyko

Nuffield

Selcourt

Edelweiss

Struisbult

486 Scheme

Casseldale

Aston Lake

Sharon Park

Sharon Park

Daggafontein

Grootvaly AH

Selection Park


Kwa-Thema Phase 1

%,N17

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E k u r h u l e n i M e t r o p o l i t a n M u n i c i p a l i t yE k u r h u l e n i M e t r o p o l i t a n M u n i c i p a l i t y

DAGGAFONTEIN 125

GROOTFONTEIN 165

RIETFONTEIN 128

GROOTVALY 124

VLAKFONTEIN 130

KWA THEMA 210

GEDULD 123

VLAKFONTEIN 281 IRTSAKANE 217

RIETFONTEIN 276 IR

PALMIETKUILEN 241

MARIEVALE 282 IR

WITHOK 131

VOGELSTRUISBULT 127

WELTEVREDEN 118

THE SPRINGS 129

WITPOORTJE 117

DRAAIKRAAL 166

SPAARWATER 171

VLAKFONTEIN 161

KOOLBULT 121

VARKENSFONTEIN 169TSAKANE 260

VLAKFONTEIN 281 IR

WITKLIP 279

DUDUZA 259

HOLGATFONTEIN 326

MODDERFONTEIN 76

NEW STATE AREAS 126

VLAKFONTEIN 161 ZONNESTRAAL 163VIERFONTEIN 204

BLOEMENDAL 283 IR

Largo

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Daggafontein

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28,368136 28,385730 28,403324 28,420918 28,438512 28,456106 28,473700 28,491294 28,508888 28,526482

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Midvaal

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Merafong City

Mogale City

Emfuleni


Rand West City

Project Name : Marievale Reclamation ProjectCoordinateSystem : WGS84 Decimal DegressDate :10 October 2019

R e c l a m a t i o n o f t h e M a r i e v a l e D u m p s : P r o p o s e d P i p e l i n e A l t e r n a t i v e sR e c l a m a t i o n o f t h e M a r i e v a l e D u m p s : P r o p o s e d P i p e l i n e A l t e r n a t i v e s 1:60 000

0 1,5 30,75 Kilometers$


Proposed Pipeline to Daggafontein




Parent Farm



Mine Dumps Outlines

7L5

7L7

7L6

Ergo Plant

Daggafontein Plant

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Casseldale

Aston Lake

Sharon Park

Vosterkroon

Sharon Park

Daggafontein

Grootvaly AH

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Kwa-Thema Phase 1

%,N17%,N17

DAGGAFONTEIN 125

GROOTFONTEIN 165

RIETFONTEIN 128

WITHOK 131

VLAKFONTEIN 130

GROOTVALY 124

WITPOORTJE 117

KWA THEMA 210

VLAKFONTEIN 161 SPAARWATER 171

TSAKANE 217

MARIEVALE 282 IR

VARKENSFONTEIN 169

VLAKFONTEIN 281 IR

VOGELSTRUISBULT 127

THE SPRINGS 129

DRAAIKRAAL 166

WELTEVREDEN 118

HOLGATFONTEIN 326

KOOLBULT 121

GEDULD 123

TSAKANE 260

RIETFONTEIN 276 IR

PALMIETKUILEN 241

VLAKFONTEIN 281 IR

DRAAIKRAAL 166

WITKLIP 279

VIERFONTEIN 204

RIETFONTEIN 115

ZONNESTRAAL 163

DUDUZA 259

NEW STATE AREAS 126

Largo

Geduld

Duduza

Springs

Tsakane

Kwa-Thema

Geluksdal

Dunnottar

Marievale

Strubenvale

Daggafontein

VorsterkroonBl

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Blesbokspruit

28,350542 28,368136 28,385730 28,403324 28,420918 28,438512 28,456106 28,473700 28,491294 28,508888 28,526482

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Merafong City

Mogale City

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Rand West City

Project Name : Marievale Reclamation ProjectCoordinateSystem : WGS84 Decimal DegressDate :08 November 2019

R e c l a m a t i o n o f t h e M a r i e v a l eR e c l a m a t i o n o f t h e M a r i e v a l e Land Tenure 1:63 000

0 1,5 30,75 Kilometers$


Proposed Pipeline to Daggafontein




Parent Farm

Directly Affected Ownwers

Indirectly Affected Ownwers

Mine Dumps Outlines

7L5

7L7

7L6

Ergo Plant

Daggafontein Plant

MapID Parent Farms Farm Portion Owner

29/21028/21027/210

3/127RE/127

RIETFONTEIN 128 IR 96/12828/210

29/2102 DAGGAFONTEIN 125 IR RE/151/125 EAST RAND WATER CARE COMPANY3 WITPOORTJE 117 IR 183/117 ERGO MINING PTY LTD4 DAGGAFONTEIN 125 IR RE/154/125 Exxaro Base Metals (Pty) Ltd

92/13092/130

6 114/125 FONDAGTUIN LANDGOED CC7 125/125 GAUTENG PROVINCIAL GOVERNMENT8 146/125 GREATER EAST RAND METRO

93/125

112/12510 WITKLIP 279 IR RE/279 IPROP (Pty) Ltd12 MARIEVALE 282 IR 282 Marievale Nature Reserve13 RIETFONTEIN 128 IR 175/128 MUN SPRINGS14 VLAKFONTEIN 281 IR 9/281 National Government of the Republic of SA15 DAGGAFONTEIN 125 IR RE/127/125 PALMKUILEN PTY LTD

16 DAGGAFONTEIN 125 IR 159/125RAPPA RESOURCES PTY LTD

17 VLAKFONTEIN 281 IR RE/281 Scarlet Sun 33 (Pty) Ltd126/125

RE/1/125GROOTFONTEIN 165 IR 10/165

VOGELSTRUISBULT 127 IR 1/127RIETFONTEIN 128 IR RE/128WITPOORTJE 117 IR 150/117DAGGAFONTEIN 125 IR 104/125WITPOORTJE 117 IR RE/1/117

RE/1/124WITPOORTJE 117 IR 155/117KWA THEMA 210 IR 35/210DAGGAFONTEIN 125 IR 199/125DAGGAFONTEIN 125 IR 197/125WITPOORTJE 117 IR RE/1/117GROOTVALY 124 IR RE/1/124

122/125180/125182/125181/125110/125196/125

WITPOORTJE 117 IR 442/117DAGGAFONTEIN 125 IR 123/125KWA THEMA 210 IR 35/210

21 RIETFONTEIN 128 IR RE/81/128 Vereeniging Prop & Investment (Pty) Ltd22 108/125 W M G ESTATES PTY LTD23 117/125 C L P F PROP INV PTY LTD24 RE/113/125 CONSOLIDATED MODDERFONTEIN MINES 1979 LTD25 128/125 E B M PROJECT PTY LTD

DAGGAFONTEIN 125 IR

DAGGAFONTEIN 125 IR

Directly Affected Farm Owners

UR

KWA THEMA 210 IR


KWA THEMA 210 IR

VLAKFONTEIN 130 IR

DAGGAFONTEIN 125 IR

DAGGAFONTEIN 125 IR

19

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Ekurhuleni Metropolitan Municipality

First Trade & Invest 4 (Pty) Ltd

I & W VAN DER MERWE BOERDERY PTY LTD

STI CONSULTING SERVICES PTY LTD

Transnet Ltd

1

5

9

18

Map_ID Farm Portion Farm Portion Farm Owner GROOTFONTEIN 165 82/165RIETFONTEIN 128 IR 96/128VLAKFONTEIN 130 IR 92/130VLAKFONTEIN 130 IR 85/130

13 RIETFONTEIN 128 IR 175/128 MUN SPRINGSGROOTFONTEIN 165 RE/165DRAAIKRAAL 166 IR 2/166VOGELSTRUISBULT 127 IR 10/127GROOTFONTEIN 165IR 10/165GROOTFONTEIN 165IR 35/165GROOTFONTEIN 165IR 7/165VOGELSTRUISBULT 127 IR 7/127RIETFONTEIN 128 IR 7/128WITPOORTJE 117 IR 92/117RIETFONTEIN 128 IR 127/128GROOTFONTEIN 165 99/165DAGGAFONTEIN 125 IR 104/125DAGGAFONTEIN 125 IR 123/125KWA THEMA 210 IR 35/210

26 RIETFONTEIN 128 IR RE/135/128 Alstonville Investment (Pty) Ltd27 VOGELSTRUISBULT 127 IR 2/127 CITY COUNCIL OF SPRINGS

28 VLAKFONTEIN 130 IR10/130 ESKOM

GROOTFONTEIN 165 52/165GROOTFONTEIN 165 85/165

30 GROOTFONTEIN 165 29/165 INYANGA TRADING 102 PTY LTDRIETFONTEIN 128 IR 137/128RIETFONTEIN 128 IR 46/128

32 RIETFONTEIN 128 IR 128/128 REPUBLIEK VAN SUID-AFRIKA

Rand Water Board

Indirectly Affected Property Details

UR

Transnet Ltd

National Government of the Republic of SA

First Trade & Invest 4 (Pty) Ltd

Ekurhuleni Metropolitan Municipality

Greater Nigel Transitional Local Council

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19

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Sharon Park

Vosterkroon

Sharon Park

Daggafontein

Grootvaly AH

Selection Park


Kwa-Thema Phase 1

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%,N17

E k u r h u l e n i M e t r o p o l i t a n M u n i c i p a l i t yE k u r h u l e n i M e t r o p o l i t a n M u n i c i p a l i t y

DAGGAFONTEIN 125

GROOTFONTEIN 165

RIETFONTEIN 128

GROOTVALY 124

GEDULD 123

WITHOK 131

VLAKFONTEIN 281 IR

VLAKFONTEIN 130

PALMIETKUILEN 241

RIETFONTEIN 276 IR

WITPOORTJE 117

KWA THEMA 210

WELTEVREDEN 118

VLAKFONTEIN 161

TSAKANE 217

SPAARWATER 171

MARIEVALE 282 IR

VOGELSTRUISBULT 127

THE SPRINGS 129

VARKENSFONTEIN 169

DRAAIKRAAL 166

HOLGATFONTEIN 326

TSAKANE 260

MODDERFONTEIN 76

VLAKFONTEIN 281 IR

KOOLBULT 121

BLOEMENDAL 283 IR

RIETFONTEIN 115

WITKLIP 279

VIERFONTEIN 204DRAAIKRAAL 166

GEIGERLE 238

ZONNESTRAAL 163

DUDUZA 259

NEW STATE AREAS 126

Largo

Geduld

Duduza

Springs

Brakpan

Tsakane

Kwa-Thema

GeluksdalDunnottar

Marievale

Strubenvale

Daggafontein

282

7/281

5/276RE/131

19/241

RE/127

1/118

RE/276

7/128

191/125

5/128RE/1/117

4/165

2/281

RE/1/124

3/124

46/326

19/241

6/281

RE/124

48/124

7/166

RE/281

52/165

27/210

RE/9/241

RE/124/125

RE/129

RE/7/117

183/117

RE/81/128

77/118

204

RE/165

3/118

RE/1/125

29/171

33/128

RE/29/169

3/161

RE/154/125

25/161

35/210

8/125

13/124

85/165

17/124

76/165

9/281

19/241

10/161

10/283

44/161

71/130

RE/23/165

196/125

RE/166

RE/21/124

RE/124

1/165

21/130

65/130

47/326

4/28194/165

35/165

65/131

56/130

4/166

9/128

78/130

2/166RE/23/165

9/283

89/130

2/131

26/124

RE/44/165

94/165

44/129

1/260

22/130

90/165

1/128

52/123

29/165

20/125

62/123

198/125

146/125

2/326

RE/127

96/128

5/210

38/161

19/115

98/165

150/125

2/124

15/118

52/130

36/161

9/131

56/123

28/165

14/165

6/166

35/171

11/161

114/131

10/12353/76

RE/39/165

11/217

112/125

134/123

103/125

60/130

49/130

124/128

RE/3/76

117/125

42/165

27/129

125/125

16/210

94/165

8/123

121/125

21/123225/123

RE/75/169

RE/118

RE/5/121

120/125

RE/279

19/129

70/169

80/123

7/217

123/125

26/161

21/125

39/161

65/128

25/118

149/125

1/217

2/260

19/210

37/161

199/125

RE/51/165

75/131

159/125

187/128

34/130

RE/113/125

64/169

20/171

131/128

12/131

137/123

66/130

38/171

13/130

32/161

5/217

68/165

34/171

158/125

39/169

158/128

9/217

22/161

RE/124

43/1715/171

89/165

48/165

283/117

32/124

104/125

279/12310/124

196/125

122/125

2/128

10/217

32/129

14/210

22/171

13/281

RE/118

RE/98/125

30/165

22/124

7/210

10/210

83/125

6/161

4/241

RE/129

66/131

18/210

2/121

8/210

24/171

190/123

RE/43/165

1/210

RE/210108/125

49/165

RE/93/128

79/123

29/210

42/171

1/165

RE/151/125

118/131

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City of Tshwane

Lesedi

Midvaal

Ekurhuleni

Merafong City

Mogale City

Emfuleni


Rand West City

Project Name : Marievale Reclamation ProjectCoordinateSystem : WGS84 Decimal DegressDate : 10 October 2019 v3

R e c l a m a t i o n o f t h e M a r i e v a l e D u m p s : L o c a l i t y M a pR e c l a m a t i o n o f t h e M a r i e v a l e D u m p s : L o c a l i t y M a p 1:70 000

0 2 41 Kilometers

$

LegendPipelinesProposed Infrastructure

Proposed Pipeline from Daggafontein to Ergo Plant





Parent Farm

Farm Portion


Mine Dumps Outlines

7L5

7L7

7L6

Ergo Plant

Daggafontein Plant

Map ID Long (E) Lat (S) X YA 28.4967 -26.3310 -50252.48973 -2913599.506B 28.5105 -26.3278 -48869.51292 -2913240.943C 28.5098 -26.3321 -48936.7804 -2913726.11D 28.5071 -26.3369 -49206.6095 -2914250.064E 28.5027 -26.3348 -49647.70463 -2914025.842F 28.5026 -26.3351 -49657.84243 -2914058.078G 28.4990 -26.3336 -50014.49275 -2913889.156H 28.4963 -26.3327 -50282.35289 -2913790.181J 28.4966 -26.3317 -50259.88662 -2913679.501

WGS84 Decimal Degrees WGS 84 Lo 29 MetersCoordinates for Dump 7L5 and 7L6

Map ID Long (E) Lat (S) X YK 28.4979 -26.3445 -50120.86797 -2915095.039L 28.4996 -26.3433 -49949.052 -2914961.236M 28.5063 -26.3469 -49284.821 -2915359.45N 28.5053 -26.3506 -49383.37581 -2915775.341O 28.5000 -26.3510 -49908.02035 -2915813.999

WGS84 Decimal Degrees WGS 84 Lo 29 MetersCoordinates for Dump 7L7




Reclamation of the Marievale Tailings Storage Facilities, City of Ekurhuleni Metropolitan


Stakeholder Meeting

Date Wednesday, 5 February 2020

Time: 10H00

Venue: Gauteng Department of Agriculture and Rural Development (GDARD), 56 Eloff Street, Johannesburg

List of attendees:


Kongiwe Environmental (Pty) Ltd Mr Michael Hennessy Legal Director



Gauteng Department of Agriculture and Rural Development

Mr Erick Moletsane

CEO: B


Mr Mokutu Nketu CEO: B


Mr Tjatja Mosia CEO: B


1.1. Ms Vanessa Viljoen welcomed all present at the meeting. Please refer to Appendix A, for a


2. Agenda

❖ Important Notice of the meeting; ❖ Kongiwe’s Role as an Independent EAP; ❖ Project Background; ❖ Project Infrastructure; ❖ Proposed specialist Studies; ❖ Legislative Framework; ❖ Project Progress to date; and ❖ Question & Answers






4. Discussion


Mr Erick Moletsane Gauteng Department of Agriculture and Rural Development (GDARD)

Mr Erick Moletsane asked if a Waste Management Plan will be developed.

Mr Siphesihle Dambuza said that the Waste Management Plan will be developed as part of the Environmental Management Plan (EMP).

Mr Mokutu Nketu


Mr Mokutu Nketu indicated that GDARD’s Biodiversity

Department (Ms Albertina Setsiba) would need the shapefiles

to indicate if the water courses on the pipelines would be

affected.

Ms Vanessa Viljoen indicate that Shapefiles would be emailed as per

request.

Post meeting note:

Shapefiles were emailed on 14 February 2020 to Ms Albertina Setsiba and other officials from GDARD.

The meeting was adjourned at 11:00, Ms Vanessa Viljoen thanked all present for their attendance and input.



Appendix A

Attendance Register



Appendix B

Presentation


Focus Group Meeting:

05 February 2020



© 2019

❖ Discuss the proposed Marievale TSFs Reclamation Project;❖ Provide an overview of the Environmental Impact Assessment

process;❖ Provide GDARD with an opportunity to raise comments/ seek

clarity and provide input; and❖ Record comments raised and include in the Comments and

Responses Report.

Introductions

• Michael Hennessy– Legal Director



© 2019

Meeting Agenda


© 2019

Important Notice




© 2019

Kongiwe’s Role





comment and supply the Department of Mineral Resources and

Energy (DMRE) with the documentation so that they can determine

if the project should proceed or not.

© 2019





❖LOM: 20 years


❖The first alternative pipeline route is approximately 25 km long and runs from the lowest point ofdump 7L7, passing by the old Daggafontein Plant, to the Ergo Plant. This route follows existingSurface Right Permits (SRPs).



© 2019

© 2019

Project Description: The Process❖The tailings material from the Marievale TSFs will be reclaimed by using high-pressure water

cannons.

❖Reprocessing will take place at the Ergo processing plant


❖Final deposition of the processed slurry from the Ergo plant will be at the associated authoriseddeposition site, namely the Brakpan/Withok TSF

❖Two (slurry and return process water) pipeline routes will be investigated as alternatives for theproject

❖TCTA is being considered as an alternative process water make-up source, along with water fromRonderbult Water Treatment Works and Marievale 1 & 2 Shafts

❖Process water will operate as a closed circuit, meaning that limited make-up water will be requiredfor the reclamation

© 2019


❖Two overland slurry pipelines of 600 mm in diameter;

❖One overland return water pipeline of 600 mm in diameter;





Specialist Studies

© 2019







❖An integrated Environmental Authorisation (EA) application has beensubmitted to the DMRE as the Competent Authority for the proposedproject.

❖The applicable applications to be assessed by the DMRE are as follows:




© 2019

© 2020


❖The Final Scoping Report was accepted by the Department of Mineral Resources & Energy on

the 27th January 2020, along with permission to proceed with EIA/EMP.

❖The Draft EIA will be submitted on 18th March 2020.

❖A Public meeting is arranged for the 04th of April 2020 at 10H00 to 15H00 (venue to be

confirmed).


❖IWULA report will be subjected to 60 days public participation and will be submitted to the

DWS for their consideration during the EIA phase.


[email protected]







Stakeholder Meeting


Time: 13:30

Venue: Marievale Bird Sanctuary Provincial Nature Reserve, R42 Delmas road, Marievale Nature Reserve, Nigel

List of attendees:






Mr Rhulani Maluleke

Manager


Mr Joshua Quinton

PSGB


Ms Anga Yaphi

PS


Ms Albertina Setsiba PS




2. Agenda







4. Discussion


Ms Albertina Setsiba


Ms Setsiba asked where Ergo will source its water from and

whether there is existing infrastructure in place already?

Mr Michael Hennessy indicated that there is no existing infrastructure but there will be temporary administration buildings, including change houses and ablution facilities in addition to the pump stations and proposed pipelines. Process water options are being investigated including water sourced from the Brakpan/Withok TSF, it is a closed water circuit; the make-up water sources are still being investigated during the EIA phase of the proposed project. Possible sources are TCTA, the Marievale mine shafts and the Blesbokspruit, where Ergo has an extraction right.



Ms Setsiba indicated that the GDARD’s Biodiversity

Department would need the shapefiles of the proposed

pipeline routes to overlay onto their sensitivity maps and see

what will be affected?

Ms Vanessa Viljoen indicated that the shapefiles would be emailed as

requested.

Post meeting note:

Shapefiles were emailed on 14 February 2020 to Ms Albertina Setsiba and other officials from GDARD.

Ms Anga Yaphi


Ms Yaphi stated that the Biodiversity Specialist Studies should

be submitted to GDARD for evaluation.

Mr Michael Hennessy indicated that the Biodiversity Specialist studies are part of the EIA and will be available for comment in March 2020.




Appendix A

Attendance Register



Appendix B

Presentation




Proposed Reclamation of the Marievale Tailings Storage Facilities, City of Ekurhuleni


Stakeholder Meeting

Date Friday, 07 February 2020

Time: 12:00

Venue: IIangabi Mining, Brikor Plant 1 - Nigel

List of attendees:





Envass Mr Corrie Retief Consultant

IIangabi Mining Mr Murray Reid Manager

IIangabi Mining Ms Marguerite Lubbe Environmental Officer

IIangabi Mining Mr JC Le Grange Geologist

IIangabi Mining Ms Lebepa Komape SLP




2. Agenda







4. Discussion


Mr Murry Reid, Manager

IIangabi Mining

Mr Reid asked how spillage control will be handled on the project?

Mr Michael Hennessy indicated that Stormwater Management Plans (SWMPs) have been designed as a closed system (i.e. no discharge of dirty water to the environment). The stormwater measures proposed will separate clean and dirty water areas and will include open trapezoidal channels (trenches), berms and containment facilities (slurry sumps and paddocks).

Mr Corrie Retief

Environmental Consultant

Envass

Mr Retief asked if Kongiwe will be doing a waste licence under Category B of the NEM:WA.

Mr Michael Hennessy indicated although previously residue deposits and residue stockpiles were regulated in terms of the Mineral and Petroleum Resources Development Act (MPRDA) Regulations and in particular Regulation 73, the National Environmental Laws Amendments Act 25 of 2014 (NEMLAA) deleted section 4(b) from the NEM:WA and residue stockpiles and residue deposits thereafter fell within the ambit of the NEM:WA and its various regulations. Activity B 4(11) of GN 921, as amended by GN 633 of 24 July 2015 now refers to “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)”. It must be stressed that “residue stockpile and residue deposit” bear the meaning as per the MPRDA, and do not include historic mineral storage facilities created prior to 2004, as is the case with Marievale. Accordingly, Activity B4(11) does not apply. However, a WML will still be required under Section 20 of NEM:WA itself.

Mr JC Le Grange

Geologist

Ilangabi Mining

Mr Le Grange asked how long it will take to build the pipelines?

Mr Siphesihle Dambuza responded that the construction of the

pipelines depends on if and when authorisation is granted; however,

the proposed Life of Mine is 20 years.

Mr Corrie Retief

Environmental Consultant

Envass

Mr Retief asked if a Geohydraulic study will be undertaken as part of the EIA process, the Department of Water and Sanitation requires that a Geo study is conducted.

Mr Siphesihle Dambuza indicated that a Geohydrological study is being conducted as part of the identified specialist studies.




Appendix A

Attendance Register



Appendix B

Presentation






Stakeholder Meeting

Date Tuesday, 11 February 2020

Time: 13:30

Venue: Transnet Freight Rail, Isando offices Transnet, 1 Anvil Road, Isando, (Boardroom B, 7th Floor).

List of attendees:




Transnet Freight Rail Ms Mamothena Mothupi, Engineering Technician

Transnet Freight Rail Mr Qatjha Ramokhothoane

Transnet Freight Rail Mr Joseph Molautsi Chief Admin officer




2. Agenda







4. Discussion


Mr Qatjha Ramokhothoane

Transnet

Mr Qatjha Ramokhothoane indicated that Transnet would

need the KMZ Files of the proposed pipeline routes to overlay

onto Transnet infrastructure to see what will be affected.

Ms Vanessa Viljoen indicated that the KMZ files would be emailed to

Transnet.

Post meeting note:

KMZ files were emailed on 12 February 2020 to Mr Ramokhothoane and other relevant officials from Transnet




Appendix A

Attendance Register



Appendix B

Presentation






Stakeholder Meeting


Time: 10:00

Venue: Eskom, 08 Lakeview Crescent, Kleinfontein Office Park, Benoni

List of attendees:




Eskom Mr Jan Mitchell Land & Rights Development

Eskom Mr Sbu Nkalanga Land & Rights Development




2. Agenda







4. Discussion


Mr Sbu Nkalanga

Eskom

Mr Nkalanga indicated that Eskom would need the DWG Files

of the proposed pipeline routes to overlay onto Eskom

infrastructure to see what will be affected.

Ms Vanessa Viljoen indicated that the DWG would be emailed as per

request.

Post meeting note:

DWG files were emailed on 12 February 2020 to Mr Jan Mitchell and Mr Sbu Nkalanga.

Mr Jan Mitchell

Eskom

Mr Mitchell asked whether or not the pipelines will be running

above or below the ground?

Mr Siphesihle Dambuza indicated that the pipelines will be running above the ground and that pipe-jacking would be done wherever the pipelines cross over road reserves.

Mr Jan Mitchell

Eskom

Mr Mitchell said that according to the provided locality map,

the proposed Alternative Pipeline Route 2 could pose a

problem regarding existing Eskom infrastructure.

Mr Siphesihle Dambuza requested that once Eskom has received the DWG files, it should provide clarity on where exactly the Eskom infrastructure will be affected.




Appendix A

Attendance Register



Appendix B

Presentation






Stakeholder Meeting – Marievale

Date Thursday, 13 February 2020

Time: 10:00

Venue: Scarlet Sun 33 (Pty) Ltd, Nigel Brick and Clay (Pty) Ltd, No 2 Nigel Marievale Road, Vorsterskroon, Nigel

List of attendees:





Ergo Mining (Pty) Limited Mr Greg Ovens

Scarlet Sun 33 (Pty) Ltd Mrs Marinda Newton Accountant


1.1. Mr Bradly Thornton welcomed all present at the meeting. Please refer to Appendix A, for a


2. Agenda

❖ Important Notice of the meeting; ❖ Kongiwe’s Role as an Independent Environmental Assessment Practitioner (EAP); ❖ Project Background; ❖ Project Infrastructure; ❖ Proposed specialist Studies; ❖ Legislative Framework; ❖ Project Progress to date; and ❖ Question & Answers






4. Discussion


Mrs Marinda Newton


Mrs Newton indicated that Scarlet Sun 33 (Pty) Ltd has no objections to the reclamation of the dump 7L7 on its property, as it wishes to have the dump removed. The reclamation of the Tailings Storage Facilities (TSF) will give Scarlet Sun an opportunity to investigate the possibility of mining clay and coal underneath the area where the dump is located.

The comment is noted.

Mrs Marinda Newton


Mrs Newton indicated that IIangabi is a subsidiary of Brikor. Ilangabi has a clay mining right for the area in question. Scarlet Sun 33 (Pty) Ltd (Brick & Clay) and Brikor all work together.

The comment is noted.

Mrs Marinda Newton


Mrs Newton said that if the proposed pipeline route traverses Scarlet Sun 33 property, negotiations will need to be done with the property owner, Ms Elsie Parkin.

Mr Greg Ovens stated that the applicant is willing to enter into negotiations with the relevant parties.

Mrs Marinda Newton

Scarlet Sun 33 (Pty) Ltd Mrs Marinda Newton indicated that as Scarlet Sun, it is not too concerned with end land-use. The option of grassing seems sufficient.

Mr Greg Ovens indicated that the idea is to re-grass the proposed

project area after the dumps have been removed to match the

surrounding environment. This would alleviate issues such as dust to

the surrounding environment.

The meeting was adjourned at 11:00, Mr Bradly Thornton thanked all present for their attendance and input.



Appendix A

Attendance Register



Appendix B

Presentation






Stakeholder Meeting


Time: 12:30

Venue: EBM Project (Pty) Ltd, cnr Plover & Vogelstruisbult str, Struisbult, Springs, Gauteng, 1559

List of attendees:





Ergo Mining (Pty) Limited Mr Greg Ovens

EBM Project (Pty) Ltd Mr Niel West CEO

EBM Project (Pty) Ltd Mr Mduduzi Cebekhulu SHE


1.1. Mr Bradly Thornton welcomed all present at the meeting. Please refer to Appendix A, for a


2. Agenda

❖ Important Notice of the meeting; ❖ Kongiwe’s Role as an Independent EAP; ❖ Project Background; ❖ Project Infrastructure; ❖ Proposed Specialist Studies; ❖ Legislative Framework; ❖ Project Progress to date; and ❖ Question & Answers






4. Discussion


Mr Niel West


Mr West indicated that EBM Project has no objection to the proposed reclamation project or having the proposed pipeline run through its property as long as adequate planning and negotiations take place prior to the final layout.

Mr Greg Ovens indicated that such negotiations and planning can be done.

Mr Niel West

EBM Project (Pty) Ltd EBM Projects can supply Ergo with water for the reclamation project.

Mr Greg Ovens thanked Mr West for the offer, he indicated that the option of EBM supplying water for the proposed Marievale project will be investigated.

Mr Niel West


Northern half of dump 7L4 is on property that belongs to EBM and the property underneath the southern portion of the dump, along with dumps 7L5 and 7L6 belongs to the City of Ekurhuleni Metropolitan Municipality.

Noted.

The meeting was adjourned at 13:30, Mr Greg Ovens thanked all present for their attendance and input.



Appendix A

Attendance Register



Appendix B

Presentation






Stakeholder Meeting

Date Friday, 14 February 2020

Time: 11:00

Venue: Department of Human Settlements, Water and Sanitation (DHSWS), Room 385 394 Ndinaye House, 178 Francis Baard Street, Pretoria

List of attendees:





Mr Bashan Govender Water Quality Manager (National)


Mr Divan Van Niekerk

Water Quality (National


Ms Candace Enoch Environmental Officer


Mr Ayanda Mtetwa




2. Agenda







4. Discussion



Department of Human

Settlements, Water and

Sanitation

Mr Van Niekerk asked if Ergo has started discussions with the

TCTA or the other identified potential make-up process water

sources.

Mr Siphesihle Dambuza indicated that Ergo has ongoing discussions regarding all potential make-up water sources. Ergo is still evaluating the best possible options, because it is not just about the source of the water, but the quality of the water also needs to be considered. The Marievale shafts water quality also needs to be assessed as a potential source and the TCTA water has a lot of salinity, which is sourced from the treatment works and is being discharging into the Blesbokspruit.

Mr Bashan Govender

Department of Human


Sanitation

Mr Govender asked where the process water for the proposed

project will be coming from?

Mr Siphesihle Dambuza said that process water will be pumped from Withok/Brakpan TSF, and if there is a shortage, then make-up water will be sourced. Ergo is looking at the Marievale shafts 1 & 2, TCTA or the Rondebult water treatment works for make-up water. The best source will be investigated and identified during the EIA phase.


Department of Human


Sanitation

Mr Van Niekerk asked if the pipelines will be crossing rivers?

Mr Siphesihle Dambuza said the proposed pipeline routes would cross over water bodies and moreover the dumps are located adjacent to the Marievale Bird Sanctuary wetland. This will trigger Section 21 (c) and (i) water uses in the Water Use Licence Application (WULA).

Mr Bashan Govender

Department of Human


Sanitation

Mr Govender asked whether Kongiwe has presented the project to their DHSWS colleagues in regard to the WULA, even though it is still conceptional at this stage.

Mr Siphesihle Dambuza responded by stating that Kongiwe has not

had an opportunity to present the project to the DHSWS’ WULA

Department because the water use licence is still in pre-application

phase. Kongiwe is engaging with relevant DHSWS officials as the

application moves forward.

Mr Bashan Govender

Department of Human


Sanitation

Mr Govender asked what the rehabilitation plans will be once

the dumps have been fully reclaimed.

Mr Siphesihle Dambuza indicated that Ergo’s rehabilitation plan is to re-grass the project footprint, after appropriate radioactivity assessments and permits have been obtained from the National Nuclear Regulator (NNR), to match the surrounding environment. The property underneath dumps 7L5 and 7L6 belongs to City of Ekurhuleni; while dump 7L7 is on property owned by Scarlet Sun 33 (Pty) Ltd. The ultimate end land-use will be at their discretion.

Mr Bashan Govender Mr Govender stated that the DHSWS would support re-grassing

because he does not think much infrastructure can be put The comment is noted.



Department of Human


Sanitation

there. He further explained that the proposed project will be

on a delta formation and a wetland, and how the groundwater

is very near to the surface. He expressed that it would be

preferable to preserve the watershed that takes water to the

stream, as it would not be desirable for this wetland to get

bigger. He also stated that he is concerned that the phragmites

in the area can grow if the wetland gets bigger.

Mr Ayanda Mtetwa


Mr Mtetwa asked, in-terms of the Social Impact Studies, how

far is the nearest community / residents were in relation to the

proposed project site.

Mr Siphesihle Dambuza indicated that there is a coal/clay mine, a military base, and an informal settlement called Happiness Village in proximity to the proposed project site, but there are no other residential areas close to the dumps.

Mr Bashan Govender

Department of Human


Sanitation

Mr Govender asked what the Life of Mine for the project is? Mr Siphesihle Dambuza indicated that the Life of Mine for the project will be 20 years.




Appendix A

Attendance Register



Appendix B

Presentation






Stakeholder Meeting


Time: 10:00

Venue: Skype Call

List of attendees:


Kongiwe Environmental (Pty) Ltd (Kongiwe)

Ms Vanessa Viljoen Stakeholder Engagement Consultant



Vereeniging Property and Investments (Pty) Ltd

Mr Sam Hancock Financial Manager


1.1. Mr Siphesihle Dambuza welcomed all present on the Skype meeting.

2. Agenda

❖ Important Notice of the Meeting; ❖ Kongiwe’s Role as an Independent EAP; ❖ Project Background; ❖ Project Infrastructure; ❖ Proposed Specialist Studies; ❖ Legislative Framework; ❖ Project Progress to date; and ❖ Question & Answers



For a copy of the presentation, please refer to Appendix A.



4. Discussion


Mr Sam Hancock

Financial Manager

Vereeniging Property and Investment (Pty) Ltd

Mr Hancock indicated that on both the proposed pipeline routes, Vereeniging Property and Investment (Pty) Ltd properties will be affected. He also asked what the practical implications of that may be and whether or not the pipeline will be below or above ground.

Mr Michael Hennessy indicated that the proposed pipeline would be laid above ground and the pipeline would run below ground where it runs along a road reserve. The part of proposed pipeline route that will affect the property of Vereeniging Property and Investment (Pty) Ltd is aligned along existing surface right permits (SRPs), which are registered in favour of Ergo. SRPs are similar to servitudes in that they provide a right of way for Ergo construct and lay pipelines for mining purposes. Mr Michael Hennessy also indicated that when it is time for the engineering and construction of the pipelines, close contact with Vereeniging Property will be maintained, to ensure that impacts to its property will be minimised to the extent possible.

Mr Sam Hancock

Financial Manager


Mr Hancock asked if Kongiwe could please send a copy of the Surface Right permit certificates in question.

Mr Siphesihle Dambuza indicated that a copy of the SRPs will be

emailed to Mr Sam Hancock.

Post meeting:

The Surface Right Permit certificates, shapefiles and the Locality Map were emailed to Mr Hancock on 20 February 2020.

Mr Sam Hancock

Financial Manager


Mr Hancock asked what the building line restrictions around the pipelines were, the reason for asking this was that Vereeniging Property plans to build a shopping centre development along the northern boundary of the proposed pipeline crossing its property, as well as a small residential development. He went on to ask if the pipeline is going to impact its proposed developments. He also stated that he has observed that the proposed pipeline route runs along property where shopping centre and housing developments have already been built.

Mr Michael Hennessy said that as long as there is no encroachment into the width of the pipeline SRPs, he does not see any further building restrictions.

Mr Sam Hancock

Financial Manager


Mr Hancock stated that Vereeniging Property is busy with

subdivisions of these properties and cannot remember seeing

any pipeline servitude by Ergo anywhere.

He went on to explain that it is 3 years down the line with applications for subdivisions and permissions for a shopping centre, and none of this information has formed part of its

Mr Michael Hennessy said he would not have seen the servitude,

because it is an SRP which, while being similar to a servitude, is not

registered against the title deed. Kongiwe would send a copy of it so

he can see where it is and if it will affect the properties. He also

explained that Kongiwe would email him a copy of the actual SRPs and

the shapefiles of the alignment of the SRP pipeline route.



application and any of its other future planning. He conceded that from what he can see, this is going to have a significant impact, and that its town planner needs to look at that.

Mr Sam Hancock

Financial Manager


Mr Hancock asked how practical it is to drive over these pipelines or will they be buried underground, and he indicated that it is impossible for a pipeline like this not to intersect road somewhere.

Mr Michael Hennessy said that when the pipeline intersects a road, generally pipe-jacking is done to take it underneath the road or underneath a water course.

Mr Sam Hancock

Financial Manager


Mr Hancock explained that his main concern is access to its development sites and the pipelines running through its properties. He also said it is difficult to see on the locality map where the pipeline will be running exactly.

Mr Siphesihle Dambuza asked that Mr Hancock have a look at the Shapefiles and SRP pipeline routes and let Kongiwe know where it will have an impact on the Vereeniging Properties and Investment Developments.

The meeting was adjourned at 11:00, Ms Vanessa Viljoen thanked all attended for their input.



Appendix A

Attendance Register



Appendix B

Presentation


Focus Group Meeting:

February 2020


Introductions



© 2019


© 2019


process;❖ Provide I&APs with an opportunity to raise comments/ seek


Responses Report.

Meeting Agenda


© 2019

Important Notice




© 2019

Kongiwe’s Role








© 2019





❖LOM: 20 years





© 2019

© 2019


❖The tailings material from the Marievale TSFs will be reclaimed by using high-pressure

water cannons.



❖Final deposition of the processed slurry from the Ergo plant will be at the associated




❖TCTA is being considered as an alternative process water make-up source, along with water

from Ronderbult Water Treatment Works and Marievale 1 & 2 Shafts

© 2019








Specialist Studies

© 2019












© 2019

© 2020




❖The Draft EIA will be submitted on 18th March 2020.

❖A Public meeting is arranged for the 04th of April 2020 at 10H00 to 15H00 (venue to be

confirmed).


❖IWULA technical report will be subjected to 60 days public participation and will be submitted

to the DWS for their consideration during the EIA phase.


[email protected]







Stakeholder Meeting

Date Thursday, 19 March 2020

Time: 10:00

Venue: Skype Call

List of attendees:


Kongiwe Environmental (Kongiwe) Mr Bradly Thornton Environmental Consultant

Kongiwe Environmental Mr Michael Hennessy Legal Director

Kongiwe Environmental Ms Gerlinde Wilreker Technical Director

Kongiwe Environmental Ms Vanessa Viljoen Stakeholder Engagement Consultant

INSA Coal Mr Bjorn Goosen Project Manager

Bishop Fraser Attorneys Mr Davide Bishop Attorney

Elemental Sustainability Mr DuToit Wilken Environmental Consultant


1.1. Mr Bradly Thornton welcomed all present on the Skype meeting.

2. Agenda

❖ Important Notice of the Meeting; ❖ Kongiwe’s Role as an Independent EAP; ❖ Project Background; ❖ Project Infrastructure; ❖ Proposed Specialist Studies; ❖ Legislative Framework; ❖ Project Progress to date; and ❖ Question & Answers



For a copy of the presentation, please refer to Appendix A.



4. Discussion


Mr DuToit Wilken Elemental Sustainability

Mr Wilken stated that during the presentation Mr Thornton indicated that the final land use is in discussion with the landowners; he asked for these to be identified.

Mr Bradly Thornton indicated that there are two landowners, on the northern side the dumps 7L5 and 7L6 are owned by Ekurhuleni Municipality and 7L7 is owned by a company by the name of Scarlet Sun (Pty) Ltd.

Mr Davide Bishop Attorney

Mr Bishop asked if Ergo Mining (Pty) Ltd is the owner of the dumps. If so, what will the final land use and rehabilitation be?

Mr Bradly Thornton indicated that Ergo Mining (Pty) Ltd is the legal owner of the dumps. Kongiwe Environmental’s recommendation is to rehabilitate the footprints and consider including the areas into the Marievale Bird Sanctuary, so that it could be expanded. The landowners have not yet given any firm commitment.

Mr Bjorn Goosen INSA Coal

Mr Goosen asked to clarify that Ergo Mining (Pty) Ltd only has title to the dumps but not the land underneath

Mr Bradly Thornton said that is correct, Ergo Mining (Pty) Ltd only owns the dumps and not the land.


Mr Wilken asked where is the slurry going to be pumped to and be stored.

Mr Bradly Thornton indicated that the actual reclamation activity takes place at the Marievale slimes dams where the tailings are converted into a slurry, which will be pumped along one of the two pipeline options to the Ergo Plant. The Ergo Plant is the gold plant next to the N17 towards Springs, which is used for reprocessing most of Ergo’s tailings material. From there the resultant tailings will be pumped to the Withok / Brakpan tailings facility (TSF), which is an existing authorised facility. This TSF is used as the deposition site for all the tailings reclamation projects in the Eastern Witwatersrand.


Mr Wilken asked if Mr Thornton can please list all the specialist studies that would be done for this project.

Mr Bradly Thornton indicated that the following Specialist Studies are being done as listed below:

• Traffic

• Heritage

• Fauna / Flora and Wetlands

• Air Quality

• Surface Water

• Social Impact Assessment

• Noise

• Groundwater


Mr Goosen indicated that INSA Coal will review the EIA and give Kongiwe Environmental comments.

Noted.


Mr Goosen explained that their main concerns are the following:

Mr Thornton noted the queries and indicated these areas were being investigated during the EIA phase.



• The suggested pipelines that run over wetlands will need to be investigated, especially over Marievale.

• What is the planned state of the ground to be left in (Farming, grazing)

• On rehabilitation, once the dumps have been removed, what will the chemical compounds be on the ground, why would Marievale Bird Sanctuary which is a National Park include the area into its property.

• Will a Risk Assessment be undertaken, to show how a spillage from the storm water management facility would be prevented from flowing into the Blesbokspruit?

Have the Marievale Bird Sanctuary and the Blesbokspruit Forum been contacted?

Mr Bradly Thornton said that Kongiwe is in consultation with the Marievale Bird Sanctuary and the Blesbokspruit Forum.


Mr Goosen indicated that the main concern is that INSA Coal has applied for wetland offset to mitigate its mining activities. He indicated that specific designated areas cannot be yet provided, because several alternatives have been suggested to DHSWS, and final comments are still pending. Only after approval by DHSWS can the exact offset point be identified for Kongiwe. Therefore, if the mine is going to invest major funds into establishing a wetland and so forth, the concern is regarding pollution and basically mitigation measures recommended by Kongiwe in that regard.

Mr Bradly Thornton noted Mr Goosen’s concern and Kongiwe would like to look at this in the EIA process. Mr Thornton asked Mr Goosen to please circulate approximate area for the proposed wetland offsets so that these can be integrated into the Marievale studies if required.


Mr Goosen indicated that Kongiwe will apply within the water use licence and the EIA for a reduced buffer on the Blesbokspruit to get this mining activity approved. INSA would like to be consulted in that regard to the reduced buffer area so as to understand the wetland specialist studies.

Mr Bradly Thornton said that Ergo would need to apply for the reduced buffer and INSA will be consulted as an IAP on the project.


Mr Goosen also said that he would like to suggest that Kongiwe apply for the 50-day extension on the EIA process in regard to the submission of the EIA/EMPr, to allow for further public consultation. This is a large project due to the pipelines, so in cancelling your public meeting. I think personally that is a mistake. I understand why you are doing it under the circumstances we

Mr Bradly Thornton said thank you for the suggestion it is noted. Post meeting note: The timeframes are at this moment extended, or regarded as being extended, by the number of days of the duration of the National State of Disaster declared for the COVID-19 pandemic in Government Notice No. 313 in Government Gazette No. 43096 of 15 March 2020,



are going through. My suggestion is to apply for the 50 day extension and push the meeting out to a later date to when this is over or reduced in whatever the case might be.

with effect from 27 March 2020 until the termination of the national state of disaster. This was communicated to all stakeholders.

Mr Bradly Thornton Kongiwe Environmental

Mr Thornton indicated that he would distribute the presentation to everyone who attended that meeting and that minutes will be compiled and sent. He also indicated that the EIA Reports are available on the Kongiwe Environmental Website for INSA Coal to comments.

Mr Goosen said thank you and confirmed that he had downloaded the

EIA/EMPr.


Mr Bradly Thornton asked Mr Goosen to clarify the state of the Bloemendal Project, how far is the authorisation.

Mr Goosen indicated that the EIA has been approved, and it is now is in the final stage of the NEMA appeals process. INSA is waiting for the minister’s comments and review on the appeals. INSA is still waiting for the Water Use Licence, which takes time.

The meeting was adjourned at 10:30, Mr Bradly Thornton thanked all attendees for their input.



Appendix A

Attendance Register



Appendix B

Presentation

Environmental Authorisation Process for the Marievale TSF Reclamation Project

Consultation:

INSA COAL

19 March 2020


Introductions

• Bradly Thornton - Project Manager

• Michael Hennessy – Legal Director

• Gerlinde Wilreker – Technical Director



© 2020



process;❖ Provide I&APs with an opportunity to raise comments/ seek


Responses Report.

© 2020

Meeting Agenda


© 2020

Important NoticeThis meeting is a formal consultation in terms of the requirements as stipulated in the:

o National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA) for an Applicationfor an Environmental Authorisation (EA) for listed activities triggered in Listing Notices GN R983,GN R984 and GN R985 in terms of the Environmental Impact Assessment (EIA) Regulations, 2014(as amended). The Department of Mineral Resources and Energy (DMRE) will be the CompetentAuthority to assess the EA for the proposed project.

o National Water Act, 1998 (Act No.36 of 1998) (NWA) for an Integrated Water Use LicenceApplication (IWULA) in accordance with the Act. The Department of Human Settlements Waterand Sanitation (DHSWS) will be the Competent Authority to assess the IWULA for the proposedproject.

© 2020

Kongiwe’s Role








© 2020





❖LOM: 20 years





© 2020


❖The tailings material from the Marievale TSFs will be reclaimed by using high-pressure

water cannons.



❖Final deposition of the processed slurry from the Ergo plant will be at the associated




❖TCTA is being considered as an alternative process water make-up source, along with water

from Rondebult Water Treatment Works and Marievale 1 & 2 Shafts

© 2020

© 2020








© 2020

Specialist Studies






© 2020





o An Integrated Water Use Licence Application (IWULA) will beundertaken in accordance with the National Water Act, 1998 (ActNo.36 of 1998) (NWA). The Department of Human SettlementsWater and Sanitation will be the Competent Authority to assess theIWULA for the proposed project

© 2020

© 2020




❖The Draft EIA available for public review from 19th March 2020 for 30 days.

❖ http://www.kongiwe.co.za/publications-view/public-documents/

❖A Public meeting has been cancelled due to COVID-19


❖IWULA technical report will be subjected to 60 days public participation and will be submitted

to the DHSWS for their consideration during the EIA phase.

© 2020

http://www.kongiwe.co.za/publications-view/public-documents/


[email protected]


Page | 12

APPENDIX C:


❖ Appendix C9 – Comments and Responses Report

Comments and Response Report for the Final Environmental Impact Assessment Report Project: Proposed Marievale Reclamation Project

Project Proponent: Ergo Mining (Pty) Ltd © 2020 Kongiwe Environmental (Pty) Ltd

1

Table of Contents

Table of Contents ............................................................................................................................................................................................................................................................................................................................... 1

Comments and Response Report: Final Environmental Impact Assessment Report .............................................................................................................................................................................................................................. 2

1.1 Directly Affected Landowners ...................................................................................................................................................................................................................................................................................................................... 2

1.2 Directly Affected Farm/Land Occupiers ..................................................................................................................................................................................................................................................................................................... 10

1.3 Directly Affected Farm Workers ................................................................................................................................................................................................................................................................................................................ 10

1.4 Adjacent Landowners and Farm/Land Occupiers ..................................................................................................................................................................................................................................................................................... 10

2.1 Local Municipality ...................................................................................................................................................................................................................................................................................................................................... 10

3.1 Department of Environmental Affairs ....................................................................................................................................................................................................................................................................................................... 15

3.2 Department of Mineral Resources ............................................................................................................................................................................................................................................................................................................ 15

3.3 Department of Water and Sanitation ........................................................................................................................................................................................................................................................................................................ 21

4.1 Interested and Affected Parties ................................................................................................................................................................................................................................................................................................................. 24



2

Comments and Response Report: Final Environmental Impact Assessment Report

INTERESTED AND AFFECTED PARTIES DATE OF

COMMENTS

RECEIVED

ISSUES RAISED EAPS RESPONSE TO ISSUES AS MANDATED BY THE APPLICANT SECTION REFERENCE

IN THE EIA REPORT CATEGORY

NAME OF INDIVIDUAL CONSULTATION

METHOD

1.1 Directly Affected Landowners

Mr John Duncan Patcon Sales (Pty) Ltd

Written Comment 24 October 2019

Please note that in regard to the reclamation of tailings dams by Ergo Mining at Marievale TSF`s 7L5,7L6 and 7L7 we have the following comments: We currently crush dump rock on the adjacent mining right and are prepared to remove the rock cladding from the Ergo site at a cost of R5,00 per ton, after Gold residues have been reclaimed.

We thank you for the email and have passed this information onto the applicant.

Section 2.3. Mining Operations

Mr Sam Hancock Vereeniging Property & Investments (Pty) Ltd

Written Comment 12 November 2019

The proposed route to Marievale will have the pipeline running along our Southern and Western boundaries. Our operations include clay mining, brick making, landfill and property development. There is a concern as to the impacts of the pipeline on our proposed developments.

We note your concern regarding the impact of the proposed pipelines on your land and proposed developments. At this stage we are at a high-level scoping / screening study, thereafter we will move into more detailed specialist studies and the EIA compilation phase. As part of the EIA phase we are obliged to investigate numerous options from an environmental impact perspective and recommend the least intrusive option. This is why there are a few pipeline options being investigated. These pipelines generally follow existing servitudes and reserves where possible; any pipeline which is proposed to traverse your property will need to be adequately assessed and agreed upon with yourself.

Section 2.3. Pipelines

Mr Johan Minnaar JM Property and Mineral Rights Consultants


I act under instructions and a mandate received from Palmietkuilen (Edms) Bpk the registered owner of Portions 124 (a portion of Portion 118), and Portion 127 (a portion of Portion 118) of the Farm Daggafontein 125 IR. Schoeman Boerdery (Pty) Ltd is farming the land, which is also my client, and which I also represent. Both entities are hereinafter referred to as ("my client"). (the above-mentioned property is hereinafter referred to as “the affected property”). Schoeman Boerdery (Pty) Ltd is a registered water user and is lawfully entitled to take water for irrigation purposes from the Blesbokspruit water source in terms of the provisions of Section 21(a) of the National Water Act, 1998 for the commercial production of crops on the above-mentioned properties.

Noted. Thank you for the information.

N/A Legislation



3


COMMENTS

RECEIVED




METHOD

My client, as landowner and commercial farmer of the above-mentioned property, is an Affected and Interested Party in terms of the provisions of the Mineral and Petroleum Resources Development Act, No. 28 of 2002 (“MPRDA”), as amended by the Mineral and Petroleum Resources Development Amendment Act, No. 49 of 2008 (“MPRDAA”) the Environmental Impact Assessment Regulations, No. R 982 of 4 December 2014 promulgated in Regulation Gazette No. 10328, as amended (“EIAR”) read with the National Environmental Management Act, No.107 of 1998 (“NEMA”), and the National Water Act, No. 36 of 1998 (“NWA”).



You as the Environmental Assessment Practitioner (“ EAP”) must register my client as Affected and Interested Party as such, and put its detail, and my firm as its authorized consultant, on their data base for this Project, and notify and advise my client and the writer with all public consultation notices and future documents and correspondences regarding the consultation process.

We confirm that Palmietkuilen (Edms) Bpk and Schoeman Boerdery (Pty) Ltd is already a registered Interested and Affected Party (I&AP) for the proposed project. We have included your details in our I&AP database as per your request. All registered I&APs are sent notifications of public consultation and the availability of documents for review.

Appendix C1 Stakeholder Engagement



I refer to the Draft Scoping Report ("DSR"), which was made available to interested and affected parties, including my client. The following comments and concerns to the DSR are hereunder documented for inclusion into the final Scoping Report.

Noted.

Appendix C9 EAP



Kindly note that affected and interested parties must have at least 30 days to submit comments, inter alia, the DSR in terms of the provisions of Regulation 40(2) of the EIAR. It is noted on page v of the DSR "The DSR will be made available for public review from 23 October 2019 to 21 November 2019", which is less than at least 30 days and contrast to the above quoted provisions. My client requires your undertaking that its comments as set out in this letter will be included in the submission of the final Scoping Report to the leading authority.

As advertised, the Public Participation Timeframe from 23 October to 21 November 2019 is exactly 30 days as prescribed in the NEMA EIA Regulations of 2014 (as amended). Notwithstanding that the period for public comment on the Draft Scoping Report closed on 21 November 2019, in good faith your email has been captured in the Comments and Response Report that will be lodged as part of the EIA/EMPr Process. Any further future correspondence will form part of the EIA process too.




It is noted that various Environmental Specialised Studies will be undertaken during the EIA/EMPr phases of the process. My client requires you to make the various Specialised Reports available for further comments.

The specialist studies undertaken will form part of the documentation that will be made available during a further 30 day comment period of the EIA Phase.

Appendix D EAP



My client is a commercial farmer and is dependable on water from the Blesbokspruit for irrigation purposes. Water depletion and contamination, especially with regard to the Blesbokspruit will cause irreparable damage and loss to his farming operations and crop production.

Your client’s concern is recorded. The purpose of the specialist studies and the EIA is to identify the impacts the proposed reclamation project will have on the Blesbokspruit. It must be noted that your client’s properties are approximately 5km upstream of the reclamation activities and therefore the

Appendix B1 Surface Water



4


COMMENTS

RECEIVED




METHOD

water quality and quantity at your client’s abstraction point are unlikely to be affected by the reclamation activities situated downstream. This will be confirmed during the EIA process.



My client is opposed to the construction and laying of any section of pipeline(s) over its properties, or the establishment of any access roads thereon. Any pipeline crossing that will disrupt the farming operations of my client on the affected properties must first be discussed and negotiated with my client, as my clients may suffer damages and loss due to the placing of such crossings.

Your client’s opposition is recorded. It is not the intention of the project to disrupt your client’s operations. As such, the exact location of the pipelines (and any required access roads) will be discussed with your client during the EIA phase. We would like to ensure positive collaboration between your client and the applicant. Legally, the Applicant would need to seek permission to cross your property in any way.

Section 2.3. Pipelines / Infrastructure



The letter is written without any prejudice to the rights of my client which are duly reserved.

Noted. Appendix C9 Legislation

Mr Ferdi Willemse Project Manager Dalmar

Written Comment 14 January 2020 I am responding herein on behalf of Alstonville Investment (Pty) Ltd, which entity falls under the Dalmar Group’s control.

This comment has been noted. Appendix C9

Stakeholder Engagement


Written Comment 14 January 2020

I have studied the locality plan, attached as page 11 to the background information document dated 15 October 2019, as provided by you under cover of your correspondence under reply, and it appears that the proposed pipeline to Marievale, (coloured orange on the plan), will pass our property (the Remainder of Portion 135 of the farm Rietfontein 128 IR) to the south thereof, but will not cross it directly. We accept that this assumption is correct, based on your indication that our aforementioned property is affected “indirectly”.

That is correct, the proposed pipeline to Ergo Plant runs just south of the farm Rietfontein 128 IR, portion 135 and does not intersect the said property; therefore, it is considered to be indirectly affected.

Appendix B Pipelines



Kindly provide us with a plan that clearly indicates the position of the proposed pipeline to Marievale, in relation to the boundaries of our subject property. The plan provided, even when enlarged, does not indicate this information clearly.

Please see the updated Land Tenure map attached.

Appendix B Land Tenure



Kindly note that an application for the establishment of the proposed Selcourt Extension 23 township on our property is in process.

This comment has been noted. Could Alstonville Investment kindly provide details of the planned extension for our consideration during the Environmental Impact Assessment phase of the project.

N/A EAP



Thank you for the email, please be so kind and provide us with the following documents for us to give informed comments on your scoping report.

• Acceptance letter • NEMA application • KML files with plants and activities planned • KML file with pipeline routes

Copy of existing or historical rights

Please find the acceptance letter for the application attached. N/A EAP

Applications for Environmental Authorisation are not in the ordinary course in the public domain. The Scoping Report already in your hands sets out precisely the content of the EA application.

N/A EAP

Please find the KML files of the proposed pipeline routes and dump outlines attached.

N/A EAP

The historic mineral storage facilities were created prior to the promulgation of the Mineral and Petroleum Resources Development Act, 2002 (Act No 28 of 2002) (MPRDA) and are accordingly not regulated by the MPRDA. No mining right in terms of the MPRDA is being applied for.

N/A

EAP



5


COMMENTS

RECEIVED




METHOD


Written Comment 27 January 2020 Have you applied for a water use licence? Kongiwe Environmental is currently undertaking a Water Use

Licence Application. The application is currently at the Pre-Application phase.

N/A EAP


Written Comment 27 January 2020 Please register us as Interested and affected party. INSA Coal Holdings has been registered as an I&AP of the

Marievale TSFs Reclamation Project. Appendix C1


Ms Albertina Setsiba Gauteng Department of Agriculture and Rural Development (GDARD) For Marievale Bird Sanctuary Provincial Nature Reserve

Focus Group Meeting

5 February 2020 Ms Setsiba asked where Ergo will source its water from and whether there is existing infrastructure in place already?

Mr Michael Hennessy indicated that there is no existing infrastructure but there will be temporary administration buildings, including change houses and ablution facilities in addition to the pump stations and proposed pipelines. Process water options are being investigated including water sourced from the Brakpan/Withok TSF, it is a closed water circuit; the make-up water sources are still being investigated during the EIA phase of the proposed project. Possible sources are TCTA, the Marievale mine shafts and the Blesbokspruit, where Ergo has an extraction right.

2.3.4 Pipelines / Infrastructure & Mining Operations

Ms Albertina Setsiba Gauteng Department of Agriculture and Rural Development (GDARD) For Marievale Bird Sanctuary Provincial Nature Reserve

Focus Group Meeting

5 February 2020 Ms Setsiba indicated that the GDARD’s Biodiversity Department would need the shapefiles of the proposed pipeline routes to overlay onto their sensitivity maps and see what will be affected?

Ms Vanessa Viljoen indicated that the shapefiles would be emailed as requested. Post meeting note: Shapefiles were emailed on 14 February 2020 to Ms Albertina Setsiba and other officials from GDARD.

N/A Pipelines / Infrastructure

Ms Anga Yaphi Gauteng Department of Agriculture and Rural Development (GDARD) For Marievale Bird Sanctuary Provincial Nature Reserve

Focus Group Meeting

5 February 2020 Ms Yaphi stated that the Biodiversity Specialist Studies should be submitted to GDARD for evaluation.

Mr Michael Hennessy indicated that the Biodiversity Specialist studies are part of the EIA and will be available for comment in March 2020.

Appendix D1 Biodiversity

Mr Murry Reid, Manager IIangabi Mining

Focus Group Meeting

07 February 2020 Mr Reid asked how spillage control will be handled on the project?

Mr Michael Hennessy indicated that Stormwater Management Plans (SWMPs) have been designed as a closed system (i.e. no discharge of dirty water to the environment). The stormwater measures proposed will separate clean and dirty water areas and will include open trapezoidal channels (trenches), berms and containment facilities (slurry sumps and paddocks).

Appendix D2 Stormwater Management

Mr Corrie Retief Environmental Consultant Envass

Focus Group Meeting

07 February 2020 Mr Retief asked if Kongiwe will be doing a waste licence under Category B of the NEM:WA.

Mr Michael Hennessy indicated although previously residue deposits and residue stockpiles were regulated in terms of the Mineral and Petroleum Resources Development Act (MPRDA) Regulations and in particular Regulation 73, the National Environmental Laws Amendments Act 25 of 2014 (NEMLAA) deleted section 4(b) from the NEM:WA and residue stockpiles and residue deposits thereafter fell within the ambit of the NEM:WA and its various regulations. Activity B 4(11) of GN 921, as amended by GN 633 of 24 July 2015 now refers to “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

Chapter 4 Legislation



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Development Act, 2002 (Act No. 28 of 2002)”. It must be stressed that “residue stockpile and residue deposit” bear the meaning as per the MPRDA, and do not include historic mineral storage facilities created prior to 2004, as is the case with Marievale. Accordingly, Activity B4(11) does not apply. However, a WML will still be required under Section 20 of NEM:WA itself.

Mr JC Le Grange Geologist Ilangabi Mining

Focus Group Meeting

07 February 2020 Mr Le Grange asked how long it will take to build the pipelines? Mr Siphesihle Dambuza responded that the construction of the pipelines depends on if and when authorisation is granted; however, the proposed Life of Mine is 20 years.


Mr Corrie Retief Environmental Consultant Envass

Focus Group Meeting

07 February 2020 Mr Retief asked if a Geohydraulic study will be undertaken as part of the EIA process, the Department of Water and Sanitation requires that it be conducted.

Mr Siphesihle Dambuza indicated that a Geohydrological study is being conducted as part of the identified specialist studies.

Appendix D3 EAP

Mr Niel West EBM Project (Pty) Ltd Focus Group

Meeting

13 February 2020 Mr West indicated that EBM Project has no objection to the proposed reclamation project or having the proposed pipeline run through its property as long as adequate planning and negotiations take place prior to the final layout.

Mr Greg Ovens indicated that such negotiations and planning can be done.


Mr Niel West EBM Project (Pty) Ltd

Focus Group Meeting

13 February 2020 EBM Projects can supply Ergo with water for the reclamation project.

Mr Greg Ovens thanked Mr West for the offer, he indicated that the option of EBM supplying water for the proposed Marievale project will be investigated.

N/A Mining Operations

Mr Niel West EBM Project (Pty) Ltd Focus Group

Meeting

13 February 2020 The northern half of dump 7L4 is on property that belongs to EBM and the property underneath the southern portion of the dump, along with dumps 7L5 and 7L6 belongs to the City of Ekurhuleni Metropolitan Municipality.

Noted. Appendix B2 Land ownership

Mrs Marinda Newton Scarlet Sun 33 (Pty) Ltd

Focus Group Meeting

13 February 2020 Mrs Newton indicated that Scarlet Sun 33 (Pty) Ltd has no objections to the reclamation of the dump 7L7 on its property, as it wishes to have the dump removed. The reclamation of the Tailings Storage Facilities (TSF) will give Scarlet Sun an opportunity to investigate the possibility of mining clay and coal underneath the area where the dump is located.

The comment is noted. N/A Stakeholder Engagement


Focus Group Meeting

13 February 2020 Mrs Newton indicated that IIangabi is a subsidiary of Brikor. Ilangabi has a clay mining right for the area in question. Scarlet Sun 33 (Pty) Ltd (Brick & Clay) and Brikor all work together.

The comment is noted. N/A EAP


Focus Group Meeting

13 February 2020 Mrs Newton said that if the proposed pipeline route traverses Scarlet Sun 33 property, negotiations will need to be done with the property owner, Ms Elsie Parkin.

Mr Greg Ovens stated that the applicant is willing to enter into negotiations with the relevant parties.


Mrs Marinda Newton Scarlet Sun 33 (Pty) Ltd Focus Group

Meeting

13 February 2020 Mrs Marinda Newton indicated that as Scarlet Sun, it is not too concerned with end land-use. The option of grassing seems sufficient.

Mr Greg Ovens indicated that the idea is to re-grass the proposed project area after the dumps have been removed to match the surrounding environment. This would alleviate issues such as dust to the surrounding environment.

Section 9.4 Rehabilitation

Mr Sam Hancock Financial Manager Vereeniging Property and Investment (Pty) Ltd

Focus Group Meeting

20 February 2020

Mr Hancock indicated that on both the proposed pipeline routes, Vereeniging Property and Investment (Pty) Ltd properties will be affected. He also asked what the practical implications of that may be and whether or not the pipeline will be below or above ground.

Mr Michael Hennessy indicated that the proposed pipeline would be laid above ground and the pipeline would run below ground where it runs along a road reserve. The part of proposed pipeline route that will affect the property of Vereeniging Property and Investment (Pty) Ltd is aligned along existing surface right permits (SRPs), which are registered in favour of Ergo. SRPs are similar to

Appendix B Pipelines / Infrastructure



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servitudes in that they provide a right of way for Ergo construct and lay pipelines for mining purposes. Mr Michael Hennessy also indicated that when it is time for the engineering and construction of the pipelines, close contact with Vereeniging Property will be maintained, to ensure that impacts to its property will be minimised to the extent possible.


Focus Group Meeting

20 February 2020 Mr Hancock asked if Kongiwe could please send a copy of the Surface Right permit certificates in question.

Mr Siphesihle Dambuza indicated that a copy of the SRPs will be emailed to Mr Sam Hancock. Post meeting: The Surface Right Permit certificates, shapefiles and the Locality Map were emailed to Mr Hancock on 20 February 2020.

N/A Stakeholder Engagement


Focus Group Meeting

20 February 2020

Mr Hancock asked what the building line restrictions around the pipelines were, the reason for asking this was that Vereeniging Property plans to build a shopping centre development along the northern boundary of the proposed pipeline crossing its property, as well as a small residential development. He went on to ask if the pipeline is going to impact its proposed developments. He also stated that he has observed that the proposed pipeline route runs along property where shopping centre and housing developments have already been built.

Mr Michael Hennessy said that as long as there is no encroachment into the width of the pipeline SRPs, he does not see any further building restrictions.



Focus Group Meeting

20 February 2020

Mr Hancock stated that Vereeniging Property is busy with subdivisions of these properties and cannot remember seeing any pipeline servitude by Ergo anywhere. He went on to explain that it is 3 years down the line with applications for subdivisions and permissions for a shopping centre, and none of this information has formed part of its application and any of its other future planning. He conceded that from what he can see, this is going to have a significant impact, and that its town planner needs to look at that.

Mr Michael Hennessy said he would not have seen the servitude, because it is an SRP which, while being similar to a servitude, is not registered against the title deed. Kongiwe would send a copy of it so he can see where it is and if it will affect the properties. He also explained that Kongiwe would email him a copy of the actual SRPs and the shapefiles of the alignment of the SRP pipeline route.



Focus Group Meeting

20 February 2020 Mr Hancock asked how practical it is to drive over these pipelines or will they be buried underground, and he indicated that it is impossible for a pipeline like this not to intersect road somewhere.

Mr Michael Hennessy said that when the pipeline intersects a road, generally pipe-jacking is done to take it underneath the road or underneath a water course.



Focus Group Meeting

20 February 2020

Mr Hancock explained that his main concern is access to its development sites and the pipelines running through its properties. He also said it is difficult to see on the locality map where the pipeline will be running exactly.

Mr Siphesihle Dambuza asked that Mr Hancock have a look at the Shapefiles and SRP pipeline routes and let Kongiwe know where it will have an impact on the Vereeniging Properties and Investment Developments.



Focus Group Meeting Email Correspondence

19 March 2020, 31 March 2020

Thank you for the first draft of the minutes. Please find the comments on the minutes attached. Please send the minutes again before finalising it.

As noted above, the minutes have been finalised incorporating your changes.




19 March 2020, 31 March 2020

The planned offset for the Bloemendal project is also attached. Please note that the location will finalise with DHSWS. The rehabilitated dumps cannot be a viable alternative as it will be too costly to rehabilitate the area to the ecological class required.

Thank you for providing us with the proposed location of the Bloemendal wetland offset plan. We take note of the location upstream of the proposed Marievale TSFs reclamation project.

Section 1.5 Mining Operations



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However, any pollution from the reprocessing and rehabilitated dump can have a significant impact on the sustainability of the offset.



19 March 2020, 31 March 2020

In terms of Public Participation, please take note of the following: The following timeframes are at this moment extended, or regarded as being extended, by the number of days of the duration of the National State of Disaster declared for the COVID-19 pandemic in Government Notice No. 313 in Government Gazette No. 43096 of 15 March 2020, with effect from 27 March 2020 until the termination of the national state of disaster: (aa) Timeframes prescribed in terms of the Environmental Impact Assessment Regulations 2014, published in terms of section 24(5) of the National Environmental Management Act, 1998 (Act No. 107 of 1998), or as contained in any environmental authorisation issued in terms of the Environmental Impact Assessment Regulations, 2014, including any condition contained in an environmental authorisation relating to the period of validity of an environmental authorisation, the period relating to an extension of the validity period of an environmental authorisation and the requirement to submit an environmental audit report, which periods lapses or falls within the period of the duration of the national state of disaster; (bb) Timeframes prescribed in terms of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) and National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004) relating to licensing and environmental authorisations;

Noted, the public participation timeframes were extended by the lockdown period as communicated to all stakeholders during this period.


Mr DuToit Wilken Elemental Sustainability Focus Group

Meeting 19 March 2020

Mr Wilken stated that during the presentation Mr Thornton indicated that the final land use is in discussion with the landowners; he asked for these to be identified.

Mr Bradly Thornton indicated that there are two landowners, on the northern side the dumps 7L5 and 7L6 are owned by Ekurhuleni Municipality and 7L7 is owned by a company by the name of Scarlet Sun (Pty) Ltd.

Section 1.4 Land Use / ownership

Mr Davide Bishop Attorney

Focus Group Meeting

19 March 2020 Mr Bishop asked if Ergo Mining (Pty) Ltd is the owner of the dumps. If so, what will the final land use and rehabilitation be?

Mr Bradly Thornton indicated that Ergo Mining (Pty) Ltd is the legal owner of the dumps. Kongiwe Environmental’s recommendation is to rehabilitate the footprints and consider including the areas into the Marievale Bird Sanctuary, so that it could be expanded. The landowners have not yet given any firm commitment.

Section 2.3.7.6 Rehabilitation


Focus Group Meeting

19 March 2020 Mr Goosen asked to clarify that Ergo Mining (Pty) Ltd only has title to the dumps but not the land underneath

Mr Bradly Thornton said that is correct, Ergo Mining (Pty) Ltd only owns the dumps and not the land.

N/A Land ownership


Focus Group Meeting

19 March 2020 Mr Wilken asked where is the slurry going to be pumped to and be stored.

Mr Bradly Thornton indicated that the actual reclamation activity takes place at the Marievale slimes dams where the tailings are converted into a slurry, which will be pumped along one of the two pipeline options to the Ergo Plant. The Ergo Plant is the gold plant next to the N17 towards Springs, which is used for reprocessing most of Ergo’s tailings material. From there the resultant tailings will be pumped to the Withok / Brakpan tailings facility (TSF), which is an existing authorised facility. This TSF is used as the

Section 2.3 Pipelines / Infrastructure



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deposition site for all the tailings reclamation projects in the Eastern Witwatersrand.


Focus Group Meeting

19 March 2020 Mr Wilken asked if Mr Thornton can please list all the specialist studies that would be done for this project.

Mr Bradly Thornton indicated that the following Specialist Studies are being done as listed below:

• Traffic

• Heritage

• Fauna / Flora and Wetlands

• Air Quality

• Surface Water

• Social Impact Assessment

• Noise

• Groundwater

Appendix D Specialist Studies


Focus Group Meeting

19 March 2020 Mr Goosen indicated that INSA Coal will review the EIA and give Kongiwe Environmental comments.

Noted.



Focus Group Meeting

19 March 2020

Mr Goosen explained that their main concerns are the following:

• The suggested pipelines that run over wetlands will need to be investigated, especially over Marievale.

• What is the planned state of the ground to be left in (Farming, grazing)

• On rehabilitation, once the dumps have been removed, what will the chemical compounds be on the ground, why would Marievale Bird Sanctuary which is a National Park include the area into its property.

• Will a Risk Assessment be undertaken, to show how a spillage from the storm water management facility would be prevented from flowing into the Blesbokspruit?

Have the Marievale Bird Sanctuary and the Blesbokspruit Forum been contacted?

Mr Thornton noted the queries and indicated these areas were being investigated during the EIA phase. Mr Bradly Thornton said that Kongiwe is in consultation with the Marievale Bird Sanctuary and the Blesbokspruit Forum.

Section 7.4 Section 2.3.7.6 Section 8.2 Appendix C8



Focus Group Meeting

19 March 2020

Mr Goosen indicated that the main concern is that INSA Coal has applied for wetland offset to mitigate its mining activities. He indicated that specific designated areas cannot be yet provided, because several alternatives have been suggested to DHSWS, and final comments are still pending. Only after approval by DHSWS can the exact offset point be identified for Kongiwe. Therefore, if the mine is going to invest major funds into establishing a wetland and so forth, the concern is regarding pollution and basically mitigation measures recommended by Kongiwe in that regard.

Mr Bradly Thornton noted Mr Goosen’s concern and Kongiwe would like to look at this in the EIA process. Mr Thornton asked Mr Goosen to please circulate approximate area for the proposed wetland offsets so that these can be integrated into the Marievale studies if required.

Section 7 Appendix E

Wetlands


Focus Group Meeting

19 March 2020

Mr Goosen indicated that Kongiwe will apply within the water use licence and the EIA for a reduced buffer on the Blesbokspruit to get this mining activity approved. INSA would like to be consulted in that regard to the reduced buffer area so as to understand the wetland specialist studies.

Mr Bradly Thornton said that Ergo would need to apply for the reduced buffer and INSA will be consulted as an IAP on the project.

Section 4 Legislation



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Focus Group Meeting

19 March 2020

Mr Goosen also said that he would like to suggest that Kongiwe apply for the 50-day extension on the EIA process in regard to the submission of the EIA/EMPr, to allow for further public consultation.

This is a large project due to the pipelines, so in cancelling your public meeting. I think personally that is a mistake. I understand why you are doing it under the circumstances we are going through. My suggestion is to apply for the 50 day extension and push the meeting out to a later date to when this is over or reduced in whatever the case might be.

Mr Bradly Thornton said thank you for the suggestion it is noted.

Appendix C6 EAP


Focus Group Meeting

19 March 2020

Mr Thornton indicated that he would distribute the presentation to everyone who attended that meeting and that minutes will be compiled and sent.

He also indicated that the EIA Reports are available on the Kongiwe Environmental Website for INSA Coal to comments.

Mr Goosen said thank you and confirmed that he had downloaded the EIA/EMPr.

N/A Stakeholder engagement


Focus Group Meeting

19 March 2020 Mr Bradly Thornton asked Mr Goosen to clarify the state of the Bloemendal Project, how far is the authorisation.

Mr Goosen indicated that the EIA has been approved, and it is now is in the final stage of the NEMA appeals process. INSA is waiting for the minister’s comments and review on the appeals.

INSA is still waiting for the Water Use Licence, which takes time.

N/A EAP

1.2 Directly Affected Farm/Land Occupiers

No comments received yet.

1.3 Directly Affected Farm Workers


1.4 Adjacent Landowners and Farm/Land Occupiers


2.1 Local Municipality


Focus Group Meeting

6 November 2019

Mr Makhudu Molepo asked if the proposed project will pose any negative impacts on the groundwater?

Mr Bradly Thornton said that that a groundwater impact assessment will be undertaken to investigate any impact on groundwater.

Appendix D3 Groundwater


Focus Group Meeting

6 November 2019

Ms Anél Hietbrink indicated that there seems to be a lot of Tailings Storage Facilities (TSFs) reclamation projects and all the applicants state that that the slimes will go to the Brakpan/Withok TSF. As indicated in the presentation, the average life of mine is 20 years, asked if Brakpan/Withok TSF does not have enough capacity where the applicant will dispose the slurry.

Mr Bradly Thornton said that Brakpan/Withok TSF has enough capacity, there is also an updated design submitted to DWS for the facility.




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Focus Group Meeting

6 November 2019

Mr Hennie Croucamp Asked if the pipeline routes will be included as part of the Environmental Authorisation process.

Mr Bradly Thornton indicated that the pipelines are part of the authorisation process for the proposed Marievale project.

N/A Pipelines


Focus Group Meeting

6 November 2019

Mr Croucamp stated that one of the problems the Municipality has had in Boksburg (Sunward Park) specifically, was several pipes burst over the last 10 years which make a big mess of slurry everywhere in the suburbs as part of the reclamation of the Elsburg Complex. How does the applicant intend to prevent the pipelines from bursting?

He also inquired if the possibility of pipeline spillages will be considered in the Environmental Impact Assessment process?

Kongiwe cannot comment on Elsburg, but Kongiwe will raise the issue with Ergo Mining. Ergo has environmental incident prevention measures in place that include monitoring for and reporting on incidents according to:

❖ The categories set out in the NNR Certificate ofRegistration;

❖ Chapter 23 of the Mine Health and Safety Act which setsout Regulations for the Reporting of Accidents andDangerous Occurrences; and

❖ GN 704, Regulation 2 with respect to any possible effecton a watercourse.

Emergency response plans are incorporated in the EIA/ EMPr documents.

Appendix E Pipelines


Focus Group Meeting

6 November 2019

Mr Johan Koekemoer asked if the pipelines will be traversing residential areas.

Mr Bradly Thornton indicated that it is a mixture of rural and residential areas. Mr Thornton said that the impacts of the pipelines will be investigated.

Section 3.5 Pipelines


Focus Group Meeting

6 November 2019

Ms Hietbrink asked if a new pipeline will be constructed or the applicant will use existing pipelines.

Mr Bradly Thornton said that there are no existing pipelines and the applicant intends to construct only new pipelines. The project team will assess the overall impacts of new pipelines.

N/A Pipelines


Focus Group Meeting

6 November 2019

Mr Hennie Croucamp asked if there are servitudes in place for these pipelines.

Mr Bradly Thornton said that the project team is currently assessing existing servitude and surface right permits records to see where additional rights of way are required.

Appendix B Pipeline Servitudes


Focus Group Meeting

6 November 2019

Mr Croucamp requested clarity in terms of the colour coding for the different pipeline routes indicated in the map.

Mr Siphesihle Dambuza referred to the locality map and indicated the pipeline routes.

Appendix B Pipelines



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Focus Group Meeting

6 November 2019

Mr Molepo asked if the project team has identified environmental liabilities regarding pipeline spillages.

Concerned that should there be spillages, cyanide will be released to the surrounding environment.

Mr Molepo enquired about the procedures to be followed should there be measures in place.

Mr Bradly Thornton indicated Mr Molepo’s concern will be relayed to the applicant and will also be addressed as part of the EIA process.

Emergency response plans are incorporated in the EIA/ EMPr documents.

Appendix E Pipelines


Focus Group Meeting

6 November 2019

Mr Makhudu Molepo Inquired if the project team has a list of hazardous materials associated with the slurry. If there is such a list, Mr Molepo requested for such a list to be included in the Scoping Report.

Mr Molepo added that it is the responsibility of the Municipality to safeguard the public therefore it is important to know about the risks associated with the proposed project.

Noted. Mr Bradly Thornton said that an Emergency response plan will be developed as part of the EIA process.

Appendix E Waste Management


Focus Group Meeting

6 November 2019

Ms Rakgoale asked if the pipelines are crossing through urban areas, will there be enough space for the pipelines.

Ms Rakgoale asked if pipeline route alternatives be considered as part of the EIA process.

Mr Bradly Thornton said that the project team will assess three alternatives from an environmental point of view.

Mr Thornton said that in accordance with the EIA regulations, alternatives should be assessed. The project team will investigate the best route and take specialist studies into consideration.



Focus Group Meeting

6 November 2019

Ms Hietbrink asked if there are connections for sewage disposals. If not, what alternatives will the applicant be looking at for sewage disposal and capacity etc.

Ms Hietbrink added that the Municipality capacity constraints on wastewater treatment works as well as the sewage works.

She also asked if the applicant will be using portable toilets, the Municipality needs to be informed about where the toilets will be placed. If it is within the city sewage system, the applicant, needs to indicate where will the sewage from the honey suckers be disposed and effluent permits should be obtained.

Mr Bradly Thornton said that will be investigated. As far as the project team is aware, the applicant will be using portable toilets through an appropriate contractor.

Appendix E Waste Management


Focus Group Meeting

6 November 2019

Ms Rakgoale asked if the pipelines will be constructed above or below ground?

Mr Bradly Thornton indicated that the pipelines will be constructed above ground.

N/A Pipelines

Ms Anél Hietbrink City of Ekurhuleni Metropolitan Municipality

Focus Group Meeting

6 November 2019

Ms Anél Hietbrink indicated that she was concerned about the bottom section where the slurry to be processed is connected at the lowest point which is close to a wetland. Ms Hietbrink enquired about the mitigation measures to prevent impacts on the wetland.

Mr Bradly Thornton said that groundwater and surface water assessments will be undertaken and will investigate adequate mitigation measures.

Appendix D2 and Appendix D3

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Environmental Assessment Practitioner & Waste Management


Focus Group Meeting

6 November 2019

Mr Koekemoer asked if the Daggafontein plant is used, where will the slurry go?

Mr Bradly Thornton indicated that all slurry materials will be taken to the Ergo Plant and residue will be disposed of on the Brakpan / Withok TSF. The Daggafontein Plant is not owned by Ergo Mining and will not be used.

Section 2.3. Mining Operations


Focus Group Meeting

6 November 2019

Mr Johan Koekemoer indicated that with the increase of the slurry on the Brakpan / Withok TSF, there will be an increase in dust, the dust from that site also needs to be reduced. Mr Koekemoer asked if there are processes in place to address this concern.

Mr Bradly Thornton indicated that the Brakpan / Withok TSF is a licenced and managed facility which has active dust management activities taking place.

N/A Air Quality


Focus Group Meeting

6 November 2019

Mr Johan Koekemoer asked what happens to pipelines over a long period of time, they become radioactive active? You also get scavengers who cut the pipes and take it to scrap yards, causes a huge problem with radioactive waste ending up at scrap yards/ He requested clarity in terms of how pipelines will be rehabilitated.

Mr Bradly Thornton said that pipelines need to be removed when they are no longer operational. Radioactivity will be assessed on the pipeline scrap before they are sold to registered scrap dealers.

N/A Pipelines / Rehabilitation

Ms Cecilia Rakgoale City of Ekurhuleni Metropolitan Municipality

Environmental Assessment Practitioner

Focus Group Meeting

6 November 2019

Ms Cecilia Rakgoale asked if all the mine dumps are on privately owned land.

Ms Rakgoale said that the end land use should be guided by specialists, so that it is not just used for residential purposes. The cleaned-up areas should be compatible with the current systems.

Mr Bradly Thornton indicated the TSFs are on publicly and privately owned land and that the specialist will be advising on the potential end land use.

Section 9.4 Land Use

Ms Lillian Kwakwa City of Ekurhuleni Metropolitan Municipality Environmental Assessment Practitioner

Focus Group Meeting

6 November 2019

Ms Lillian Kwakwa asked if the dumps will be removed at the same time?

Mr Bradly Thornton indicated that the dumps are likely to be removed one at a time.



Focus Group Meeting

6 November 2019

Mr Makhudu Molepo asked if Kongiwe is aware of the new development of a mall, across phase 1 open land behind Corobrik. The municipality has received an application.

Mr Hennie Croucamp said it is an application that was rejected by the municipality as far as he is aware.

N/A EAP


Focus Group Meeting

6 November 2019

Ms Rakgoale indicated that the proposed pipelines traverses through wetlands, this needs to be adequately addressed as part of the EIA.

Mr Bradly Thornton said that this matter will be investigated in the impact assessment phase.

Appendix D Wetlands



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Focus Group Meeting

6 November 2019

Ms Anél Hietbrink asked that if the movement of the slurry from Ergo plant to Brakpan/Withok TSF is on existing pipeline, that it must also be included into your report, because there might also be risks, stating that we have to look at the process from start to end. She also suggested that the project team should identify risks associated with moving the slurry from Ergo plant to the Withok TSF.

Mr Thornton said thank you for the comment it is noted. The Brakpan/Withok TSF and the pipeline thereto from the Ergo Plant are authorised and managed activities.



Focus Group Meeting

6 November 2019

Mr Hennie Croucamp indicated that the Military Base west of the dumps is the new PRASA Gibela Rail Consortium Dunnottar Factory, which is a huge piece of land that appears on the Municipality’s Arial photos, but that Springs/Nigel road is running next to that. The location of the pipeline-Wall of that land on the west of Springs/Nigel road running right down has already got an approved residential township from the Gauteng Department of Human Settlements. We do not want to sterilise the land with a pipeline going through that area.

Mr Bradly Thornton indicated that the project team consults with PRASA. Mr Thornton indicated that the project team will consult with Gauteng Department of Human Settlements on this matter.



Focus Group Meeting

6 November 2019

Ms Anél Hietbrink expressed that the EIA needs to consider the Municipality’s future developments such as housing etc. The consideration of future developments will ensure that there is no sterilization of land etc.

Mr Bradly Thornton said that the Applicant attempts to place pipelines on existing servitudes, surface right permits and wayleaves as far as possible.

Appendix B1 Pipeline Servitudes


Focus Group Meeting

6 November 2019

Mr Hennie Croucamp said that east of military base all of that is outside of the Municipality’s urban edge. That urban edge basically runs around the back of the Dunnottar Factory, down below 7L5, 7L6, the urban boundary runs around that. This has implications for future land uses. What should be considered; the dump to the south cannot really be considered for anything else but agriculture. The two dumps to the north the applicant can consider using the land for a cemetery.

Mr Bradly Thornton thanked Mr Croucamp for the suggestion.

N/A Land Use


Focus Group Meeting

6 November 2019

Requested to be sent shape files / KMZ.

Mr Croucamp indicated that the project team can get information from the GIS department, they have updated Arial Photos.

Post meeting note: Ms Nokuthula Ndala from Kongiwe Environmental emailed Mr Croucamp the requested KMZ files. the KMZ and requested information.

N/A EAP


Focus Group Meeting

6 November 2019

Ms Anél Hietbrink asked if land has been identified where the infrastructure e.g. offices, change houses will be constructed for the proposed project.

Mr Bradly Thornton said that usually pump stations are constructed at the lowest topographical point of the dump footprint. As for offices and the change house. Generally, the applicant will try to stay within the dump footprint, so they remove a bit of material and work within the dump footprint. There is not a lot of infrastructure.

Appendix B3 Infrastructure

Ms Anél Hietbrink Focus Group Meeting

6 November 2019 Ms Anél Hietbrink requested for infrastructure to be clearly marked on the maps.

Mr Bradly Thornton said infrastructure will be marked on the maps in the EIA phase.

Appendix B3 Mapping



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City of Ekurhuleni Metropolitan Municipality Environmental Assessment Practitioner & Waste Management


Focus Group Meeting

6 November 2019

Mr Hennie Croucamp asked what stops the dumps from giving way, like with Merriespruit. The wall just gives way like a dam and washes into the spruit.

Mr Bradly Thornton indicated that if the dumps are dry, they are safer, it is when the dumps have lots of water on top of them, that there is a danger of the walls can break.


3.1 Department of Environmental Affairs

No comments received.

3.2 Department of Mineral Resources

No comments received.

Department of Health

Ms Crystal Rosenberg, Johannesburg District Health


Ms Crystal Rosenberg asked if any construction or operations will take place in Johannesburg? I see Witpoortjie is mentioned for the pipeline.

We thank you for your mail. This project falls entirely within Ekurhuleni Municipality. The actual Tailings Storage Facilities are located adjacent the Marievale Bird Sanctuary and the pipelines link with the existing ERGO plant near Brakpan.

Please refer to the map in the background information document and please feel free to be in touch with any further queries.

Appendix B1 Stakeholder Engagement


Mr S. Mukhola Gauteng Department of Agriculture and Rural Development (GDARD)

Written Comment 04 December 2019

Mr S. Mukhola said that based on the outcome of the Wetland Delineation and Assessment Report, the Department advises the applicant to investigate using horizontal directional drilling (HDD) when crossing wetland systems with high-risk rating.

This comment is noted and the feasibility of horizontal directional drilling (HDD) will be investigated by the Applicant.

N/A Wetlands



Mr S. Mukhola said that clarity must be given in the final scoping report as the area between Site 1 and Site 2 falls within the Marievale Bird Sanctuary Provincial Nature Reserve; a wetland according to the Gauteng Conservation Plan Version 3.3, this is not reflected in the pipeline route alternatives discussion which states that both alternatives avoid traversing through any watercourses.

Noted, both pipeline alternatives are likely to traverse through the said area. This will be evaluated and addressed during the EIA phase of the Proposed Project.




Mr S. Mukhola said that the final scoping report must also provide details on the construction and rehabilitation phase of the above-ground HDPE lined steel pipeline through the Marievale Bird Sanctuary Provincial Nature Reserve.

Details on the construction and rehabilitation phase of the above-ground HDPE lined steel pipeline, through the Marievale Bird Sanctuary Provincial Nature Reserve, will be assessed and provided during the EIA phase of the Proposed Project.


Mr S. Mukhola Written Comment 04 December 2019

Mr S. Mukhola said that the report states that a newspaper advertisement was placed in The Springs Advertiser on Thursday,

The media tear sheet was only received after the submission of the Draft Scoping Report. However, the media advert was then Appendix C

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24 October 2019, and contained in Appendix C4 of the Public Participation Report, this advertisement was not placed in the report and must be included in the final scoping report.

included and submitted with the Final Scoping Report. A copy of the advert is attached to this letter.


Gauteng Department of

Agriculture and Rural

Development (GDARD).

Written Comment 26 February 2020

Ms Albertina Setsiba said that with regard to the proposed _TCTA

Pipeline project, specialist biodiversity studies are required to

investigate the following aspects:

• Plants, with specific reference to Habenaria bicolor.

• Mammals, with specific reference to Lutra maculicollis

(Spotted-necked-otter).

• Birds, with specific reference to the confirmed habitat for

African marsh Harrier (Circus ranivorus) & Tyto capensis (

African Grass owl).

• Site falls within Gauteng IBA

• primary Vegetation (Blesbokspruit Highveld grassland &

Tsakane Clay Grassland).

• Wetlands and Pans

• Perennial and non- Perennial Rivers,

• Outside urban areas

• Affect part of the Ramsar site( Blesbokspruit) and is within

medium use zone of Marievale.

• Dolomite. And climate change corridor.

Please note that this information is relevant solely for the study

site specified in your request. Red/Orange Listed plant species

information relevant to a wider geographic area can be obtained

from Lorraine Mills ([email protected]).

All specialist studies must comply with GDARD Requirements for

Biodiversity Assessments. The most recent version of this

document (currently version 2) can be obtained by e-mailing

[email protected].

The biodiversity specialist studies carried out for the proposed

project have incorporated the following

aspects/recommendations from GDARD and Ms. Lorraine Mills

was contacted by the biodiversity specialist.





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Ms Albertina Setsiba said that should the environmental

assessment practitioner be of the opinion that any of the above

specialist studies are unnecessary for the site/activity in question,

then an ecologically-based motivation justifying why the studies

are deemed unnecessary must be submitted to GDARD as part of

the application. This submission will be evaluated and either

accepted or returned to the applicant for the completion of the

necessary studies.

Noted. The GDARD Requirements informed the biodiversity study. Appendix D1 Biodiversity






Ms Albertina Setsiba asked that we note that the application site

is designated critical biodiversity area & ecological support area in

the Gauteng Conservation Plan (Version 3.3), i.e. it is a highly

sensitive site, essential for the conservation of biodiversity in

Gauteng. Based on the biodiversity sensitivities confirmed on this

site, it is highly unlikely that any activity will be supported by

Conservation. Please take this into consideration before

proceeding with the expense of specialist studies.

Noted. N/A






Ms Albertina Setsiba said that With regard to the SLURRY

RECEIVING FACILITY project, specialist biodiversity studies are

required to investigate the following aspects:

• Plants, with specific reference to Habenaria bicolor.

• Mammals, with specific reference to Lutra maculicollis

(Spotted-necked otter).

• Birds, with specific reference to the confirmed habitat for:

• Greater Flamingo.

• Tyto capensis (African Grass Owl).

• Circus ranivorus (African Marsh Harrier).

• Sagittarius bird (Sagittarius serpentarius).

• Falls within Gauteng Important Biodiversity Area (IBA)

(Blesbokspruit).

• Primary Vegetation (Falls within Blesbokspruit

Highveld, Climate change corridor & SANBI priority

grassland).

The biodiversity specialist studies carried out for the proposed

project have incorporated the following

aspects/recommendations from GDARD and Ms. Lorraine Mills

was contacted by the biodiversity specialist.




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• Wetlands.

• Perennial River.

• Falls within Lesedi Agricultural Hub and outside urban

areas.

• Dolomite.

• Falls within minimal use zone of Marievale bird

sanctuary.

Please note that this information is relevant solely for the study

site specified in your request. Red/Orange Listed plant species

information relevant to a wider geographic area can be obtained

from Lorraine Mills ([email protected]).






Ms Albertina Setsiba advised that all specialist studies must comply

with GDARD Requirements for Biodiversity Assessments. The

most recent version of this document (currently version 2) can be

obtained by e-mailing [email protected].

Should the environmental assessment practitioner be of the

opinion that any of the above specialist studies are unnecessary

for the site/activity in question, then an ecologically-based

motivation justifying why the studies are deemed unnecessary

must be submitted to GDARD as part of the application. This

submission will be evaluated and either accepted or returned to

the applicant for the completion of the necessary studies.

Noted. The GDARD Requirements informed the biodiversity study. Appendix D1 Biodiversity

Mr Erick Moletsane Gauteng Department of Agriculture and Rural Development (GDARD)

Focus Group Meeting

5 February 2020 Mr Erick Moletsane asked if a Waste Management Plan will be developed.

Mr Siphesihle Dambuza said that the Waste Management Plan will be developed as part of the Environmental Management Plan (EMP).

Appendix E - EMPr Waste Management

Mr Mokutu Nketu Gauteng Department of Agriculture and Rural Development (GDARD)

Focus Group Meeting

5 February 2020 Mr Mokutu Nketu indicated that GDARD’s Biodiversity Department (Ms Albertina Setsiba) would need the shapefiles to indicate if the water courses on the pipelines would be affected.

Ms Vanessa Viljoen indicate that Shapefiles would be emailed as per request. Post meeting note: Shapefiles were emailed on 14 February 2020 to Ms Albertina Setsiba and other officials from GDARD.

N/A Pipeline Servitudes



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Ms. Sizakele Ndzhukula Control Environmental Officer: EPPC Gauteng Department of Agriculture & Rural Development

Written Comment 28 April 2020

The EMPr should make provisions for measures that will be undertaken in a cases of pipeline failures, as this cannot be put aside. The possibilities of pipeline failures pose a risk of the slurry flowing onto the environment and eventually into the wetland, there should be a mitigating mechanism for such an occurrence.

As specified on page 212 of the DEIR, key areas of the Ergo operation and network are under 24-hour telemetric surveillance to optimise procedures, including safety and security. Pipeline spillages are thus monitored, with spillage paddocks in place along the pipeline network. Any pipeline spillages are to be rectified immediately as per Ergo Mining’s procedures.

Section 7.10.7 Pipeline /

Infrastructure



Where will the contaminated slime be removed to, what is the safe disposal plan for the contaminated material?

Once processed, the residue tailings will be deposited at the licenced and managed Brakpan/Withok Tailings Storage Facility.




More clarity should be provided on how dust will be suppressed from the reclamation activities, if using water, will it be grey water? Sourced from where Blesbokspruit?

During the reclamation process, recycled mine water will be used to convert the tailings into a slurry for pumping to the Ergo plant. Inherently this will suppress dust. Other mitigations are also to be in place including water bowsers and the application of binding agents. Dust fallout monitoring is proposed to monitor any impacts.

Section 2.3

Section 2.3.4

Section 8.2

Appendix E - EMMPr

Mining Operations



The onsite waste management plan is not clear on this sentence, how will waste (general & hazardous) be stored. Will there be sorting of waste at source to facilitate recycling and reuse of recyclable material such as steel plastic etc. while supporting local businesses of SMMEs operating in the waste management space.

Domestic Waste Domestic waste will be stored in clearly demarcated waste skips, in designated areas on the project site. The waste will frequently be disposed of at a local municipal domestic waste handling facility. The waste skips will be demarcated as follows:

❖ Green: general waste;❖ Black: hazardous waste; and❖ Blue: steel / scrap waste.

Industrial Waste Industrial waste will be contained in steel skips or bins and removed by licenced contractors and disposed of in a licenced industrial waste disposal site located off the project site. Sewage Effluent No sewage effluent will be generated on the project site as mobile toilets (honey suckers) will be utilised and replaced on a weekly basis.

Reuse and Recycling The water usage strategy for the projects is designed to operate as a closed water system and therefore most of water on site will be captured and re-used as much as possible, thereby creating a complete balance. This water balance operation is required to minimise the water losses that occur during operations and conserve and re-use as much water as possible to attain a closed

Appendix E – EMPr

Section 2.3.4

Section 2.3.5

Waste



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water system. Adhering to this water balance model will produce a sustainable and socially responsible water balance scheme. Measures will be taken to ensure that water is re-used/recycled as much as possible, these include:

❖ Water in the paddocks, as a result of spills or rainfall, willbe reused for reclamation activities. This will ensure thatthe water levels within the paddocks are kept at aminimum at all times.

Dirty water must, as far as possible, be recycled and reused, or treated and discharged.



Spillages of slurry will affect the fauna and flora in the Blesbokspruit wetland. Preventative measures must be put in place to contain potential spillages within the operational site.

A comprehensive stormwater management plan has been designed and detailed in the Surface Water Impact Assessment report attached to the EIA/EMPr.

Section 7.6.6

Appendix E - EMPr

Surface Water



Sedimentation of wetlands should be avoided at all costs as it leads to the proliferation of reeds and other alien species, which discourage species (fauna and flora) diversity in the wetlands.

A comprehensive stormwater management plan has been designed and detailed in the Surface Water Impact Assessment report attached to the EIA/EMPr.

Section 7.6.6

Appendix E - EMPr

Surface Water



Road surfaces that are exposed to high volumes of truck traffic should be kept wet to suppress dust generation. Grey water should be utilised for this activity.

Noted. Recycled mine water will be used to wet any dirt roads.

Appendix E - EMPr Mining Operations



The employee training and skill development should incorporate some aspects of the EMPR so that there is wider participation from the team in ensuring that there is understanding and adherence to environmental compliance requirements.

Noted. Ergo Employees are trained on the implementation of the EMPr during induction.

Appendix E - EMPr EMPr



The reclamation activities should be screened so that it reduces visual impacts to the receiving environments, noise impacts and light impacts. The status quo must not be negatively affected by the operational activities.

Noted.

Appendix E - EMPr Visual



The development has not committed itself to any form of renewable energy generation be it at a small scale, as part of Sustainable Development goals, Gauteng has introduced the need to investigate and implement some form of renewable energy generation in the new developments especially a mining one with

Noted, this project will use electricity for an extremely limited time frame. Renewable sources will be investigated where applicable.

Section 2.3.4 Electricity



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higher energy consumption to reduce carbon emission and footprint of the country.



Mining operations uses water in the operations, there is no commitment onto how water efficiency will be undertaken at any stage of the operations, either in office area or at any stage of the development to ensure that potable water is not used in areas where substitution with grey water is possible.

The nature of this project is to use recycled mine water as far as possible as a water source. There is little potable water used other than for drinking water. Section 2.3.4 Mining Operations



The ECO should then report the quantities of both general and hazardous waste on the Gauteng Waste Information System for record keeping and also for the province to be able to analyze trends on how the current interventions are effective in waste management.

Noted.

N/A Hazardous Waste

3.3 Department of Water and Sanitation

Mr Divan Van Niekerk Department of Human Settlements, Water and Sanitation

Focus Group Meeting

14 February 2020 Mr Van Niekerk asked if Ergo has started discussions with the TCTA or the other identified potential make-up process water sources.

Mr Siphesihle Dambuza indicated that Ergo has ongoing discussions regarding all potential make-up water sources. Ergo is still evaluating the best possible options, because it is not just about the source of the water, but the quality of the water also needs to be considered. The Marievale shafts water quality also needs to be assessed as a potential source and the TCTA water has a lot of salinity, which is sourced from the treatment works and is being discharging into the Blesbokspruit.

Appendix D3 Groundwater /

Surface Water

Mr Bashan Govender Department of Human Settlements, Water and Sanitation

Focus Group Meeting

14 February 2020 Mr Govender asked where the process water for the proposed

project will be coming from?

Mr Siphesihle Dambuza said that process water will be pumped

from Withok/Brakpan TSF, and if there is a shortage, then make-

up water will be sourced. Ergo is looking at the Marievale shafts 1

& 2, TCTA or the Rondebult water treatment works for make-up

water. The best source will be investigated and identified during

the EIA phase.


Mr Divan Van Niekerk Department of Human Settlements, Water and Sanitation

Focus Group Meeting

14 February 2020 Mr Van Niekerk asked if the pipelines will be crossing rivers?

Mr Siphesihle Dambuza said the proposed pipeline routes would cross over water bodies and moreover the dumps are located adjacent to the Marievale Bird Sanctuary wetland. This will trigger Section 21 (c) and (i) water uses in the Water Use Licence Application (WULA).

Appendix D2 Pipelines


Focus Group Meeting

14 February 2020 Mr Govender asked whether Kongiwe has presented the project to their DHSWS colleagues in regard to the WULA, even though it is still conceptional at this stage.

Mr Siphesihle Dambuza responded by stating that Kongiwe has not had an opportunity to present the project to the DHSWS’ WULA Department because the water use licence is still in pre-application phase. Kongiwe is engaging with relevant DHSWS officials as the application moves forward.

N/A IWULA


Focus Group Meeting

14 February 2020

Mr Govender asked what the rehabilitation plans will be once the dumps have been fully reclaimed.

Mr Siphesihle Dambuza indicated that Ergo’s rehabilitation plan is to re-grass the project footprint, after appropriate radioactivity assessments and permits have been obtained from the National Nuclear Regulator (NNR), to match the surrounding environment. The property underneath dumps 7L5 and 7L6 belongs to City of




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Ekurhuleni; while dump 7L7 is on property owned by Scarlet Sun 33 (Pty) Ltd. The ultimate end land-use will be at their discretion.


Focus Group Meeting

14 February 2020

Mr Govender stated that the DHSWS would support re-grassing because he does not think much infrastructure can be put there. He further explained that the proposed project will be on a delta formation and a wetland, and how the groundwater is very near to the surface. He expressed that it would be preferable to preserve the watershed that takes water to the stream, as it would not be desirable for this wetland to get bigger. He also stated that he is concerned that the phragmites in the area can grow if the wetland gets bigger.

The comment is noted. Section 9.4 Rehabilitation

Mr Ayanda Mtetwa Department of Human Settlements, Water and Sanitation

Focus Group Meeting

14 February 2020 Mr Mtetwa asked, in-terms of the Social Impact Studies, how far is the nearest community / residents were in relation to the proposed project site.

Mr Siphesihle Dambuza indicated that there is a coal/clay mine, a military base, and an informal settlement called Happiness Village in proximity to the proposed project site, but there are no other residential areas close to the dumps.

Appendix D6 Social Impact

Assessment


Focus Group Meeting

14 February 2020 Mr Govender asked what the Life of Mine for the project is? Mr Siphesihle Dambuza indicated that the Life of Mine for the project will be 20 years.

Section 2.3.7 Mining Operation

Department of Agriculture Forestry and Fisheries

Ms Mulalo Sundani Department of Environmental, Forestry and Fisheries


Ms Mulalo Sundani expressed that the Department of Environment, Forestry and Fisheries: Forestry Branch hereby acknowledges the opportunity to provide input on the abovementioned report.

Noted.

N/A Stakeholder

Engagement



Ms Mulalo Sundani said the mandate of the Forestry Branch of the Department of Environment, Forestry and Fisheries (DEFF) when dealing with land use applications, is mainly to ensure control over development affecting natural forests, protected woodlands and listed protected trees under the National Forests Act, 1998 (Act No. 84 of 1998) (NFA).

Noted.

N/A Land Use



Ms Mulalo Sundani said the proposed pipeline in Kwa-Thema Phase 1, Kwa -Thema and Struisbult areas is located in proximity to woody vegetation. We therefore recommended that followings should be taken into consideration: Any species protected under the National Forests Act, (Act No 84 of 1998) may not be cut, disturbed, removed or damage without a licence in terms of Section 15 of NFA.

Noted, this will be included into the biodiversity specialist study and Environmental Management Programme (EMPr).




Ms Mulalo Sundani asked that should any additional road be construction, any plant communities including trees along the areas should be considered.

Noted, this will be included into the biodiversity specialist study and Environmental Management Programme (EMPr).




Ms Mulalo Sundani said that the Department would also like to request the width of the pipeline servitude to be indicated in the report.

The width of the pipelines is 600 mm.

Section 2.3 Infrastructure



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Ms Mulalo Sundani asked that should there be a need for a site visit, to please contact Ms Mpho Thenga or Ms Mulalo Sundani.

Noted.

N/A Stakeholder

Engagement

3.6 Eskom

Mr John Geeringh (Pr Sci Nat) Senior Consultant Environmental Management Eskom Transmission Division: Land & Rights


Mr John Geeringh requested that the applicant is made aware that any crossing of Eskom servitudes on the various pipe line routes require a formal application to Eskom for servitude encroachment.

Noted, The applicant is aware that any crossing of Eskom servitudes on the various pipeline routes require a formal application to Eskom for servitude encroachment.


Mr Jan Mitchell Eskom


Mr Jan Mitchell asked that we obtain Eskom permission and apply for wayleaves where necessary.

The project team is in consultation with Eskom and is aware that permission is required.


Mr Sbu Nkalanga Eskom

Focus Group Meeting

12 February 2020 Mr Nkalanga indicated that Eskom would need the DWG Files of the proposed pipeline routes to overlay onto Eskom infrastructure to see what will be affected.

Ms Vanessa Viljoen indicated that the DWG would be emailed as per request.

Post meeting note: DWG files were emailed on 12 February 2020 to Mr Jan Mitchell and Mr Sbu Nkalanga.



Focus Group Meeting

12 February 2020 Mr Mitchell asked whether or not the pipelines will be running above or below the ground?

Mr Siphesihle Dambuza indicated that the pipelines will be running above the ground and that pipe-jacking would be done wherever the pipelines cross over road reserves.



Focus Group Meeting

12 February 2020 Mr Mitchell said that according to the provided locality map, the proposed Alternative Pipeline Route 2 could pose a problem regarding existing Eskom infrastructure.

Mr Siphesihle Dambuza requested that once Eskom has received the DWG files, it should provide clarity on where exactly the Eskom infrastructure will be affected.


3.7 Transnet

Mr Qatjha Ramokhothoane Transnet

Focus Group Meeting

11 February 2020 Mr Qatjha Ramokhothoane indicated that Transnet would need the KMZ Files of the proposed pipeline routes to overlay onto Transnet infrastructure to see what will be affected.

Ms Vanessa Viljoen indicated that the KMZ files would be emailed to Transnet.

Post meeting note: KMZ files were emailed on 12 February 2020 to Mr Ramokhothoane and other relevant officials from Transnet


3.8 National Nuclear Regulator (NNR)

Mr Patle Mohajane National Nuclear Regulator

Focus Group Meeting

15 October 2019 Mr Patle Mohajane asked if the public have raised questions about radiation in the meetings that Kongiwe have conducted.

Ms Ashleigh Blackwell indicated that stakeholders have asked about radiation in the meetings that have been held. She said that the questions asked where more towards the impacts related to the health associated with the radiation.

Appendix C9 Stakeholder

Engagement

Ms Rina Myburgh Ergo Mining

Focus Group Meeting

15 October 2019 Ms Rina Myburgh said that in terms of Marievale, it was never authorised by NNR.

Mr Patle Mohajane indicated that it was authorised under the COR 52 in Nigel. Marievale is still seen under the licence and must be managed in accordance under the NNR.

N/A Legislation



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Mr Patle Mohajane National Nuclear Regulator


Mr Patle Mohajane said that the NNR will be appreciative if the Specialist table can also include Radiation specialist assessments as these sites are sources of radiation.

A Workers Safety Assessment (WAS) will be conducted 6 months prior to operations once the site has been cleared and accurate readings can be taken. In addition, these results will be compared to results from similar operations undertaken by Ergo Mining.

An Independent Phase 2 Public Safety Assessment (PSA) will be conducted following the completion of Phase 1 in February 2020. This assessment will quantify the radiation risk of Marievale (and other sites) on public safety.

Radiation clearance certificates will be sought from the NRR to ensure that the site is clear of any pollution sources once the project is complete.

N/A Radiation

3.9 Rand Water

4.1 Interested and Affected Parties

Mr Philip de Jager Grootvaly Agricultural Holdings


Mr Philip de Jager indicated that any water extracted from the system will have a negative impact on the RAMSAR site and will impact on property values.

Currently suitable water sources for the project are being investigated. The reclamation project will work on a closed water circuit whereby dirty (mine) water is used with limited make up water to undertake the activity. The impacts of potential water sources will be evaluated in the EIA phase. It is not the intention to extract water from the Blesbokspruit.

Section 2.3.4 Mining Operations

Mr Philip de Jager Grootvaly Agricultural Holdings


Mr Philip de Jager indicated that this Project will take place next to a RAMSAR site and protected area.

We are aware of the proximity of the Marievale TSF’s to the Marievale Bird Sanctuary which is on the Montreux Record of the RAMSAR. We are also aware there are efforts to re-instate the RAMSAR status of this wetland system.

A successful removal of these TSF’s as a known pollution source to this system is expected to assist this cause.

Specialist studies are underway to examine if these TSF’s can be safely removed and what mitigation measure need to be in place to do so.

The specialist studies undertaken will inform the potential future land use for the land underneath the TSF’s. The proximity to the Bird Sanctuary will be considered when suggesting a possible future use.

Appendix D Specialist Studies

Ronnie Newby Private Property Owner


Mr Ronnie Newby asked if there are sufficient water levels in the Blesbokspruit.

Currently suitable water sources for the project are being investigated. The reclamation project will run on a closed water circuit where dirty (hydraulic monitoring) water is used with limited make up water being required. The impacts of potential water sources will be evaluated in the EIA phase. It is not the intention to extract water from the Blesbokspruit.




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Ronnie Newby Private Property Owner

Written Comment 24 October 2019 Mr Ronnie Newby asked what the negative effects on bird life. The impacts on bird life, both positive and negative, are being

evaluated by biodiversity specialist studies which will be incorporated into the EIA for your review.


Ms Mariette Liefferink

CEO: Federation for a

Sustainable Environment

Written Comment

24 October 2019,

5 November and

6 November 2019

Ms Mariette Liefferink asked that the FSE be registered as an

interested and affected party.

The FSE is registered as an interested and affected party as per

your request. Appendix C1 Stakeholder

Engagement




Written Comment

24 October 2019,

5 November and

6 November 2019

Ms Mariette Liefferink asked that an electronic copies of the Draft

Scoping Report and WUL application?

The Draft Scoping report was delivered to your address on CD on

28 October 2019, to which you have confirmed receipt on 31

October 2019. You will be notified of the availability of the WUL

application as it progresses.

N/A Stakeholder

Engagement




Written Comment

24 October 2019,

5 November and

6 November 2019

Ms Mariette Liefferink asked that WUL applications are usually

presented at CMFs. Will the Applicant be presenting its application

at the next Blesbokspruit CMF?

Yes, the Blesbokspruit Catchment Management Forum (CMF) has

been notified of the project and it is likely that the project will be

presented to the Blesbokspruit CMF in 2020.

N/A Stakeholder

Engagement




Written Comment

24 October 2019,

5 November and

6 November 2019

Ms Mariette Liefferink asked whether the water for the

reclamation operations will be sourced from the Eastern Basin

AMD Treatment Plant.

Ergo Mining is investigating all alternative water resources during

this Scoping Phase. Further clarity on the water sources will be

provided and elaborated on shortly. It must be noted that the

Scoping Report is currently in draft form and may be revised prior

to finalisation.

More detailed information will be provided as the project

progresses.





Written Comment

24 October 2019,

5 November and

6 November 2019

Ms Mariette Liefferink referred to the subjoined extract from the

above BID.

“Potable water will be purchased from Rand Water or the

municipality, with a contingency for portable JoJo tanks or

connection to existing water pipeline infrastructure. In terms of

process water, the water cycle operates as a closed circuit,

meaning that limited make-up water will be required for the

reclamation of the Marievale TSFs. Water required for the

reclamation activities will be sourced from the existing central

water storage facility located in Germiston and conveyed through

existing and proposed process water pipelines to the project site

for reuse in a closed-circuit system.”

Kindly advise whether the reference to water for the reclamation

activities the existing central water storage facility located in

Germiston is in fact referring to the Central AMD Treatment Plant.

As above.

Ergo Mining is investigating all alternative water resources during

this Scoping Phase. Further clarity on the water sources will be

provided and elaborated on shortly. It must be noted that the

Scoping Report is currently in draft form and may be revised prior

to finalisation.

More detailed information will be provided as the project

progresses.




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Written Comment

24 October 2019,

5 November and

6 November 2019

Ms Mariette Liefferink referred to the subjoined extract and asked

for clarity:

“Ergo Mining (Pty) Limited (hereafter Ergo), intends to reclaim and

reprocess gold residues from the Marievale tailings storage

facilities (TSFs) Nos. 7L5, 7L6 and 7L7, through its subsidiary Ergo.

These TSFs are historical mineral deposits (slimes dams), situated

6 km north-east of Nigel and about 10 km southeast of Springs, in

the Ekurhuleni Metropolitan Municipality (EMM), and were

created prior to the promulgation of the Mineral and Petroleum

Resources Development Act, 2002 (Act No 28 of 2002) (MPRDA)

and are accordingly not regulated by the MPRDA.”

Application for an Environmental Authorisation for listed activities

triggered in Listing Notices GN R327, GN R325 and GN R324 in

terms of the Environmental Impact Assessment (EIA) Regulations,

2017, as promulgated in terms of the National Environmental

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

Application for listed waste activities in terms of the National

Environmental Management: Waste Act, 2008 (Act No. 59 of

2008), as amended (NEM:WA). The Competent Authority

responsible for assessing the abovementioned applications is the

Department of Mineral Resources and Energy-

(DMRE)- Gauteng Region”.

(Emphasis added.)

Since in terms of the NEM:Waste Act (59/2008) this Act does not

apply to residue deposits and residue stockpiles that are regulated

under the MPRDA but since the Marievale TSFs are not regulated

under the MPRDA, it necessitates that the Applicant applies for

authorisation under the Waste Act, that is “waste” that is defined

in the Waste Act as “waste generated by mining” (please refer to

Chapter 1, “Interpretation and Principles” of the Waste Act).

It is correct that the Marievale dumps, which were created prior

to the commencement of the Mineral and Petroleum Resources

Development Act, 2002 (MPRDA), are accordingly not regulated

under the MPRDA. For this reason, the definitions of “residue

stockpiles” and “residue deposits”, as they stand in the MPRDA, do

not apply and therefore, the dumps do not fall under Activity B

4(11) of the Waste Listing Notice (GN 921, as amended by GN 633

of 24 July 2015). This activity refers to “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)”.

However, the National Environmental Management: Waste Act,

2008 (NEM:WA), provides in Schedule 1 that waste management

licences are required for specific activities and in Category B, this

includes the treatment of hazardous waste. “Treatment” is

defined in Section 1 as including any method, technique or process

that is designed to remove, separate, concentrate or recover a

hazardous or toxic component of a waste. Schedule 3 to NEM:WA

defines hazardous waste and this Schedule includes a definition for

“residue stockpile” that reads “any debris, discard, tailings, slimes,

screening, slurry, waste rock, foundry sand, mineral processing

plant waste, ash or any other product derived from or incidental

to a mining operation and which is stockpiled, stored or

accumulated within the mining area for potential re-use, or which

is disposed of, by the holder of a mining right, mining permit or,

production right or an old order right, including historic mines and

dumps created before the implementation of this Act.” This is of

course the exact wording that was proposed for the MPRDA by the

Third Amendment of 2013, which in fact never came into force and

has now been withdrawn. It seems therefore that Schedule 3 to

the NEM:WA was worded in anticipation of the MPRDA being

amended in due course.

Notwithstanding that this did not happen, an applicant for an

environmental authorisation in respect of the recovery of historic

mineral storage facilities will also be required to apply for a waste

management licence, in accordance with Section 20 of NEM:WA

Chapter 4 Legislation



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Is our understanding correct? which provides that no person may commence, undertake or

conduct a waste management activity, except in accordance with

a waste management licence is issued in respect of that activity, if

a licence is required.

It should be noted that this position will most likely change if the

proposed amendments to the National Environmental

Management Act, 1998 (NEMA), in accordance with the 2017

Amendment Bill, are enacted. This Amendment envisages that

residue deposits and residue stockpiles will be removed entirely

from the ambit of NEM:WA and be regulated under NEMA.

However, for this to be entirely effective, the various Regulations

will need to be amended carefully and new Regulations will need

to be enacted.

The Marievale TSF Application has been accepted by the DMRE in

its current form and we are proceeding accordingly.




Written Comment

24 October 2019,

5 November and

6 November 2019

Ms Mariette Liefferink explained that the FSE does not oppose the

reclamation of historical TSFs but cautions that in past dump

reclamation activities, a number of cases have been identified

where the re-mining of dumps was not completed (e.g Mintails

operations) either due to a lack of funding on the part of the miner

or due to the heterogeneity in the dumps which were mined.

Noted.

We cannot comment on any previous Mintails operation.

We agree that the partial reclamation of TSF’s would not be in

accordance with proper practice. As an EAP we include in our

Environmental Management Programmes (EMPrs) the

requirement to remove the whole TSF and not leave remnants

behind. If approved, the EMPr provides legally binding instruction

on how to manage environmental matters on site.

N/A Legislation




Written Comment

24 October 2019,

5 November and

6 November 2019

Ms Mariette Liefferink stated that according to Council for

Geoscience (ref. DM van Tonder, H Coetzee, S Esterhuyse et al,

“South Africa’s Challenges Pertaining to Mine Closure – The

Concept of Regional Mining and Closure Strategies, 2008):

“…any new application to exploit mining residues should only be

approved if it involves the removal of an entire residue deposit and

the rehabilitation of the remaining footprint. If this is not the case,

rather than consolidating contaminated sites, the reprocessing

Noted, thank you for the reference information.

As above, we agree that the partial reclamation of TSF’s is

inappropriate. As an EAP we include in our EMPrs the requirement

to remove the whole TSF and not leave remnants behind.

The EIA Process will also highlight possible future land uses which

can be considered by the landowner should the TSF’s be

reclaimed.




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activities result in the creation of two contaminated sites, where

one previously existed.”

The Council for Geoscience furthermore recommended that:

“In past practice of granting rights and authorisation for the

reprocessing of individual residue deposits may need to be

reviewed insofar as it allows the selective extraction of value from

portions of a site without ploughing some of that value back into

the rehabilitation of the entire mining area. It must be accepted

that the reprocessing of some mining residues will never be

economically viable and that these will need to be transported to

super dumps if this is not too costly or rehabilitated in situ.”

And found:

“Radiometric surveys over previously reprocessed mine residue

deposit footprints have, in some cases, shown elevated levels of

residual radioactivity in the soils. In these cases, it must be

accepted that some areas will never be suitable for unrestricted

development and that these areas will need to be demarcated as

such, and appropriate land-uses proposed and implemented.”




Written Comment

24 October 2019,

5 November and

6 November 2019

Ms Mariette Liefferink stated that It should also be noted that:

• The reprocessing of old TSFs may result in the

remobilization of metal-bound cyanides (ref. MW

Sutton, H Pretorius, JH Nel, F. Julyan, HG Rex, Closure

Planning and Estimating within the Southern Africa

Division of a Global Gold Miner – 2008).

The possible contribution of tailings reclamation activities on

surface to acid mine drainage: The associated contribution to

ingress is likely to be considerable as old tailings are hydraulically

mined using high-pressure water cannons. This introduces large

volumes of additional water into a highly disturbed area where

surface mining and subsequent filling resulted in exceptionally

high infiltration rates (ref. FWinde. Desktop Assessment of the

Risk for Basement Structures of Buildings of Standard Bank and

Noted, thank you for the reference information.

The remobilisation of metal-bound cyanides and possible

contribution to AMD as a result of the proposed reclamation

activities is being considered in the Surface Water and

Groundwater Specialist studies. These studies will assess the risk

as well as recommend any mitigation measures to reduce to the

risk.

Appendix D2 and

Appendix D3

Groundwater /

Surface Water



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ABSA in Central Johannesburg to be Affected by rising Mine Water

Levels in the Central Basin, May 2011)




Written Comment

24 October 2019,

5 November and

6 November 2019

Ms Mariette Liefferink stated that in view of the abovementioned

findings and recommendations, the FSE requests that the Scoping

Report includes an assessment of the risks associated with the

remobilization of metal bound cyanides, the possible contribution

to ingress and AMD; the residual radioactivity in the footprints of

the reclaimed TSFs and the future sustainable land use of these

areas; and whether the Applicant is of the intention to

remine(remove) the entire TSFs and to plough back some of the

profits into the rehabilitation of the entire mining area.

As above. The remobilisation of metal-bound cyanides and

possible contribution to AMD as a result of the proposed

reclamation activities is being considered in the Surface Water and

Groundwater Specialist studies. These studies will assess the risk

as well as recommend any mitigation measures to reduce to the

risk.

The EIA will also consider a future sustainable land use considering

the likely end state of the TSF footprints.

As an EAP we include in our EMPrs the requirement to remove the

whole TSF and not leave remnants behind.


Mr Tony Dodd Sharon Park Residents Association


Mr Tony Dodd asked for clarity on Property Devaluation and Pipeline Routes.

We note your concern regarding property devaluation as a result of the proposed pipeline.

At this stage we are at a high-level scoping / screening study, thereafter we will move into more detailed specialist studies and the EIA compilation phase.

As part of the EIA phase we are obliged to investigate numerous options from an environmental impact perspective and recommend the least intrusive option. This is why there are a few pipeline options being investigated.

These pipelines generally follow existing servitudes and reserves where possible.

These pipelines are generally above ground to ensure maintenance is easily done.

Appendix B1 Pipelines


Written Comment 6 November 2019 Mr Tony Dodd asked about accidental spillages. The risk of accidental spillage and the required emergency

response plan will be investigated in the EIA phase of the project. Appendix E Pipelines


Written Comment 6 November 2019 Mr Tony Dodd asked that the pipeline should be rerouted Comment noted, thank you for bringing this to our attention and

we will consider this when evaluating all the pipeline route options.

Appendix B1 Pipelines

Mr Darryl Allcock EHS Officer Waste Product Utilization (WPU)

Open Day 9 November 2019 Mr Darryl Allcock indicated that it is good that the dumps are being removed. Asked whether there any endemic animal Species of Special Concern (SSC)? Would SCC have to be relocated?

A biodiversity specialist assessment is currently in progress which will inform the existence of any SCC and any mitigation measures required.


Mr Darryl Allcock EHS Officer

Open Day 9 November 2019 Mr Darryl Allcock asked if there are any heritage sites? A heritage specialist assessment is currently in progress which will inform the existence of any heritage sites and any mitigation measures required.

Appendix D5 Heritage



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Waste Product Utilization (WPU)

Ms Bev Caldwell Selpark CFP

Open Day 9 November 2019 Ms Bev Caldwell asked whether the project area would be rehabilitated as a conservation area?

The specialist studies currently being undertaken will inform us to what the most appropriate end land use will be. The proximity to the Marievale Bird Sanctuary must be considered when making these recommendations.



Open Day 9 November 2019

Ms Bev Caldwell said she is concerned about resident’s health. Indicated that people are being tested for uranium poisoning. Asked, how much of the chemicals are going into the water system?

Noted. The Marievale TSF sites are currently a pollution source and the removal of them will aid in abating future environmental impacts.

A surface water specialist assessment is currently in progress which will assess this risk and inform mitigation measures required.

Appendix D2 Surface Water



Ms Bev Caldwell indicated that there are illegal miners that are hacking into sewer lines. There is a big risk that they may damage pipelines. Wants to know who will watch over that and make sure that there are not spillages.

Ergo has a SCADA system that will alert them of any leakages. If alerted Ergo investigates the reason for the leakages and repairs the leakages. The Ergo team has security personel that patrol the pipeline routes, therefore reducing the number of criminal related activities along these routes.

N/A Pipelines


Open Day 9 November 2019 Ms Bev Caldwell if runoff will pollute the Blesbokspruit (BBS)? A surface water specialist assessment is currently in progress which will assess this risk and inform mitigation measures required.



Open Day 9 November 2019 Ms Bev Caldwell said the ground under the dumps is unsafe for human health. Is also concerned that it will not be rehabilitated properly.


Appendix D3 Groundwater


Open Day 9 November 2019 Ms Bev Caldwell asked why there is a need to remove the tailings? What is the purpose of this project and why is it being done?

Mr Bradly Thornton said that the project is being done for economic and environmental reasons.

Chapter 5 EAP


Open Day 9 November 2019 Ms Bev Caldwell asked what will happen to the wetlands in the area?


Appendix D1 Wetlands


Open Day 9 November 2019 Ms Bev Caldwell said she is concerned about what will happen to the animals and plants after rehabilitation.




Open Day 9 November 2019 Ms Bev Caldwell said that she hopes that the end land use will be ecologically inclusive.




Open Day 9 November 2019 Ms Bev Caldwell asked where the water for the project will be sourced from?

Further investigation during the impact assessment phase on where the water will be sourced from for the project and any secondary impacts.


Mr Alfred Makofane Community Member

Open Day 9 November 2019 Ms Bev Caldwell asked whether stakeholders will be notified when the project begins?

Stakeholders have to be notified before the project begins if authorised.

N/A Stakeholder

Engagement

Mr Alfred Makofane Community Member

Open Day 9 November 2019 Ms Bev Caldwell asked if there will be jobs created? These projects typically do not create many additional employment opportunities.

Appendix D6 Social



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Mr Peter Law Wildlife & Environmental Society of South Africa Springs & Nigel branch

Open Day 9 November 2019 Mr Peter Law stated that there is an adjacent application for golf course to be turned into a coal mine and that there are several coal mine applications around the area.

Noted N/A EAP


Open Day 9 November 2019 Mr Peter Law asked how much water will be needed per day? Can water from the Marievale 1 & 2 shafts be used?

This option will be investigated in the impact assessment phase. Section 2.3.4 Mining Operations


Open Day 9 November 2019 Mr Peter Law asked why the Ergo plant going to be used and not Daggafontein as it is closer? Water control is crucial.

Daggafontein plant is in abeyance and not Ergo Mining’s property. Appendix D2 Surface Water


Open Day 9 November 2019 Mr Peter Law stated that he is not too concerned about the dust and that he has seen from other projects how dust has been reduced.

Noted Appendix D4 Air Quality


Open Day 9 November 2019 Mr Peter Law suggested that the operation take water from East Rand Basin. It will drop the decant level through 1 shaft and 3 shaft. These shafts are owned by Randex.

It will depend on the quality of this water; it will be investigated in the EIA phase.



Open Day 9 November 2019 Mr Peter Law indicated that he has monitoring data along the East Rand which he can share with Kongiwe.

That it would be appreciated. N/A Monitoring


Open Day 9 November 2019 Mr Peter Law indicated that water levels in the area need to be monitored. Levels drop by 15cm in the winter. TCTA water not making a big difference to water levels in Blesbokspruit.

Noted. N/A Monitoring

Mr Philip De Jager Private Property Owner

Open Day 9 November 2019 Mr Philip De Jager asked how high the Brakpan dump will be raised? What will the water use be for?

The Brakpan/Withok TSF is an authorised facility capable of accommodating this project. The exact height which this project will add to the dump is not determined. Water sources are being investigated.


Mr Matthew Havinga Private Property Owner Mr Philip De Jager Private Property Owner


Mr Matthew Havinga asked what the track record of DRDs rehabilitation is? What will happen to the land after it has been rehabilitated. Wants something to support the ecology of the wetland i.e. Would like to see the rehabilitated land donated to Marievale Bird Sanctuary.



Mr Matthew Havinga Private Property Owner Mr Philip De Jager Private Property Owner

Open Day 9 November 2019 Mr Matthew Havinga stated that there is a township which will cross the TCTA pipeline, it will need to be investigated.

Noted. Appendix B1 Pipelines

Mr Philip De Jager


Open Day 9 November 2019 Mr Philip De Jager asked how many litres per day would be used? Approximately 20Ml/day. Appendix D2 Surface Water



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Mr Philip De Jager Private Property Owner

Open Day 9 November 2019 Mr Philip De Jager said he is concerned about water flow reduction volumes, and how this will affect quality of the Blesbokspruit. Rather take water from sewerage farms.



Mr Ronnie Newby Private Property Owner

Open Day 9 November 2019 Mr Ronnie Newby asked what the project’s duration going to be? The life of mine will be approximately 20 years. Section 2.3 EAP


Open Day 9 November 2019 Mr Ronnie Newby asked if water will be taken from the Blesbokspruit? Concerned that this will cause problems in the Blesbokspruit.

Water sources are being investigated, but it is not expected that water is to be extracted from the Blesbokspruit. This is an environmental consideration.



Open Day 9 November 2019 Mr Ronnie Newby asked how Ergo will prevent the slurry from flowing into the Blesbokspruit.



Mr Mike Du Toit President Chamber of Commerce

Open Day 9 November 2019 Mr Mike Du Toit asked if the pipelines from Daggafontein to Ergo have been removed? Concerned with spillages.

Ergo Mining has a spillage response procedure in place. N/A Pipelines

Mr Ronny Mashabela Community Member

Open Day 9 November 2019 Mr Ronny Mashabela asked what the employment opportunities will be?

These projects typically do not create many additional employment opportunities.

Appendix D6 Social


Open Day 9 November 2019 Mr Ronny Mashabela suggested that the local community must be used for procurement of services.

Noted. Appendix D6 Social


Open Day 9 November 2019 Mr Ronny Mashabela indicated that the dust coming of the dumps impacts are high.

Noted. The removal of these TSF’s should lessen this environmental impact in the long term.

Appendix D4 Air Quality

Mr Trevor Dimane Community Member

Open Day 9 November 2019 Mr Trevor Dimane asked what the employment opportunities will be?

These projects typically do not create many additional employment opportunities.

Appendix D6 Social


Open Day 9 November 2019 Mr Trevor Dimane stated that he knows about dust issues from similar experiences with Fraser Alexander, dust impacts were felt.

Noted. The removal of these TSF’s should lessen this environmental impact in the long term.

Appendix D4 Air Quality


Open Day 9 November 2019 Mr Trevor Dimane asked how will the water resources be affected? The Blesbokspruit is used for drinking purposes.




Open Day 9 November 2019 Mr Trevor Dimane asked how impacts will be mitigated once construction commences.

The Environmental Management Programme must be implemented if the project is approved by the DMRE.

Appendix E Mining Operations

Mr Bill Ross-Adams Grootvaly 124 IR Ptn 9


Mr Bill Ross-Adams expressed concerns around Property Devaluation/ Pipeline / Pipeline Route clarification








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Mr Bill Ross-Adams asked how water levels in the Blesbokspruit will be affected.

Currently suitable water sources for the project are being investigated. Reclamation projects work on a closed water circuit where dirty (hydraulic monitoring) water is usually used with limited make up water as required. The impacts of potential water sources will be evaluated in the EIA phase. It is not the intention to extract water from the Blesbokspruit.




Mr Bill Ross-Adams asked what the negative effects on bird & fish life will be.

The impacts on bird and fish life, both positive and negative, are being evaluated by biodiversity specialist studies which will be incorporated into the EIA for your review.

Appendix DQ Biodiversity



Mr Bill Ross-Adams expressed concerns about the aesthetics of his property being affected by the proposed project.

We note your concern regarding property devaluation as a result of the proposed pipeline. At this stage we are at a high-level scoping / screening study, thereafter we will move into more detailed specialist studies and the EIA compilation phase.










Mr Bill Ross-Adams asked what the planned end land-usage was. The planned future usage of the land once the TSF’s are removed will be informed by the specialist studies which are currently underway. These will be made available to you for review.




Mr Bill Ross-Adams suggested that the proposed pipelines should be below ground.

Pipelines need to be above ground to ensure maintenance and repair if needed.

N/A Pipelines

Nadia Hetzel Boshoff Smuts Incorporated


Nadia Hetzel communicated that Boschoff Smuts Inc had perused the documents and it seems that it is a low risk project as it is only the reworkings of old slime dams.

Noted. N/A Mining Operations



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Nadia Hetzel stated that they have notes that the proposed pipeline will be built on various farms including the farm Vlakfontein and Grootfontein.

Correct. Proposed pipeline alternatives are on Vlakfontein 281 IR and Grootfontein 165 IR. Chapter 2 Pipelines



Nadia Hetzel stated that their client is leasing a portion of the farm Vlakfontein 721, Govan Mbeki Metropole and is the owner of portion 4 of the farm Grootfontein 8, Standerton.

Noted. N/A EAP



Nadia Hetzel asked for an indication of whether or not these properties will be affected at all by the abovementioned project.

Vlakfontein 721 and portion 4 of the farm Grootfontein 8 are not part of the project area and the properties are not affected. Chapter 2 EAP

Mr Chris Koitsoe Marievale Community


Mr Chris Koitsoe informed that they, as the community of Marievale, are residing in the area that Ergo Mining (PTY) Ltd is intending to reclaim and reprocess gold residues from the Marievale tailings storage facilities.

Noted.

I wish to draw to your attention that in terms of the provision of Regulation 43(1) of the Environmental Impact Assessment Regulations, 2014 (as amended in 2017), a registered interested and affected party is entitled to comment, in writing, on all reports or plans submitted to such party during the public participation process contemplated in these Regulations and to bring to the attention of the proponent or applicant any issues which that party believes may be of significance to the consideration of the application, provided that the interested and affected party discloses any direct business, financial, personal or other interest which that party may have in the approval or refusal of the application. (The underlining is mine).

I would thus be most grateful if you could confirm what personal or other interest you have in the proposed project, your mail notes you are residing in the area, please can you give us a specific location so that we can understand where you are. Your name is signed as the Marievale Chairperson, we would appreciate your advice as to what the organisation is that you represent and what its mandate is. Please could you send us more information.


Engagement



Mr Chris Koitsoe revealed that Site 2: TFS is Located in their area but they’ve realised that the invitation for interested and affected parties was held on the 9th November 2019 In Springs, and the venue was far away from where the project will take place. This means their community was not represented and for that reason they, as the community, are adamant that this is not in line with (EIA) REGULATIONS.

As to the location of the Open Day, this was held at the Grootvaly Blesbokspruit Wetland Reserve, in Welgedacht Road, Springs on 9 November 2019. This venue was most convenient for the majority of the Interested and Affected Parties. We note that in terms of Regulation 41(6) of the Regulations referred to above –

When complying with this regulation, the person conducting the public participation process must ensure that - (a) information containing all relevant facts in respect of theapplication or proposed application is made available to potentialinterested and affected parties; and(b) participation by potential or registered interested and affectedparties is facilitated in such a manner that all potential orregistered interested and affected parties are provided with a

N/A Stakeholder

Engagement



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reasonable opportunity to comment on the application or proposed application.

We are of the view that proper disclosure of all relevant material has been made available to all interested and affected parties, and that a reasonable open forum was established for the discussion of the proposed project.



Mr Chris Koitsoe stated that the community is still expecting to get a relevant invitation whereby every member of the community will be available before any further mining activity can take place, so as to have a chance to participate and to voice their concerns and prior to proceeding with the reclamation process.

As noted above, your concern has been noted in the Comments and Response Report and we would be prepared to set up an additional meeting with yourself in January 2020, subject to understanding the mandate of the organisation.

Additional meetings will be arranged during the EIA/EMPr process and you will be notified of the date and venue.


Engagement

Mr Chris Koitsoe

Marievale Community

Written Comment 25 November

2019

Mr Chris Koitsoe said that the challenge was that the notice was

placed in the bushes, where there are restrictions of movement

for our community, by the soldiers in that area.

In addition to site notices, various adequate notifications in

newspapers and through relevant ward councillors and forums

have been made.

Appendix C Stakeholder

Engagement



We requested in the past that you must please indicate how this project will affect Afgri.

This seems to be a low risk project for our client as it is simply the reworking of old slime dams. Please confirm.

Thank you for the mail, your comment is noted.

We notify AFGRI due to your extensive infrastructure in the rural areas, these notices are for your information.

N/A Stakeholder

Engagement

Ms Mariette Liefferink CEO: Federation for a Sustainable Environment

Written Comment 09 May 2020 The following comments are submitted on behalf of the Federation for Sustainable Environment (FSE).

Noted. N/A

Stakeholder

Engagement


Written Comment 09 May 2020

The FSE is a federation of community based civil society organisations committed to the realisation of the constitutional right to an environment that is not harmful to health or well-being, and to having the environment sustainably managed and protected for future generations. Their mission is specifically focussed on addressing the adverse impacts of mining and industrial activities on the lives and livelihoods of vulnerable and disadvantaged communities who live and work near South Africa’s mines and industries.

Noted.

N/A EAP



Prefatory The FSE’s is not opposed to the Proposed Project, however, we wish to proffer the following comments. Our comments are verbose. In order to assist with the reading of this submission, we have highlighted our requests for more information in bold typography.

Noted.

N/A EAP


Written Comment 09 May 2020 Notwithstanding, we respectfully request that our comments, which are not accentuated, not to be passed over and to be responded to in a meaningful manner.

Noted. Appendix C8 EAP



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Responsibility and Liability for historical pollution On page 3 of the DEIAR reference is made to the fact that the TSFs within the scope of this application were created prior to the promulgation of the Mineral and Petroleum Resources Development Act 28 of 2002 (MPRDA) and accordingly not regulated by the MPRDA.

The Draft Environmental Impact Assessment Report (DEIAR) adduces evidence of significant pollution of surface and groundwater (page 300 of the DEIAR) as a result of mining operations. The motivation of the Marievale Project is based upon the clean-up and removal of pollution point sources. While it is acknowledged that the Marievale Tailings Storage Facilities (TSFs) were established prior to the promulgation of the MPRDA, the mining rights holder would have been required to manage the TSFs since 1998 in terms of the National Environmental Management Act’s (107 of 1998) (NEMA) principles and the National Water Act’s (36 of 1998) (NWA) requirements, namely: Section 28 of NEMA: Duty of care and remediation of environmental damage

(1) “Every person who causes, has caused or may causesignificant pollution or degradation of theenvironment must take reasonable measures toprevent such pollution or degradation from occurring,continuing or recurring…”

NEMA has been amended to clarify that the duty to take reasonable measures to prevent significant pollution or degradation of the environment from occurring, continuing or recurring (“the duty of care”) also applies to pollution that occurred before NEMA commenced; to pollution that might arise at a different time from the actual activity that caused the contamination and to pollution that may arise following an action that changes pre-existing contamination (NEMA section 28(1A)). It is therefore no defence to say that the pollution is historic, indirect or underlying – the responsibility to take reasonable steps remains.

Section 19 of the NWA: 19 (1) An owner of land, a person in control of land or a person who occupies or uses the land on which- Any activity or process is or was performed or undertaken; or Any other situation exists, which causes, has caused or is likely to cause pollution*of a water resource, must take all reasonable measures to prevent any such pollution from occurring, continuing or recurring.

The evidence of surface and groundwater pollution referred to on page 300 of the DEIR is a result of historic mining operations. The historic owner is no longer in existence and Marievale Gold Mine had already been closed by 1998. While Ergo proposes to take control of the TSFs, it never has been the occupier or user of the Historic Marievale Gold Mine properties. We cannot comment on the legacy and the failure of the historic mine owner to address pollution of water.

Section 1.1 Surface Water /

Groundwater



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*(Pollution means the direct or indirect alteration of the physical, chemical or biological properties of a water resource so as to make it less fit for any beneficial purpose for which it may reasonably be expected to be used; or harmful or potentially harmful to the welfare, health or safety of human beings, aquatic or nonaquatic organisms, resource quality or property.) In view of the aforesaid, it begs the question why the mining rights holder failed to prevent the pollution of the surface and groundwater and failed to conduct concurrent (progressive) rehabilitation of the land. Please advise.



Applicable legislation and guidelines In Chapter 4 of the DEIAR we are referred to the applicable legislation, guidelines and provincial and local policies. In preparing the Environmental Management Programme Report (EMPR), we recommend that the Applicant and its EAP align the Project’s management and mitigation measures to the challenges, actions and recommendations identified in:

1. The National Water and Sanitation Master Plan (October 2019). Please see attached hereto.

(ANNEXURE “A”) 2. The Mine Water Management Policy. 3. The United Nations’ Sustainable Development Goals

(SDGs) in particular SDG6, namely, to ensure availability and sustainable management of water and sanitation for all. Targets 6.3 and 6.6 are of specific relevance to the proposed Project, namely to by 2030 improve water quality by reducing pollution, eliminating dumping and minimizing release of hazardous chemicals and materials, and the protection and restoration of water related ecosystems.

4. The National Water Resource Strategy. (ANNEXURE “B”)

5. And since the project will impact upon the Integrated Vaal River System, the Reconciliation Strategy for the Integrated Vaal River System. I attach an extract from the Strategy, which has relevance to the Project hereto.

(ANNEXURE “C”) 6. The NEMA’s Regulations pertaining to financial

provisioning for the rehabilitation and remediation of environmental damage caused by reconnaissance, prospecting, exploration, mining and production operations (2015) and the proposed Regulations (17 May 2019).

(ANNEXURE “D”) 7. The South African Human Rights Commission’s (SAHRC)

Report pursuant to its “National Hearing on the

Noted. The listed policies and guidelines have been incorporated into the Project’s management and mitigation measures and noted where applicable in the final EIA/EMPr. Thank you for the contribution.

Section 4 EAP



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Underlying Socio-Economic Challenges of Mining Affected Communities in South Africa” and the Commission’s enforceable directives on mining in protected and sensitive areas and free, prior and informed consent. Please see attached.

(ANNEXURE “E”) 8. Gauteng Mining Belt Regional Spatial Planning Policy.

(ANNEXUE “F”)



Mining Method We are informed that the reclamation operations will be by means of hydraulic reclamation (page vi of the DEIAR) as opposed to the mechanical excavation of gold bearing tailings. Of relevance in this regarding is Ergo Mining (Pty) Ltd’s (the Applicant) statement on page vii of the Revised Draft Environmental Impact Assessment Report for its Valley Silts Project in which the technology to be used is stated as follows: “Mechanical excavation is preferred. Hydraulically removing the silts can cause irreversible water contamination and is not preferred.” (Emphasis added.)

In view of the above-mentioned statement, it can logically be inferred that the proposed hydraulic reclamation of tailings within close proximity of the Marievale Bird Sanctuary (a RAMSAR site) and the Blesbokspruit wetland (page vi of the DEIAR), if not mitigated and managed responsibly, may cause “irreversible water contamination” of these sensitive and protected areas.

While we laud the Applicant’s intention to remove a historic pollution point-source and rehabilitate the land to a state that is sustainable, functioning and represents a pre-mining landscape (page vii) and the proposed extension of the Marievale Bird Sanctuary/Blesbokspruit Wetland (page 318), we recommend that the EMPR details the rehabilitation objectives and actions with specific time lines and financial provisions to achieve the said restoration.

The two projects are different in nature from a technical perspective. The Valley Silts Project involves the mechanical removal of (wet) silts from within a water course. Spraying of a high-pressure water cannon within such an environment would be detrimental as adding water and agitating with pressure would have a far greater impact than using a excavator to extract the silts. This is why it is not suggested at Valley Silts. The Marievale Project entails the reclamation of dry slimes dams which are not directly in the water course and rather adjacent to the wetland and above surface.

Stormwater management measures have been proposed to prevent surface water from the tailings from entering the Blesbokspruit. Rehabilitation details have been included in the final EIA/EMPr.

Section 2.3

Section 7.7.6

Mining Operations





Need and desirability

On page ix of the DEIAR the expected positive benefits are listed

as firstly, job security for staff and contractors currently contracted

or employed by Ergo; skills development for those employed for

the project; economic growth and contribution to the economy;

and secondly improved surface water quality over time; improved

groundwater quality over time and improved ecosystem health

and functioning over time.

Noted. We add that without a functioning economy, there could

be no environmental protection. The economy and the

environment are co-dependent. With that said, we believe the

removal of the Marievale TSFs will result in positive long-term

environmental effects on the Marievale Bird

Sanctuary/Blesbokspruit wetland.

Section 5 EAP



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The prioritisation by the Applicant of the economic benefits in view

of the escalating ecological crisis in South Africa (e.g. more than

50% of South Africa’s wetlands have been lost, and of those that

remain, 33% are in poor ecological condition; between 1999 and

2011 the extent of main rivers in South Africa classified as having

a poor ecological condition increased by 500%, with some rivers

pushed beyond the point of recovery; the extent of tributaries with

a poor ecological condition increased by 229% in this same period;

only 15% of South Africa’s rivers is in a good condition and with no

sites in a good condition within the Vaal River Water Management

Area; and two-thirds of the total length of SA’s rivers is in a poor

ecological condition) ignores the emerging and more

sophisticated and insightful model of sustainable development,

namely that a healthy environment (biophysical) is the primary

and essential foundation for economic activity. It follows hence

that taking care of the Marievale Bird Sanctuary/Blesbokspruit

wetland which falls within the stressed Integrated Vaal River

System ought to be the first essential priority for the Applicant.

The economic benefits ought to come last as the economy is

entirely dependent on the environment in order to exist at all.





Comment on Risks Associated with Uranium

Page 300 of the DEIAR refers to uranium (U) concentrations in the

order of 1.5mg/L amongst others in the water retention

ponds/facilities at the Daggafontein TSF and U concentrations of

between 0.009 and 0.032 mg/L in the Blesbokspruit

On page 158 of the DEIAR reference is made to the guideline value

proposed by Wade and Winde of 0.02mg/L for the chemical

toxicity of U in drinking water and the NNR’s guideline “of 80mg/kg

for whole rock analysis” and the SANS241:2014 Drinking Water

Standard for U (0.03mg/L).

It follows hence that the U concentrations at a number of sites

exceed the regulatory limits for drinking water. Communities

using the Blesbokspruit for potable usage, irrigation, watering of

cattle, fishing, spiritual rituals, etc. ought therefore to be informed

of the risks since the reclamation operations may, in the short

and/or medium term result in higher U values. Furthermore, the

All environmental findings from specialists assessments conducted

were submitted, along with the DEIAR, for public review.

The Public Safety Assessment is currently underway. Prior to

starting the operations, a CoR will be applied for from the NNR.

Appendix E - EMPr Radiation



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low pH values (page 300) may result in the mobilisation and

solubilisation of U.

Analogous to the above-mentioned risk, MW Sutton and IM

Weiersbye in their treatise titled “South African Legislation

Pertinent to Gold Mine Closure and Residual Risk” found that

during “the reclamation of older sand and slimes dams for residual

gold… there is evidence for remobilization of contaminants (such

as uranium and cyanides) during disturbance of old tailings

deposits.” We support the recommendations of the authors,

namely the adoption of a strict Cleaner Production (CP) approach

for the extractive and waste disposal phases and the incorporation

of the precautionary principle for the medium and long-term

phases.

With reference to the NNR’s guideline of 80mg/kg for whole rock

analysis, kindly advise what the Becquerel measurements (units of

radioactivity) are in the soil/rock. The regulatory limit for

radioactivity in soil is 500Bq/kg.

Page 20 of the DEIAR refer to the applications for an EA to the

DMRE, a waste management Licence and an IWULA. There is no

reference made to an application for a Certificate of Registration

(CoR) to the National Nuclear Regulator (NNR) although the NNR

is listed as a commenting authority on page 23 of the DEIAR. Kindly

clarify.





Pipelines

We are informed on page 27 that one of the pipeline routes, which

will be investigated will be a pipeline connection from the Eastern

Basin AMD Treatment Plant to the Daggafontein plant. Kindly

advise whether this option proposes to use neutralised AMD for

the hydraulic mining of the slimes dams. Our understanding finds

support in the statement on page 29, namely that “where water

makeup is required, this would be from TCTA”.

The reclamation process uses predominantly reused / recycled

dirty mine water. Where there is need for makeup water,

numerous sources are being investigated as potential options.

Water from TCTA is considered as one of the alternatives for

makeup water if and when required.

Section 2.3.4 Pipelines





Stormwater Containment

We are informed on page 29 of the DEIAR that dirty storm water

“will be contained on existing paddocks”. We are also informed on

We agree.

Section 7.6.6

Appendix E - EMPr

Stormwater

Management



41


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RECEIVED




METHOD

page 292 that if a sound SWMP is not implemented then, in the

long term, the proposed project has the potential to cumulatively

add high salt or metal loads to the already deteriorated water

quality within the Blesbokspruit catchment and that “the most

important aspect to prevent negative impacts from a surface

water perspective is to ensure that a sound stormwater

management plan is implemented prior to the commencement of

mining.”

The subjoined photographs, which were taken during the FSE’s

visit in or about March 2019 to the area, documents the collapse

of a side wall (embankment slope) of one of the Marievale TSFs

and the migration of the slimes into the Blesbokspruit. The reason

why the slimes were not contained is because of the poor state of

the exiting paddocks. If the project is authorised, it will be

imperative to ensure that the paddocks are functional from the

outset of the mining activities. Analogous to our crucial

recommendation, the DEIAR recommends that “the existing

trench along the northern side of Dumps 7L5 and 7L6 is desilted

and upgraded according to the SWMP and the existing toe

paddocks around the dumps are desilted and upgraded according

to the SWMP”.

The DEIAR recommends adherence to the conditions in GN R704.

We recommend, in addition to these requirements, compliance

with DWS’ Best Practice Guideline – G1: Storm Water

Management, in particular Principle 2, namely:

• Ensure the minimisation of contaminated areas, reuse of dirty

water wherever possible and planning to ensure that clean areas

are not lost to the catchment unnecessarily.

As described, the mining method is a closed system whereby water

is recycled through the system.

Furthermore, in the EMPr, a stormwater management system is

proposed to prevent dirty water from entering the Blesbokspruit.





Blesbokspruit

The DWS’ Classes and Resource Quality Objectives of Water

Resources for Catchments of the Upper Vaal have relevance.

Please see attached.

(ANNEXURE “G”)

The current ecological state of the Blesbokspruit is because of

multiple past and present activities both upstream and

downstream of the Proposed Project site. Notwithstanding, we

believe that the correct implementation of the recommended

stormwater management measures and EMPr should reduce

surface water impacts to acceptable levels. Also, we envisage that

the complete removal of the TSFs should improve the long-term

Section 7

Section 8

Stormwater

Management



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METHOD

The Blesbokspruit (EWR II RU62) falls within a Category D. The

Resource Quality Objectives recommend:

• Salts need to be improved to levels that do not threaten

the ecosystem and to provide for users. The

recommended numerical limit for Electrical Conductivity

(EC) is 111mS/m.

• The riparian zone must be in a largely modified or better

condition.

• The instream habitat must be in a largely modified or

better condition to support the ecosystem.

• The river water should not be toxic to aquatic organisms

or be a threat to human health. The following numerical

limits are recommended:

o F – 3.0mg/L

o Al – 150 µg/L

o CD hard – 5.0 µg/L

o Cu hard - 8.0 µg/L

o Hg – 1.70 µg/L

o Mn – 1300 µg/L

o Pb hard – 13 µg/L

o Zn – 36 µg/L

It is necessary for the Applicant to demonstrate how the

reclamation of the Marievale TSFs will achieve the above

objectives since according to the DEIAR (page 300) the current SO4

concentrations in groundwater are currently in the order of

4768mg/L; 2400 mg/L, 4000mg/L respectively.

ecological quality of the Blesbokspruit downstream of the

Proposed Project.





Recovery of Gold and Uranium

On page 3 of the DEIAR we are informed that “gold will be the main

mineral prospected” (we assume in terms of the Application,

mined for and not prospected) but that concentrations of uranium

will also be investigated in conjunction with the availability of

stone gravel and waste rock.

The statement on page 70 of the DEIAR namely “the Proposed

Project would play a significant role in eliminating some of these

suspected Uranium pollution sources and reducing the extent of

Noted. These recommendations will be communicated to the

applicant.

N/A EAP



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METHOD

exposure to surrounding communities” in the light of the above

statement is therefore merely aspirational and not an absolute

certainty.

While we have taken cognisance of the fact that the U values are

low, we nonetheless strongly recommend the recovery of U in

order for the residue (to be deposited on the Withok/Brakpan TSF)

to be non-uraniferous. U remains radioactive for geological ages

hence the radioactive risks will continue for millions of years.





Gaps

Lack of data and understanding on how the dumps to the north of

the Marievale dumps and not related to the Marievale project

were managed, the cumulative impacts associated with these are

not assessed (page 294).

The Marievale project falls within a broader project to remove

tailings, reprocess them and deposit them at the Brakpan/Withok

TSF. The dumps north of Marievale are also earmarked for

reclamation.

N/A Reclamation





Conclusion

Page 297 of the Draft Environmental Impact Assessment Report

(DEIAR) informs us of the proposed mitigation actions and

recommends that:

• “All mitigation measure must be strictly adhered to; and

• “Rehabilitation of the wetland expected to be degraded

during the proposed activities must be undertaken”.

In the light of the Department of Human Settlement, Water and

Sanitation’s (DHSWS) and the Department of Mineral Resources

and Energy’s (DMRE) capacity constraints to ensure compliance

with the proposed mitigation and management measures, we

recommend the establishment of a NGO/Community Forum in

addition to the Blesbokspruit Catchment Management Forum in

order for interested and affected parties to:

• “…raise the concerns of the voiceless and marginalised

and hold government, business and all leaders in society

accountable for their actions”. (The National

Development Plan 2030.)

The applicant is already member of the Blesbokspruit Catchment

Management Forum. Comments regarding the project can be

raised in this forum. Creating an additional specific forum will

result in stakeholder fatigue.

N/A Applicant



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METHOD

• “… involve local communities in the decision-making

process.” (Chapter 7 of the National Water Act, 36 of

1998)

• “…play a watchdog role in supporting compliance by

water users with water regulation at all levels.” (National

Water Resource Strategy (9.4.9))

As an active stakeholder, the FSE wishes to participate in such a

Forum.





I write on behalf of the Federation for a Sustainable Environment (FSE).

Noted.

N/A Stakeholder

Engagement





I refer to the attached PowerPoint presentation we received this morning from Marc De Fontaine and in particular Slide 27, bullet point 6.1 and 6.4 namely the proposed interventions pertaining to the Blespokspruit Catchment, that is, to inter alia revise and expand on the selected parameters of the Blesbokspruit Catchment and to determine the assimilative capacity of the Blesbokspruit Wetland.

Noted.

N/A EAP





The above proposed interventions, we believe, have relevance to

the abovementioned Tailings Reclamation Project. We

recommend that the said proposed interventions be included in

the Applicant’s (Ergo Mining) EIA Report and in its EMPR since the

associated contribution of pollution to the Blesbokspruit Wetland

in the short and medium term is likely to be considerable as old

tailings are hydraulically mined using high-pressure water

cannons. This will introduce large volumes of additional water into

a highly disturbed area.

We agree that the Proposed Project does have relevance to some

of the Upper Vaal Blue Deal Project’s proposed interventions.

Specifically, to expand on the selected parameters of the

Blesbokspruit Catchment and to determine the assimilative

capacity of the Blesbokspruit Wetland. Although the project may

impact in the short term; we envisage that the removal of the TSFs

will improve the overall water qualities of the Blesbokspruit.

Mitigation measures to minimise surface and groundwater

impacts from the Proposed Project can be found in Appendix D2

and D3 of the EIA, respectively.

Section 7.6

Section 7.7

Appendix D2

Appendix D3

Surface Water /

Groundwater





The above postulation finds support in the findings of MW Sutton, IM Weiersbye, NF Mphefu, M Viljoen, E Cukrowska, K Govender, TS McCarthy and H Tutu namely that there is evidence of remobilization of contaminants (such as uranium and cyanides) during disturbance of old tailings deposits.

Noted.

N/A EAP



45


COMMENTS

RECEIVED




METHOD




Written Comment 2 June 2020

I apologise for my belated reply to your e-mail and in particular

your response: “For tailings reclamation EIA’s we haven’t seen the

need for climate change specialist assessments as the impact in

these particular cases are negligible.”

Noted, for fullness we add the full response:

“With regards your request, during an EIA process our task as the

Environmental Assessment Practitioner (EAP) at Scoping level is to

select which specialist studies we think would be relevant and

should be done and present these methodologies to the

Competent Authority, this is based on geography and anticipated

impacts, this process is subject to public participation as well. We

sometimes during this Scoping process refine this methodology

depending on the anticipated impacts and may do more work in

areas where we feel need attention or to clarify detail for

interested and affected parties. For tailings reclamation EIA’s we

haven’t seen the need for climate change specialist assessments

as the impact in these particular cases are negligible.”

The Competent Authority has approved our proposed

methodology.

Section 2.2.3 EAP





While we concur that the impacts of climate change may not be as

significant for tailings reclamation projects as for underground and

open cast mining operations, we are of the opinion that climate

change will present challenges to reclamation projects. We have

already witnessed the manifestations of climate change within the

Project Areas such as higher temperatures, altered rainfall

patterns, and more frequent or intense extreme events such as

changes in flow patterns, drought and storms (Marsden Jacob &

Associates, 2006). This, in turn, have and will affect the availability

of water, where and what types of plants and animals can survive,

the quality of their habitats and their abundance.

May we suggest that management/mitigation measures be

proposed in the above-mentioned Projects’ EMPRs to address

these challenges?

While you concur that such reclamation projects may not have an

impact themselves on the climate or be directly conducive to

climate change, you are of the opinion that conversely, climate

change will present challenges to reclamation projects. In

particular, higher temperatures, altered rainfall patterns, and

more frequent or intense extreme events such as changes in flow

patterns, drought and storms may affect the availability of water,

where and what types of plants and animals can survive, the

quality of their habitats and their abundance.

We wish to point out in this regard that as far as water supply is

concerned, the Marievale EIA provides in Paragraph 2.3.4 that –

In terms of water make-up and process water use, Ergo will

make use of its Centralised Water Distribution System to

recycle process water in a closed circuit. Where water

makeup is required, this would be considered from TCTA,

the Strubenvale Water Treatment Plant (WTP) and/or from

the Daggafontein TSF or possibly mine shaft water. The

Central Water Distribution System was commissioned

during the last quarter of 2017 to store and distribute water

emanating from the Rondebult wastewater treatment




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COMMENTS

RECEIVED




METHOD

works, treated AMD water from Trans-Caledon Tunnel

Authority (TCTA) and recycled water from the Brakpan/

Withok Tailings Deposition Facility. The centrally located

water facility allows Ergo to distribute water more

efficiently throughout the operations. Further

improvements have been initiated and implemented to

increase pumping capacity from the Brakpan/ Withok

Tailings Deposition Facility so that more recycled water can

be delivered to the Central Water Distribution System and

better utilised from there. An example of improvements is

the installation of an inline booster pump station to

improve pumping efficiencies and volume from the

Brakpan/Withok TSF and the Central Water Distribution

System. The Central Water Distribution System continues

to perform as planned with significant reductions in potable

water consumed.

The reclamation projects are short term, and accordingly, we do

not foresee risk for a project with a projected operational life of

less than 20 years for the disruption of water supply. Ergo has put

measures in place to ensure they have sufficient water for the

operations as this is a critical factor of business. Furthermore the

surface water specialist study assesses and proposes a storm

water management plan to mitigate for storm events.





The potential for drought in the Witwatersrand and the impacts of

climate change place a particular imperative on the effective

management of the water resources and the wetlands within the

Project areas, and the future land use options for the footprints.

Furthermore, the reclamation of the Soweto Cluster and the

Marievale TSFs proposes to employ hydraulic mining, which

requires water and at the same time deposits slurry containing

polluted water on an unlined TSF.

Noted, as above recycled mine water is the primary water source.

Section 2.3.4

Section 3.4.1

Surface Water





The long-term impacts of climate change on water resources are

not clearly established, but increased variability in the rainfall and

runoff patterns is becoming apparent. Mining effluent on the other

hand is a relatively non-variable and stable source of water. The

use of this effluent as a supplementary water resource is

recommended as a complement to other natural water resources

in terms of the NWRS-2. May we suggest that the EIA/EMPRs also

Please note response above which deals with the overall water

management strategy for the operations.

Section 2.3.4

Section 3.4.1

Surface Water /

Ground Water



47


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RECEIVED




METHOD

include as a mitigation/management measure for climate change,

the desalination of mine process water and re-use of treated

seepage water from the Withok/Brakpan TSF?





In light of the urgency to protect our water resources and changing

hydrological patterns due to climate change, we respectfully

submit that climate adaption measures should be one of the top

priorities of a mining company and consideration of the impacts of

climate change ought to be incorporated in its EIA/EMPRs.

We fully agree that the protection of water courses and

consideration of project impacts on potential climate change, as

well as the potential impacts climate change could have on

potential projects is to be on top of all parties’ priorities.

We maintain that tailings reclamation primarily uses recycled mine

water and the removal of these tailings facilities improves the

overall environmental water qualities over the long term, aligning

with climate goals.

Section 2.3.4

Section 3.4.1

Surface Water /

Ground Water

Page | 4

APPENDIX C:


❖ Appendix C10 – 5 June 2020 Regulations PP Plan

Kongiwe Environmental (Pty) Ltd. Reg No 2016 / 135562 / 07 Directors: MJ Hennessy, BJ Thornton (CEO), GI Wilreker Tel: +27 (10) 140 6508 | Fax: +27 (86) 476 6438 Email: [email protected] 150 Bryanston Drive, Bryanston, Sandton, 2191, South Africa. PostNet Suite no 163, Private Bag X21, Bryanston, 2021, South Africa. www.kongiwe.co.za

15 July 2020

The Regional Director


Gauteng Region

Mineralia Building, Cnr De Korte and De Beer Street

Braamfontein

2017

For Attention: Mr Musa Mangobe

By email: [email protected]

Dear Sir,

APPLICATION FOR ENVIRONMENTAL AUTHORISATION FOR THE RECLAMATION OF THE MARIEVALE

TAILINGS STORAGE FACILITIES, CITY OF EKURHULENI METROPOLITAN MUNICIPALITY, GAUTENG

PROVINCE - DMRE REFERENCE NUMBER: GP30/5/1/1/2(000007BP) BAR

We act as the environmental assessment practitioner for Ergo Mining (Pty) Ltd in respect of an

application for environmental authorisation for the reclamation of the Marievale Tailing Storage

Facility which was submitted to the DMRE on 22 October 2019, bearing Department of Mineral

Resources and Energy (“DMRE”) Reference GP30/5/1/1/2(000007BP)BAR (“the Marievale Project”).

We refer to our correspondence addressed to you on 26 June 2020 in which we submitted the final

Environmental Impact Assessment report / Draft Environmental Management Programme report

(“the EIAR/EMPr”) in respect of the Marievale Project, for a decision.

It has since come to our attention that that the EIAR/EMPr was in fact lodged prematurely in light of

the Directions issued by the Minister of Environment, Forestry and Fisheries (“the Minister of

Environment”) in terms of Regulation 4(10) of the Regulations published by the Minister of

Cooperative Governance and Traditional Affairs in terms of section 27(2) of the Disaster Management

Act, 2002 on 29 April 2020 (“the Permitting Directions”).

The purpose of this letter is therefore to request that you disregard the version of the EIAR/EMPr

lodged with your offices on 26 June 2020, and approve the proposed public participation plan (“the

Proposed Plan”) which is attached and marked “ A”, where after the final EIAR/EMPr will be timeously

lodged at your offices in accordance with the approved public participation plan and timelines

associated therewith. Our reasons for this proposed process follow.



2

Process Followed

On 13 March 2020, Stakeholders were notified that the draft EIAR/EMPr for the Marievale Project

would be made available for public review and comment. The thirty (30) day public review period was

scheduled to run from 19 March 2020 until 21 April 2020 and an open day was planned to take place

on Saturday, 4 April 2020.

On 17 March 2020, Stakeholders were advised that, due to the national disaster, it would not be

possible to convene an open day. It was therefore cancelled.

On 1 April 2020, Stakeholders were further advised that due to directions published by the Minister

of Environment on 31 March 2020 in terms of regulation 10(8) of the Regulations issued in terms of

section 27(2) of the Disaster Management Act (“the Repealed Directions), the application for the

Marievale Project had been suspended for the duration of lockdown, and that the public review period

had accordingly been extended from 21 April 2020 to 14 May 2020.

On 16 April 2020, Stakeholders were informed that an extension of the lockdown period meant that

the public participation period would again be extended until 28 May 2020.

On 26 June 2020, the final EIAR/EMPr was submitted to the DMRE for a decision and I&APs were

advised accordingly.

This process was followed because the Repealed Directions had linked the suspension of time periods

contained in the Environmental Impact Assessment Regulations, 2014 (“the EIA Regulations”) to the

period of lockdown which was later defined in the Regulations published by the Minister of

Cooperative Governance and Traditional Affairs on 29 April 2020, to mean the period between 23H59

on 26 March 2020, until 23H59 on 30 April 2020 when Alert Levels were introduced.

However, when the Permitting Directions were published just over a month later on 5 June 2020, it

appears that the time periods contained in the EIA Regulations had in fact remained suspended for a

period of at least twenty one (21) days (i.e. until 29 June 2020) and that public participation could not

recommence until a public participation plan had been agreed between the applicant and the case

officer.

Accordingly, and after seeking legal advice on this issue, it appears that our continued public

participation process, although it commenced prior to the publication of the Permitting Regulations,

was in fact premature. We are advised that the submission of the final EIAR/EMPr was therefore,

accordingly, premature too.

3

Proposed Way Forward

Against the background set out above, the applicant would like to reopen the public participation

process for a twenty one (21) day period, being the period that remained prior to lockdown. In this

regard we request that you agree to our proposal to do so, and approve the Proposed Plan attached

marked “A”.

In addition, we request that you disregard the EIAR/EMPr which was lodged on 26 June 2020, given

that it was submitted prematurely, so that we may submit the final EIAR/EMPr once the public

participation process has been completed in terms of the Permitting Directions and the approved

public participation plan.

In terms of time periods, we draw your attention to the following. The final scoping report was

accepted by the DMRE on 27 January 2020. This triggered the one hundred and six (106) day period

in which to submit the final EIAR/EMPr. In the ordinary course this would have expired on 12 May

2020. However, in accordance with the Permitting Directions, this time period remains suspended as

of 27 March 2020 unless and until the DMRE and the applicant have agreed on the Proposed Plan.

Accordingly, no extension to the one hundred and six (106) day period is required.

We request that you kindly advise whether you are in agreement with our proposed way forward and

provide us with your decision on the Proposed Plan as soon as possible.

Please feel free to contact us should you wish to discuss the above interpretation and approach.

Yours faithfully,

Bradly Thornton

CHIEF EXECUTIVE

Ergo Mining Operations (Pty) Limited: Reclamation of the Marievale TSF Project Public Participation Plan © 2020 Kongiwe Environmental (Pty) Ltd

Page | 1

Annexure A




PUBLIC PARTICIPATION PLAN

1 INTRODUCTION

Ergo Mining (Pty) Limited (hereafter Ergo) intends to reclaim and reprocess gold residues from the Marievale

tailings storage facilities (TSFs) Nos. 7L5, 7L6 and 7L7. These TSFs are historical mineral deposits (slimes

dams), situated approximately 6 km north-east of Nigel and 10 km south-east of Springs, in the Ekurhuleni

Metropolitan Municipality (EMM). These TSFs were created prior to the promulgation of the Mineral and

Petroleum Resources Development Act, 2002 (Act No 28 of 2002) (MPRDA) and are accordingly not regulated

by the MPRDA.

On 5 June 2020 the Minister of Forestry, Fisheries and the Environment (the Minister) published Directions

in terms of Regulation 4(10) of the Regulations issued by the Minister of Cooperative Governance and

Traditional Affairs (Minister of COGTA) in terms of section 27(2) of the Disaster Management Act, 2002 (Act

No. 57 of 2002) as published on 29 April 2020 in Government Notice No. R. 480 (the Directions). The

Directions replaced the previous Directions published by the Minister on 31 March 2020 in GN R480. The

purpose of the Directions is to provide guidance to ensure fair licensing processes and public participation

processes as required by the environmental laws and regulations specified therein; which include the

Environmental Impact Assessment Regulations, 2014. Annexure 3 to the Directions stipulates the

requirements for the provision of services by environmental assessment practitioners (EAPs) as part of the

environmental authorisation process.

The purpose of this document is to provide details of the Public Participation Process (PPP) for the Scoping

and Environmental Impact Assessment phase (S&EIA) that has taken place to date and to request that you

approve the proposed Public Participation Plan contained herein.

1.1 Applicable Legislation

The PPP is being undertaken in line with the statutory requirements for public participation. The following

legislation was considered when compiling the public participation plan:

❖ Directions published by the Minister on 05 June 2020;

❖ The Regulations published by the Minister COGTA on 29 April 2020;

❖ Public Participation guideline in terms of National Environmental Management Act, (Act No. 107 of

1998)

❖ The EIA 2014 Regulations;


Page | 2

❖ The Constitution of the Republic of South Africa (Act No. 108 of 1996);

❖ The Mineral and Petroleum Resources Development Act (Act 107 of 1998);

❖ The National Water Act (Act No. 36 of 1998);

❖ Promotion of Access to Information Act (Act No. 2 of 2000); and

❖ International good-practice guidelines for public participation and the Core Values of the

International Association for Public Participation.

1.2 Objectives of the Public Participation Process

The PPP objectives are to:

❖ Provide stakeholders with balanced and objective information, to assist them in understanding the

proposed project, alternatives, potential impacts and mitigation measures;

❖ Provide stakeholders the opportunity to participate in the process and provide comment;

❖ Comply with the legal requirements; and

❖ Work directly with stakeholders throughout the environmental regulatory process to ensure that

stakeholder concerns are consistently understood and considered.

1.3 Summary of PPP activities undertaken to date

The PPP for the proposed project is designed to be implemented in phases (Scoping and Impact Assessment

phases). A summary of the PP activities (to date) is outlined in Table 1 below.

Table 1: Summary of the PPP activities

Activity Details Reference in EIA report

Scoping Phase (PPP as part of the Draft Scoping process)

Identification of stakeholders

Stakeholders were identified by means of WinDeed

searches, stakeholder networking and research for the

compilation of a stakeholder database.

Appendix C1

Stakeholder database

Identification of land claims

A formal enquiry, which contained a list of all the directly

affected properties for the project, was submitted to the

Land Claims Commission, Gauteng Department of

Agriculture, Land Reform and Rural Development

(DALRRD) on Thursday, 17 July 2019 (refer to Appendix

C2). Feedback was received by means of letters dated

Wednesday, 30 October 2019 (refer to Appendix C2)

indicating that there are land claims on some of the

properties within the proposed project area.

Appendix C2

Land claims letters

Development of the

Background Information

Document

The BID was developed and emailed to the complete

stakeholder database on Wednesday, 16 October 2019.

The BID was also distributed at stakeholder meetings,

public libraries and it is available on Kongiwe’s

website:http://www.kongiwe.co.za/publications-

view/public-documents/

Appendix C3

BIDs

Proof of stakeholder meetings




Page | 3


Placing of media

advertisements

A newspaper advertisement was placed in the Springs

Advertiser, a Regional newspaper on Thursday, 24

October 2019.

Appendix C4

Media Advertisements

Placing of site notices

Site notices were placed at publicly accessible places within proximity of the project area from Tuesday, 29 October 2019. Copies of the Site Notices were also placed at the following public places:

❖ Dunnottar Public Library, 47 Rhodes Avenue, Dunnottar

❖ Kwa-Thema Public Library, 7019 Nkosi Street, Kwa-Thema, Springs

A site notice placement report and map have been developed, indicating the exact locations where site notices were placed, with photos and GPS coordinates.

Appendix C5

Site notice report and

placement map

Announcement of the

project and Draft Scoping

Report

The announcement letter was emailed to the full

stakeholder database on Wednesday, 16 October 2019

to:

❖ Announce availability of the Draft Scoping Report.

❖ Share details of the open day.

❖ Indicate where the Scoping Report will be available

for public review and comment; and

❖ Provide details of the public review and comment

period.

The Draft Scoping Report is available on Kongiwe’s

website http://www.kongiwe.co.za/publications-

view/public-documents/

Appendix C6

Announcement Letter

Appendix C3

BID

Stakeholder meetings

One-on-one meetings and focus group meetings were

held with Authorities and Directly Affected landowners,

please refer to the attached stakeholders meeting

schedule and minutes. A list of meetings and minutes of

these meetings have been compiled and distributed.

A high-level overview of the Proposed Project was

discussed, and stakeholder comments have been

captured and responded to in the CRR.

Appendix C8

Stakeholder meeting schedule

& Meeting Minutes

Appendix C9

Comments and Responses

Report

Open Day

An open day was held with stakeholders on Saturday, 09

November 2019, from 10H00 until 15H00 at the

Grootvaly Blesbokspruit Wetland Reserve in

Welgadacht Road in Springs. Minutes from the open day

have been compiled and distributed to everyone who

attended the meeting. Comments raised from the

meeting will be included in the Comments and Responses

Report.

Appendix C9

Comments and Responses

Report

Final Scoping Phase (PPP as part of the Final Scoping process)




Page | 4


Update stakeholder details

The stakeholder database has been updated with new

I&APs who formally registered, attended stakeholder

meetings or submitted comments.

Appendix C1

Stakeholder database

Placement of Final Scoping

Reports

The Final Scoping Report for the proposed Marievale

project was made available on the Kongiwe

Environmental website

http://www.kongiwe.co.za/publications-view/public-

documents/

-

Announcement of the Final

Scoping Report

Announcement letter of availability of the Final Scoping

Report for public review and comment was emailed to the

full stakeholder database on Thursday, 28 November

2019.

Appendix C6

Announcement Letter

Impact Assessment Phase (PPP as part of the Draft EIR/EMPr process)

Announcement of the

availability of the Draft

EIR/EMPr Reports

A Notification letter announcing the availability of the

DEIR/EMPr for public review and comment was emailed

to the stakeholder database on Friday, 13 March 2020.

(Public comment period for DEIR/EMPr (30 days):

Thursday, 19 March 2020 to Tuesday, 21 April 2020.

Appendix C6

Announcement Letter

Placement of Draft EIR/EMPr

Reports for public review

and comment

The DEIR/EMPr has been made available to stakeholders

at the following public places:

❖ Dunnottar Public Library

❖ Kwa-Thema Public Library;

❖ Marievale Bird Sanctuary Provincial Nature

Reserve

An electronic copy of the DEIR/EMPr was made available

on Kongiwe’s website

http://www.kongiwe.co.za/publications-view/public-

documents/

Copies of the DEIR/EMPr has been sent to the DMRE and

various Commenting Authorities for review and

comment.

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Open Day cancelled

In light of the announced ban on public gatherings to

curb the spread of COVID-19 and in line with the

Presidential address of 15 March 2020, stakeholders

were informed that the proposed open day for the

Marievale project has been cancelled indefinitely.

Stakeholders have been encouraged to review the

reports and submit written comments to Kongiwe’s

stakeholder engagement team.

A notification letter (Appendix C6) informing

stakeholders about the cancellation of the open day was

sent on Monday, 17 March 2020, by means of email to

the full stakeholder database.

Appendix C6

Notification letter

Placement of media

advertisement for the EIA

An advertisement was placed in Springs Advertiser, a

Regional newspaper on Thursday, 19 March 2020.

Appendix C4

Advertisement

2 PROPOSED PUBLIC PARTICIPATION PLAN FOR THE EIA PHASE

The recent influence of COVID -19 and the associated measures to curb the spread has a major bearing on

the PPP. Our project team has put measures in place to ensure that all stakeholders are meaningfully

consulted by using a wide range of media, documents, and online tools. As set out in the letter to which this

Annexure A is attached, the PPP was interrupted by COVI-19 related legislation with twenty one (21) days

remaining. We therefore propose that the PPP is continued as set out below in the Proposed Public

Participation Plan as follows:

2.1 Communication and Engagement

All stakeholders will be provided with sufficient and accurate project information. Project information will be

made accessible as follows:

❖ Presented in a language and style that stakeholders can understand, with simple explanations of

complex concepts;

❖ Presented both in writing (letters, information sheets, non-technical summaries of the environmental

reports, poster displays) and verbally ( telephonic discussions) since some stakeholders are better at

hearing than at reading, and vice versa

❖ Easily obtainable, i.e. discussion documents will be mailed or emailed to individuals, and available at

stakeholders’ representative organisations and on Kongiwe Environmental’s website.

The various PPP information materials which will be used as part of the environmental regulatory process

will be included as appendices to the relevant reports. The project team envisages that a number of methods


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to publish communication materials, including distribution of hard copy documents (summary of the EIA

reports, notification letters.). Table 2 below provides an overview of the proposed communication and

engagement tools that will support the implementation of this Plan.

Table 2 Communication and engagement tools

Engagement tool Description

Newspaper advertisements

Newspaper advertisement will be placed in The

Star, a regional newspaper to announce the

availability of the Draft EIA/EMPr for public review

and comment, opportunities to provide

comments/concerns and the contact details of the

public participation consultants.

Zero data portals

Electronic copies of the report will be made

available on a zero data portal. This will allow

stakeholders to download the electronic copy of the

report without incurring data charges.

Notification Letter with a Comment and

Registration Form

A notification letter will be compiled and distributed

to all stakeholders. The notification letter will

inform stakeholders of the availability of the Draft

EIA/EMPr reports for public review and comment.

The notification letter will be distributed by means

of an email and hand delivered to stakeholders that

do not have access to email/internet connection.

The comment and registration sheet will also

request stakeholders to indicate their preferred

method of engagement, this will assist with future

engagement.

Telephonic discussions

Follow up telephonic discussions will be held with

key stakeholders and individuals who have no

internet access, please refer to the attached

stakeholder list. The purpose of these discussions is

to ensure that stakeholders are aware of the

availability of the Draft EIA/EMPr reports for public

review and comment. Stakeholders will also be

offered an opportunity to schedule online /

telephonic discussions to discuss the contents of the

Draft EIA/EMPr reports.

SMS Broadcasting

Stakeholders will also be notified by SMS about the

availability of the Draft EIA/EMPr reports and how

they can access the reports. Stakeholders will be


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provided with an opportunity to arrange telephonic

or online engagement sessions (Skype/Microsoft

teams/telephonic) meeting.

Regular emails

Stakeholders will be kept updated by means of

regular email updates.

Online engagement sessions

Online meetings will be held with key stakeholders

where requested via skype. These meetings will be

seen as formal consultation. This will be done by

means of a PowerPoint Presentation which will be

shared and discussed online.

Notice boards

Notice boards informing stakeholders about the

availability of the Draft EIA/EMPr for public review

and comment. Notice boards will be placed in

visible places.

Delivery of hard copies

Hard copies will be printed and distributed through

community representatives and will be enclosed in

a plastic folder and sanitised. Logistics of delivering

the hard copies will be discussed with the relevant

ward councillors and community representatives.

Consultation with the relevant Ward Councillors

and seek advice on the best and practicable way to

distribute notices in their wards to inform

representatives of the communities of the proposed

project.

All proof of correspondence with stakeholders will be recorded and included as appendices to the

environmental reports.

2.2 Stakeholder Consultations Meetings

Focused efforts will be made to engage with directly impacted stakeholders (those residents in the Project

area, or with assets in the area), including vulnerable groups at local level. These individuals will be consulted

directly and via their representatives, and other influential people within communities. Our project team will

liaise with the relevant ward councilors and community leaders regarding the distribution of the project

information through existing channels of communication. Online meetings will be held with key stakeholders

via Skype/Microsoft Teams. Project information will be discussed through a PowerPoint Presentation which

will be shared and discussed online.

All comments raised by stakeholders during these meetings will also be captured into the Comment and

Response Report (CRR). Responses to comments will be provided in line with the overall project scope and

available information.


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2.3 Availability of Reports for public review and comment

Pursuant to the Directions, regarding measures to address, prevent and combat the spread of COVID-19, only

electronic copies of the Environmental Impact Assessment Report/Environmental Management Programme

will be made available. All stakeholders will be encouraged to download the reports from Kongiwe

Environmental’s website: http://www.kongiwe.co.za/publications-view/public-documents/. A non-technical

summary of the report will be compiled and distributed to stakeholders, in a sanitised hard copy for

stakeholders with no access to the internet. However, to cater for those without internet access, hard copies

of the non-technical summary will be distributed through the relevant community representatives. An

electronic copy (CD) of the reports can be made available on request directed to the stakeholder engagement

team. To curb the spread of COVID-19, all hard copies will be enclosed in a plastic folder and sanitised.

2.3.1 Consultation during the Decision-Making Phase

Once the competent authority has come to a decision regarding the authorisation of the project, all

registered stakeholders will be notified of the decision made and the appeal process to be followed. The

decision from the Competent Authority will be communicated to stakeholders by means of notification letter

(electronic and hard copies), SMS, local newspaper advertisement, posters at publicly accessible areas and

on Kongiwe Environmental’s website.

3 Time frames

It is anticipated that the PPP will be implemented as soon as the Competent Authority (Department of

Mineral Resources and Energy) has approved the Public Participation Plan and will run for a period of twenty

one (21) days. All PPP activities will be recorded and documented; these will be incorporated into the Final

EIA report which will be submitted to the DMRE for evaluation.


Documents

1 Environmental Authorisation and an Integrated Water Use Licence Application for the Reclamation of the Marievale Tailings Storage Facilities, …