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COPYRIGHT WARNING With very few exceptions the copyright in all text and other matter, including the manner of presentation, is the exclusive property of the author. It is a criminal offence to reproduce and/or use, without written consent, any matter, technical procedure and/or technique contained in this document. Criminal and civil proceedings will be taken as a matter of strict routine against any person and/or institution infringing the copyright of the author and/or proprietors. INTEGRATED WATER AND WASTE MANAGEMENT PLAN (IWWMP) IN SUPPORT OF THE WATER USE LICENSE APPLICATION (WULA) FOR BHP BILLITON ENERGY COAL SOUTH AFRICA (PTY) LIMITED WOLVEKRANS COLLIERY: APPLICATION FOR DISCHARGE OF EXCESS MINE WATER INTO THE OLIFANTS RIVER UNDER THE CONTROLLED RELEASE SCHEME IN TERMS OF SECTION 21(F) OF THE NATIONAL WATER ACT, 1998 (ACT NO. 36 OF 1998) Prepared for: BHP Billiton Energy Coal South Africa (Pty) Limited Wolvekrans Colliery PO Box 61820 Marshalltown, 2001 Submitted to: Department of Water Affairs Mpumalanga Region Private Bag X10580 Bronkhorstspruit, 1020 Prepared by: Strategic Environmental Focus (Pty) Ltd CSIR Campus, Building 4, 2nd Floor Meiring Naude Street, Brummeria, Pretoria Tel. No.: +27 12 349 1307 Fax. No.: +27 12 349 1229 Website: www.sefsa.co.za E-mail: [email protected] JULY 2014 SEF Project Code: 505591

BHP BILLITON ENERGY COAL SOUTH AFRICA (PTY) … · The table below provides the contact details for the applicant and the independent environmental assessment practitioner: Applicant:

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COPYRIGHT WARNING

With very few exceptions the copyright in all text and other matter, including the manner of presentation, is the exclusive property

of the author. It is a criminal offence to reproduce and/or use, without written consent, any matter, technical procedure and/or

technique contained in this document. Criminal and civil proceedings will be taken as a matter of strict routine against any person

and/or institution infringing the copyright of the author and/or proprietors.

INTEGRATED WATER AND WASTE MANAGEMENT PLAN (IWWMP) IN SUPPORT OF

THE WATER USE LICENSE APPLICATION (WULA) FOR

BHP BILLITON ENERGY COAL SOUTH AFRICA (PTY) LIMITED WOLVEKRANS COLLIERY: APPLICATION FOR DISCHARGE OF EXCESS MINE WATER INTO THE OLIFANTS RIVER UNDER THE

CONTROLLED RELEASE SCHEME IN TERMS OF SECTION 21(F) OF THE NATIONAL WATER ACT, 1998 (ACT NO. 36 OF 1998)

Prepared for:

BHP Billiton Energy Coal South Africa (Pty) Limited Wolvekrans Colliery PO Box 61820

Marshalltown, 2001

Submitted to:

Department of Water Affairs Mpumalanga Region Private Bag X10580

Bronkhorstspruit, 1020

Prepared by:

Strategic Environmental Focus (Pty) Ltd

CSIR Campus, Building 4, 2nd Floor Meiring Naude Street, Brummeria, Pretoria

Tel. No.: +27 12 349 1307 Fax. No.: +27 12 349 1229

Website: www.sefsa.co.za E-mail: [email protected]

JULY 2014

SEF Project Code: 505591

i

CONTENTS CONTENTS i TABLES i

FIGURES i

SECTION 1: BACKGROUND AND MOTIVATION 2

SECTION 2: BASELINE DETAILS OF THE ENVIRONMENT 3

2.1 LOCATION 3

2.2 RECEIVING ENVIRONMENT 3

2.2.1 Geology and soils 3

2.2.2 Climate 3

2.2.3 Hydrology 4

2.2.4 Sensitive Environments 4

2.2.5 Socio-Economic Environment 4

SECTION 3: OVERALL DESCRIPTION OF THE CATCHMENT 6

SECTION 4: DESCRIPTION OF THE PROPOSED ACTIVITIES 8

SECTION 5: LEGAL ASSESSMENT 8

5.1 EXISTING AUTHORISATIONS 8

5.2 SUMMARY OF RELEVANT EXEMPTIONS 9

5.3 SUMMARY OF GENERAL AUTHORISATIONS 9

5.4 SECTION 27(1) MOTIVATION 9

SECTION 6: ASSESSMENT OF RISKS AND PROPOSED MITIGAT ION 11

SECTION 7: WATER MANAGEMENT STRATEGY 16

SECTION 8: PUBLIC PARTICIPATION 25

SECTION 9: REFERENCES 26

TABLES

Table 1: Contamination of surface water resources . .............................................................. 14 Table 2: Groundwater Contamination................. ..................................................................... 15 Table 3: Environmental Monitoring programme applica ble to the Wolvekrans Colliery ...... 17 Table 4: Implementation, Auditing and Reporting Pro tocol ............................................. ...... 21

FIGURES

Figure 1: Locality Map of the Wolvekrans Colliery . .................................................................. 5 Figure 2: The Olifants Water Management Area indica ting the sub-area boundaries (DWAF,

2003)............................................................................................................................. 7

Wolvekrans Colliery Integrated Water and Waste Management Plan 505591

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SECTION 1: BACKGROUND AND MOTIVATION

Strategic Environmental Focus (Pty) Limited has been appointed by BHP Billiton Energy Coal South Africa (Pty) Limited (BECSA) to facilitate the Water Use License Application process for the proposed discharge of waste water generated from mining operations into the Olifants River under the Controlled Release Scheme in terms of Section 21(f) of the National Water Act, 1998 (Act No.36 of 1998). The Wolvekrans Colliery currently has a water use license issued under Section 21(f) of the National Water Act, 1998. The present license (license number is 27/2/2/B611/103/8) was issued on 1 April 2011 and was valid for a period of three (3) years for Portion 35 of the Farm Wolvekrans 17 IS. The registered owner of the property is Ingwe Surface Holdings (Pty) Limited, and this entity is a wholly owned subsidiary of BECSA. BECSA and Tavistock Collieries (Pty) Ltd, jointly hold the mining rights for the property under Mining Right Ref. MP30/5/1/2/2/379MR, and applications have been submitted and approved by the DMR for BECSA to become a 100% holder of the subject area. The present license allows for the release of No. 2 seam underground water into the Olifants River during high flow conditions under the auspices of the controlled release protocol as implemented since 1996. Under the controlled release protocol, the Wolvekrans Colliery released water into the Witbank Dam over a period of 24 hours from 8:00 on 24 December 2013 to 8:00 on 25 December 2013 as per its sulphate allocation of 3.57 tons/day. Due to the impending expiration of the water use license, BECSA is undergoing the process of re-applying for the water use license, with the same conditions under which the previous license was issued. The table below provides the contact details for the applicant and the independent environmental assessment practitioner:

Applicant: BHP Billiton Energy Coal South Africa (P ty) Ltd Address P O Box 61075, Marshalltown, 2107

Contact Person: Mr. Vikesh Dhanooklal

Tel (011) 3762410

Fax -

Email [email protected]

Company Registration number 1963/00053/07

Environmental Assessment Practitioner: Strategic En vironmental Focus Address P.O. Box 74785, Lynnwood Ridge, Pretoria, 0040

Contact Person: Mr Craig Allen

Tel 012 349 1307

Fax 012 349 1229

Email [email protected]

Company Registration number 2002/022066/07

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The following objectives have been set for the project: • Obtain all relevant authorisations and licenses prior to discharge of mine-affected water; • Pollution prevention in all sectors; • Continuous review of the impacts that the Wolvekrans Colliery will have on the environment; • Continuous review and implementation of management measures to minimise or prevent

environmental impacts, including impacts on surface and groundwater resources; • Participate in environmentally related dialogue with stakeholders and provide appropriate

environmental training for all employees and contractors; and • Maintain emergency preparedness through close community communication and forum

participation as well as applicable safety considerations.

SECTION 2: BASELINE DETAILS OF THE ENVIRONMENT

2.1 LOCATION The Wolvekrans Colliery consists of four (4) sections; Albion, Wolvekrans, Vandyksdrift and Vlaklaagte West. It is located in the Olifants Water Management Area (WMA), which extends over the Gauteng, Limpopo and Mpumalanga Provinces. The property on which the discharge activity will take place is limited to Portion 35 of the Farm Wolvekrans 17 IS in the B11G quaternary catchment. A locality map is presented as Figure 1.

2.2 RECEIVING ENVIRONMENT

2.2.1 Geology and soils

The geology within the Olifants WMA generally consists of hard rock formations and the most conspicuous feature is the occurrence of the Bushveld Igneous Complex. The Upper Olifants Sub-area is characterized by the rich coal deposits in the regions of Witbank and Middelburg (DWAF, 2004). The area on which the Wolvekrans Colliery is situated is occurs in the Eastern Highveld Grassland vegetation type, as classified by Mucina and Rutherford (2007). As per this description, the geology and soils are the red to yellow sandy soils of the Ba and Bb land types. It is dominated by the Bb land type at approximately 65% of the vegetation area and approximately 30% Ba. These land types are usually found on shales and sandstones of the Madzaringwe Formation or the Karoo Supergroup and are characterized by undulating landscapes with gentle slopes.

2.2.2 Climate

The climate of the Mpumalanga region is subtropical in nature which is characterised by hot summers and mild to cool winters. The Eastern Highveld Grassland vegetation type shows a strongly seasonal summer rainfall pattern. Mean Annual Precipitation in the area is between 650 and 900 mm with the overall average in the region of 726 mm (Mucina and Rutherford, 2007).

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2.2.3 Hydrology

Due to the amount of mining and industry in the Olifants WMA, the Olifants River is highly regulated. Relative to the study area, two major dams occur. The Witbank and the Middelburg dams primarily meet the demands of both the urban and industrial demands in the region. A large number of pans and wetlands are known to occur in the Upper Olifant Sub-area (DWAF, 2004). Within the boundaries of the Wolvekrans Colliery, seven hydrogeomorphic (HGM) types of wetlands occur that are not considered to be in pristine condition (SEF, 2009). The area of the Olifants River associated with the Wolvekrans Colliery has been found to consist of varied aquatic biotypes or area of uniform structure. There are also two weirs present within the area of the Olifants River associated with the colliery. The Internal Strategic Perspective for the Olifants Water Management Area developed by the Department of Water and Forestry in 2004 indicates that the Mean Annual Runoff (MAR) for the entire Olifants WMA is 2042 million m3/a and the ecological Reserve requirement was estimated at 460 million m3/a using desktop methodology. Mining activities are considered to have the most significant impact on the water in this sub-area, with mining processes disturbing the integrity of the overlying rock and soil strata which significantly impact on infiltration and recharge of the groundwater system (DWAF, 2004). During the original Section 21(f) water use license application process, the MAR was calculated for each of the sections of the mining area. It was found that the MAR for the Wolvekrans section at the exit of the mine property was in the region of 129.4 X 106 m3, contributing 68% of the MAR at the Witbank Dam.

2.2.4 Sensitive Environments

The site on which the Wolvekrans Colliery is situated has been found to harbor a range of sensitive environments, including dams, wetlands (both hillslope seepage and valley bottom wetlands), depressions, rivers, rocky outcrops, open grassland as well as areas under rehabilitation (SEF, 2009). As part of the Biodiversity Action Plan that was created for the Wolvekrans Colliery in 2009, the identified wetlands, rocky outcrops and grassland habitats were highlighted as needing the greatest conservation effort. However, the portion of the Olifants River associated with the colliery was the focus of the biodiversity management objectives.

2.2.5 Socio-Economic Environment

Specific to the industry of mining, it should be noted that development in the Olifants WMA is centered around the mineral deposits of the land. The areas of Witbank and Middelburg have high associated economic activity as well as a concentration of thermal power stations. Mining does contribute a significant amount to the economy of the region, as approximately 22.1% of the gross geographic product can be attributed to mining (DWAF, 2004). The abundant supply of coal in the region also has a knock-on effect for other industries. The availability and supply of cheap coal is instrumental to the success of the manufacturing sector in the region, particularly the steel industry and also the electricity sector. It should also be noted that the highest concentration of the population in the Olifants WMA is found in the Upper Olifants Sub-area (DWAF, 2004).

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Figure 1: Locality Map of the Wolvekrans Colliery

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SECTION 3: OVERALL DESCRIPTION OF THE CATCHMENT

The BECSA Wolvekrans Colliery occurs in the Olifants Water Management Area. This WMA is further divided into 4 sub-areas with the Wolvekrans Colliery is located in the Upper Olifants sub-area. This sub-area is characterised by the extensive coal reserves in the southern region in the areas of Witbank and Middelburg (DWAF, 2004). The Upper Olifants sub-area is also the most urbanised of the WMA, with the population expected to grow in the future. The Olifants River originates in the Highveld of Mpumalanga and the water management area covers three provinces; Gauteng, Mpumalanga and Limpopo. The sub-area consists of the catchment of the Olifants River down to Loskop Dam (DWAF, 2003). On a finer scale, the Wolvekrans Colliery occurs within the Witbank Dam catchment. The Olifants WMA is 54 570m2 in size, taking into account only the South African portion of the Olifants River Catchment. Urban, industrial and mining industries constitute 19% of the total requirements for water in the Olifants Water Management Area. The contribution of urban, industrial and mining sectors to the gross geographic product is more than 50%. In addition, most of the water in the upper Olifants sub-area is used as cooling water for thermal power stations. This is a highly consumptive activity and requires high quality water. According to DWAF (2003), future growth in water requirements in this WMA will be in the power generation, urban, industrial and mining sectors with the largest impact being in the Upper Olifants sub-area. According to the Internal Strategic Perspective developed by the, then, Department of Water Affairs and Forestry for the Olifants WMA in 2004, a Water Resources Yield Model (WRYM) and Water Resources Planning Model (WRPM) does exist for the Olifants WMA. However, there is still uncertainty as to the availability of surface water and groundwater at the local level and more detailed hydrological studies are therefore required. The water quality of the upper Olifants catchment is largely influenced by the coal mining undertaken in the area. This influences the quality of water in the Witbank and Middelburg Dam catchments. The Integrated Water Resource Management Plan prepared by Golder Associates for the DWA (Report No. P WMA 04/000/00/7007) indicated that the TDS and sulphate levels in the Witbank, Middelburg and Loskop Dam have been increasing since 1970.

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Figure 2: The Olifants Water Management Area indica ting the sub-area boundaries (DWAF, 2003)

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SECTION 4: DESCRIPTION OF THE PROPOSED ACTIVITIES The present application for a water use license is specific to the activity of discharging water from mining and associated activities into the Olifants River. The release of such water is to be line with the conditions outlined in the Controlled Release Scheme Protocol that has been in place since 1996. Under this scheme, underground water from the No. 2 coal seam may be released into the Olifants River during high-flow conditions.

SECTION 5: LEGAL ASSESSMENT In order to comply with legal requirements, BECSA Wolvekrans Colliery will at all times adhere to the DWA’s hierarchy of water management and decision-making as described below. BECSA Wolvekrans Colliery will also ensure that legal routes are followed to obtain licenses and authorisations regarding the proposed project (i.e. correct applications within applicable timeframes).

Pollution prevention consideration: Deterioration of water quality must be prevented wherever possible and minimised where complete prevention is not possible. Conservation consideration: Losses of water and consumptive use of water must be minimised. Water quality consideration: Water users must be provided with water of a quality good enough so that it does not cause significant user problems. Sustainability considerations: The project plan must be sustainable over the entire project life cycle as well as over different hydrological cycles.

5.1 EXISTING AUTHORISATIONS BECSA currently holds a water use license for the release of mine affected water under the controlled release scheme. The license number is 27/2/2/B611/103/8 and it was issued on 1 April 2011 and is valid for a period of three (3) years. As such, it expired on 1 April 2014 and as such no discharge may be handled at this stage. BECSA also has an integrated water use license for various activities under Sections 21 (b), (c), (g), (i) and (j) of the National Water Act which bears license number 24084535 issued by the Department of Water Affairs on 10 October 2008.

RESOURCE PROTECTION AND WASTE MANAGEMENT HIERARCHY

Step 1: Pollution Prevention

Step 3: Discharge or disposal of waste and/or waste water

Site specific risk based approach Polluter pays principle

Step 2: Minimi sation of Impacts

Water reuse and reclamation Water treatment

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5.2 SUMMARY OF RELEVANT EXEMPTIONS No exemptions will be applied for in terms of the present application.

5.3 SUMMARY OF GENERAL AUTHORISATIONS No general authorisations have presently been issued for the site, nor will any application be made for a general authorisation in terms of the present project. Part 2: Section 27 (1) of the National Water Act (Act No. 36 of 1998) provides a listing of the considerations, conditions and essential requirements for the issuing of a general authorisation or a water use license. As per Section 27 (1) please find below a motivation for the present water use license application:

5.4 SECTION 27(1) MOTIVATION 1. Section 27 (a) – existing lawful water uses BECSA is the holder of a water use license by virtue of it owning Douglas Colliery Services Limited (License number: 24084535) for section 21 (b), (c), (g), (i) and (j) water uses. In addition, the present water use has been authorised under License Number: 27/2/2/B611/103/8 (File No.: 16/2/7/B100/C94) which expired on 1 April 2014. 2. Section 27 (b) – the need to redress the results of past racial and gender discrimination The BECSA Wolvekrans Colliery provides housing allowances and/or bond assistance to its employees and is a supporter of local initiatives in schools in the vicinity. Technical training and study assistance is also provided for employees. In terms of the present activity, no new initiatives will be undertaken. 3. Section 27 (c) – efficient and beneficial use of water in the public interest BECSA does have a target for the reduction of water consumption. Water utilised on site is recycled where possible and used for dust suppression on site. Although the extraction of water for mining operations is unavoidable, the activity being applied for allows for the large volumes of the extracted water to be reintroduced into the same system. 4. Section 27 (d) – the socio-economic impact – (i) of the water use or uses if authorised; or (ii) of the failure to authorise the water use or uses Given the demand for water by downstream water users in the urban areas of Witbank and Middleburg, the release of water into the system is viewed as positive. The release of mine affected water also ensures that excessive amounts of water are not stored on site at the Wolvekrans Colliery. The failure to grant the authorisation for the proposed water use will result in a general discard of water that could be utilised by downstream urban water users, particularly in the eMalahleni and other downstream municipalities for whom the Olifants River is the main domestic water source.

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5. Section 27 (e) – any catchment management strate gy applicable to the relevant water resource A catchment management strategy is not in place for the Olifants Water Management Area (WMA) and a catchment management agency has not yet been established. The Olifants ISP (DWAF, 2004) indicates that the controlled release scheme will be the protocol to be followed for the management of excess mine water until a catchment management strategy is developed. The only available guideline documents available are the Olifants ISP (DWAF, 2004) and the references to the catchment in the National Water Resources Strategy. 6. Section 27 (f) - the likely effect of the water use to be authorised on the water resource and on other water users The water to be released will contribute to the availability of water for downstream water users. The quality of the water released meets the requirements of the DWA and allows for water users (such as the Wolvekrans Colliery) that have utilised large amounts of water to release water back into the system to provide a measure of counteracting their usage. 7. Section 27 (g) - the class and the resource qual ity objectives of the water resource Resource quality objectives will be set as part of the Reserve Determination Process should it be required, which will be undertaken by the DWA. 8. Section 27 (h) - investments already made and to be made by the water user in respect of the water use in question The investments made by the BECSA Wolvekrans Colliery to date extend to the development of facilities in the mine construction phase to accommodate the storage of water for extended periods until such time as it may be released under the controlled release scheme directives. No new investments will be made by BHP Billiton. 9. Section 27 (i) - the strategic importance of the water use to be authorised The Upper Olifants sub-area is the most water stressed area of the Olifants Water Management Area with the mining operations of the area, the ESKOM power stations and the burgeoning urban demand. Thus, the release of treated water will contribute to water availability in the catchment. Presently water is transferred from the Vaal, Usuthu and Komati River catchments to accommodate the present need by ESKOM power stations. All water released back into the Olifants River is done so under conditions laid out in the controlled release scheme protocol. 10. Section 27 (j) – the quality of water in the wa ter resource which may be required for the Reserve and for meeting international obligations From available information on the characteristics of the Olifants Water Management Area, the water quality of the Upper Olifants sub-area is heavily impacted upon by the mining in the Witbank and Middleburg area. From the Internal Strategic Perspective document for the Olifants River Water Management Area (DWAF, 2004), indicated that the water quality Reserve was not determined and would be phased in as part of the Integrated Water Resource Management (IWRM) process. The reconciliation strategy for the Olifants River

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Water Supply available on the Department of Water Affairs website (accessed 6 March 2014) also indicates that the ecological Reserve for the Olifants River Catchment is not yet operational. Thus, the reserve determination will be determined by the DWA. It is anticipated that the ecological Reserve will be implemented in 2017 subsequent to the proposed De Hoop Dam reaching full capacity. 11. Section 27 (k) – the probable duration of any u ndertaking for which a water use is to be authorised The water use being applied for is envisioned to continue until the closure of the mine or the cessation of mining activities.

SECTION 6: ASSESSMENT OF RISKS AND PROPOSED MITIGAT ION

The proposed development will have negative impacts on the quality of the water resource. This has however, been taken into account in the development of the controlled released scheme protocol for both the Witbank and Middelburg Catchments.

Listed below is the methodology employed to determine the significance of impacts

The criteria for the description and assessment of environmental impacts were drawn from the EIA Regulations promulgated under the National Environmental Management Act, 1998 (Act No. 107 of 1998). Activities within the framework of the proposed development and their respective construction and operational phases, give rise to certain impacts.

The activities arising from each of these phases have been included in the impact tables. This is to identify activities that require certain environmental management actions to mitigate the impacts arising from them. The criteria against which the activities were assessed are given in the next section. Assessment Criteria The assessment of the impacts has been conducted according to a synthesis of criteria required by the integrated environmental management procedure.

Extent The physical and spatial scale of the impact is classified as: a) Footprint: The impacted area extends only as far as the activity, such as footprint occurring within

the total site area. b) Site: The impact could affect the whole, or a significant portion of the site. c) Regional: The impact could affect the area including the neighbouring farms, the transport routes

and the adjoining towns. d) National: The impact could have an effect that expands throughout the country (South Africa). e) International: Where the impact has international ramifications that extend beyond the boundaries

of South Africa.

Duration The lifetime of the impact, that is measured in relation to the lifetime of the proposed development. a) Short term: The impact will either disappear with mitigation or will be mitigated through a natural

process in a period shorter than that of the construction phase.

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b) Short to Medium term: The impact will be relevant through to the end of a construction phase. c) Medium term: The impact will last up to the end of the development phases, where after it will be

entirely negated. d) Long term: The impact will continue or last for the entire operational lifetime of the development, but

will be mitigated by direct human action or by natural processes thereafter. e) Permanent: This is the only class of impact, which will be non-transitory. Mitigation either by man or

natural process will not occur in such a way or in such a time span that the impact can be considered transient.

Intensity The intensity of the impact is considered by examining whether the impact is destructive or benign, whether it destroys the impacted environment, alters its functioning, or slightly alters the environment itself. The intensity is rated as: a) Low: The impact alters the affected environment in such a way that the natural processes or

functions are not affected. b) Medium: The affected environment is altered, but functions and processes continue, albeit in a

modified way. c) High: Function or process of the affected environment is disturbed to the extent where it temporarily

or permanently ceases.

Probability This describes the likelihood of the impacts actually occurring. The impact may occur for any length of time during the life cycle of the activity, and not at any given time. The classes are rated as follows: a) Improbable: The possibility of the impact occurring is none, due either to the circumstances, design

or experience. The chance of this impact occurring is zero (0%). b) Possible: The possibility of the impact occurring is very low, due either to the circumstances, design

or experience. The chances of this impact occurring is defined as 25%. c) Likely: There is a possibility that the impact will occur to the extent that provisions must therefore be

made. The chances of this impact occurring is defined as 50%. d) Highly Likely: It is most likely that the impacts will occur at some stage of the development. Plans

must be drawn up before carrying out the activity. The chances of this impact occurring is defined as 75%.

e) Definite: The impact will take place regardless of any prevention plans, and only mitigation actions or contingency plans to contain the effect can be relied on. The chance of this impact occurring is defined as 100%.

Mitigation The impacts that are generated by the development can be minimised if measures are implemented in order to reduce the impacts. The mitigation measures ensure that the development considers the environment and the predicted impacts in order to minimise impacts and achieve sustainable development.

Determination of Significance – Without Mitigation Significance is determined through a synthesis of impact characteristics as described in the above paragraphs. It provides an indication of the importance of the impact in terms of both tangible and intangible characteristics. The significance of the impact “without mitigation” is the prime determinant of the nature and degree of mitigation required. Where the impact is positive, significance is noted as “positive”. Significance is rated on the following scale:

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a) No significance: The impact is not substantial and does not require any mitigation action. b) Low: The impact is of little importance, but may require limited mitigation. c) Medium: The impact is of importance and is therefore considered to have a negative impact.

Mitigation is required to reduce the negative impacts to acceptable levels. d) High: The impact is of major importance. Failure to mitigate, with the objective of reducing the

impact to acceptable levels, could render the entire development option or entire project proposal unacceptable. Mitigation is therefore essential.

Determination of Significance – With Mitigation Determination of significance refers to the foreseeable significance of the impact after the successful implementation of the necessary mitigation measures. Significance with mitigation is rated on the following scale: a) No significance: The impact will be mitigated to the point where it is regarded as insubstantial. b) Low: The impact will be mitigated to the point where it is of limited importance. c) Low to medium: The impact is of importance, however, through the implementation of the correct

mitigation measures such potential impacts can be reduced to acceptable levels. d) Medium: The impact is of major importance but through the implementation of the correct mitigation

measures, the negative impacts will be reduced to acceptable levels. e) Medium to high: Notwithstanding the successful implementation of the mitigation measures, to

reduce the negative impacts to acceptable levels, the negative impact will remain of significance. However, taken within the overall context of the project, the persistent impact does not constitute a fatal flaw.

f) High: The impact is of major importance. Mitigation of the impact is not possible on a cost-effective basis. The impact is regarded as high importance and taken within the overall context of the project, is regarded as a fatal flaw. An impact regarded as high significance, after mitigation could render the entire development option or entire project proposal unacceptable.

Assessment Weighting Each aspect within an impact description was assigned a series of quantitative criteria. Such criteria are likely to differ during the different stages of the project’s life cycle. In order to establish a defined base upon which it becomes feasible to make an informed decision, it was necessary to weigh and rank all the criteria.

Ranking, Weighting and Scaling For each impact under scrutiny, a scaled weighting factor is attached to each respective impact (Figure 1). The purpose of assigning such weights serve to highlight those aspects considered the most critical to the various stakeholders and ensure that each specialist’s element of bias is taken into account. The weighting factor also provides a means whereby the impact assessor can successfully deal with the complexities that exist between the different impacts and associated aspect criteria.

Simply, such a weighting factor is indicative of the importance of the impact in terms of the potential effect that it could have on the surrounding environment. Therefore, the aspects considered to have a relatively high value will score a relatively higher weighting than that which is of lower importance.

Identifying the Potential Impacts Without Mitigatio n Measures (WOM) Following the assignment of the necessary weights to the respective aspects, criteria are summed and multiplied by their assigned weightings, resulting in a value for each impact (prior to the implementation of mitigation measures).

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Figure 1: Description of biophysical assessment par ameters with its respective weighting Equation 1: Significance Rating (WOM) = (Extent + Intensity + Duration + Probability) x Weighting Factor Identifying the Potential Impacts With Mitigation M easures (WM) In order to gain a comprehensive understanding of the overall significance of the impact, after implementation of the mitigation measures, it was necessary to re-evaluate the impact. Mitigation Efficiency (ME) The most effective means of deriving a quantitative value of mitigated impacts is to assign each significance rating value (WOM) a mitigation effectiveness rating. The allocation of such a rating is a measure of the efficiency and effectiveness, as identified through professional experience and empirical evidence of how effectively the proposed mitigation measures will manage the impact. Thus, the lower the assigned value the greater the effectiveness of the proposed mitigation measures and subsequently, the lower the impacts with mitigation.

Equation 2: Significance Rating (WM) = Significance Rating (WOM) x Mitigation Efficiency or WM = WOM x ME Significance Following Mitigation (SFM) The significance of the impact after the mitigation measures are taken into consideration. The efficiency of the mitigation measure determines the significance of the impact. The level of impact is therefore seen in its entirety with all considerations taken into account.

6.1 Impacts and Mitigation

i. Contamination of surface water resources Source and description of the impact: The release of mine affected water into the Olifants River during periods of high flow. Table 1: Contamination of surface water resources

Activity Release of mine affected water

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Nature of the impact

Contamination of surface water resources Status -

Receiving environment

The Olifants River

Magnitude

Extent Regional (3 ) Intensity High (5) Duration Short – Medium term (2) Probability Likely (3)

Significance

Without mitigation (WOM)

(Extent + Intensity + Duration + Probability) x Weighting Factor (3 + 5 + 2 + 3) x 5 = 65

High With mitigation (WM)

WOM x ME = WM 65 x 0.8 = 52 Medium - High

Significance With Mitigation (WM)

Medium – High

Mitigation Measures • The present surface water quality monitoring programme should continue and it is recommended that

selected metals should be monitored in addition to the present parameters; and

• The release of mine-affected water should only be done when high flow conditions make allowances for such release and no deviation from the conditions of the controlled release scheme should be entertained.

Significance of the impact: The significance of this impact is high and as such the conditions of the present license indicates the release of water of a set quality and quantity to be released into the Olifants river and such activities are only to be exercised under pre-set circumstances outlined by the Department of Water Affairs. To this end, BECSA complies with such conditions presently and will continue to do so. The conditions of release take consideration the effect of the water on the surface resources. ii. Contamination of groundwater resources Source and description of the impact: Water currently stored in Pit 4A is at maximum capacity and the possibility of spillage or seepage into the groundwater system exists. Table 2: Groundwater Contamination

Activity Spillage and seepage of stored water for extended p eriods prior to release into the water resource

Nature of the impact Contamination of groundwater resources Status - Receiving environment

Groundwater system

Magnitude

Extent Region (3) Intensity Medium (3) Duration Medium term ( 3) Probability Likely ( 3)

Significance Without mitigation (WOM)

(Extent + Intensity + Duration + Probability) x Weighting Factor (3 + 4 + 3 + 3) x 4 = 48 Medium

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With mitigation (WM)

WOM x ME = WM 52 x 1 = 48 Medium

Significance With Mitigation (WM)

MEDIUM

Mitigation Measures: • The present groundwater monitoring programme instituted at the Wolvekrans Colliery in 1999 must

continue and regular reports, as per the conditions of the license, should be submitted to the Department of Water Affairs; and

• The only water stored in Pit 4A in anticipation of release into the water resource must adhere to the water quality specifications outlined in the conditions of the water use license to be issued.

Significance of the impact: This impact has a significance of medium. A groundwater monitoring programme is currently in place and monitors the effects of possible seepage on the groundwater system.

SECTION 7: WATER MANAGEMENT STRATEGY The BECSA Wolvekrans Colliery subscribes to the philosophy of the Resource Protection and Waste Management Hierarchy of the Department of Water Affairs, as outlined in Section 5 of this document. The water use and management system consists of the following aspects:

• Water Supply;

• Process Water Supply;

• Clean Water Management Facilities; o Primary Clean Water Management System o Secondary Clean Water Management System o Management of Olifants River Flood Events

• Dirty Water Management Systems;

• Sewage Management Facilities; and

• Water Balance. In terms of waste management policies, the Wolvekrans Colliery has active policies and procedures for the short term and long term management of mine residue as well as solid waste management, Under the auspices of the Douglas Colliery, a detailed, implemented monitoring system was developed which included the monitoring of the new and existing opencast mining activities. The system also includes a detailed environmental monitoring system and implementation, auditing and reporting protocols. The following tables have been sourced from the Douglas Colliery Integrated WUL application of 2010.

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Table 3: Environmental Monitoring programme applica ble to the Wolvekrans Colliery

Aspect

Issue Purpose Monitoring points

Frequency Sampling method

Variables

Surface water Olifants River Determine any deterioration in water quality as a result of the mining related activities

Refer to App D Monthly Grab sampling

EC, pH, TDS, SS, Cl, SO4, NO3, Na, F, Fe, Al, Mn, Zn, Total Alkalinity, Ca, Mg, K, Total Hardness.

Six monthly Grab sampling

Analyses to 95% charge balance, including all metals and hydrocarbons.

Clean water canals Determine the sediment levels or any other contamination prior to discharge into the Olifants River

Downstream points on northern and southern canals

Monthly Grab sampling

EC, pH, TDS, SS, Cl, SO4, NO3, Na, F, Fe, Al, Mn, Zn, Total Alkalinity, Ca, Mg, K, Total Hardness, hydrocarbons.

Water management infrastructure

Monitoring of condition, identifying areas that require maintenance

Along clean and dirty water canals, dirty water dams

Quarterly After a big rain event.

Visual Evidence of erosion, cracks, subsidence, overgrowth, etc.

Dirty water systems Determine the water quality and long-term chemical changes in the dirty water systems

Dirty water dam Monthly Grab sampling

EC, pH, TDS, SS, Cl, SO4, NO3, Na, F, Fe, Al, Mn, Zn, Total Alkalinity, Ca, Mg, K, Total Hardness.

Overburden stockpiles, contingency berms

Determine any seepages from the overburden stockpiles that could impact on the water quality of the Olifants River

Along the full extent of the overburden stockpiles and contingency berms

Quarterly Visual inspection

Evidence of salt precipitation or water seeps.

Haul road crossings To identify and mitigate any spillages into the clean water system

All haul road crossings over clean water canals

Weekly Visual inspection

Evidence of spillages

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Aspect

Issue Purpose Monitoring points

Frequency Sampling method

Variables

Biomonitoring Determine ecological integrity of the Olifants River

Refer to App D Quarterly SASS4/5 IHAS

SASS4/5 IHAS

Annually FAII FAII Groundwater Groundwater

quality To determine any impact on the groundwater quality as a result of mining

Refer to App D Six monthly High integrity grab sampler (double valve), preferably made from PVC/Teflon

Neutral to alkaline pH-environments: pH, EC, TDS, Ca, Mg, Na, K, Cl, SO4, NO3, Total Alkalinity, F, Fe, Al and Mn. Acidic pH-environments: All of the above parameters, and including a full range of heavy metals. (Note: An ICP-scan will give a semi-quantitative indication of heavy metals that are mobilized at significant levels, which could be utilised to determine heavy metals to be monitored).

Groundwater levels To determine any impact on the groundwater quantity as a result of mining

As above As above High integrity dip meter

Water level

Mine water balance

Rainfall and evaporation

To obtain long-term data records to verify the water balance model

VDD Weather Station

Daily Visual Volume (mm)

Water levels in dams

To verify water balance and volume of dirty water stored

Points to be determined

Monthly Survey Height (m)

Dirty water volumes To determine volume of dirty water pumped and stored

Points to be determined

Monthly reading

Water meters Volume (m3)

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Aspect

Issue Purpose Monitoring points

Frequency Sampling method

Variables

Water volumes abstracted

To determine volume of dirty water abstracted for processing and dust suppression

Points to be determined

Monthly reading

Water meters Volume (m3)

Clean water discharged

To determine volume of clean water discharged to the Olifants River

Points to be determined

Monthly reading

To be determined

Volume (m3)

Inter -mine flow

Barrier pillars To confirm barrier pillar geometry

Selected points (to be finalised)

Once off Survey Thickness distribution Coal seam floor elevations Structural integrity

Hydraulic properties To confirm hydraulic properties in barrier pillars

As above Once off Directional (horizontal) or normal air percussion drilling. Packer tests

Horizontal and vertical hydraulic conductivity

Water levels To determine groundwater make and recharge rates in underground workings and barrier pillars

As above Barrier pillar boreholes

Six monthly (unflooded) Quarterly (flooded)

High integrity dip meter (non-stretchable material)

Water level distribution from adjacent sections to be included in database.

Water quality To determine groundwater qualities in underground workings and barrier pillars

As above Six monthly High integrity grab sampler (double valve)

As for groundwater quality

Land use management

Concurrent rehabilitation

To determine conformance with environmental objective for concurrent rehabilitation

Mining area Monthly Survey Hectares disturbed Hectares levelled Hectares topsoiled Hectares revegetated

Topsoil placement To ensure compliance with arable standards (minimum 600mm)

Rehabilitated areas

Monthly Survey Thickness of topsoil

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Aspect

Issue Purpose Monitoring points

Frequency Sampling method

Variables

Rehabilitation plan To ensure conformance to final rehabilitation plan and free-draining standard

Rehabilitated areas

Monthly Survey Final level of rehabilitation

Soil analysis To determine any deficiencies in soil fertility prior to seeding

Topsoiled areas Ongoing (prior to seeding)

Soil samples As per specialist advise

Alien vegetation To monitor conformance with alien vegetation programme

Total mining area, including rehabilitated areas

Monthly (during eradication programme)

Survey Area (hectares)

Air quality Dust outfall To determine the levels of dust outfall as a result of the mining activities

Sites 3, 4, 14-18, 20-22

Continuous Dust outfall buckets

Settleable particles (mg/m2/day)

Environmental noise

Noise levels To determine the noise levels within the communities and sensitive areas

KwaJuma VDD Village Douglas Hostel

Monthly To be determined

dBA

Blasting Air blast and ground vibration

To determine the effectiveness of the blasting procedure and early identification of potential infrastructural damage

As per specialist advise

Natural resources

Fresh water abstraction

To measure conformance to water conservation objectives

As per Water Conservation Strategy

Energy conservation

To measure conformance to energy conservation objectives

As per Energy Conservation Strategy

Waste minimisation To measure conformance to waste minimisation objectives

As per Waste Minimisation Strategy

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Table 4: Implementation, Auditing and Reporting Pro tocol

Aspect Programme/Audit Schedule/Frequency Comments

PROGRAMMES/PLANS

Land use management Revision of land use management plan

Within first year of mining. Any substantial changes to mining plan/schedule

Review existing seed mix.

Revision of alien vegetation programme

Annually

Flora rescue operations Annually, in growing season First rescue operation must be initiated prior to construction

Rehabilitation of an equivalent area of wetland to that being lost due to mining, within the same catchment.

Rehabilitation commitment to be finalised with DWAF prior to mining.

Natural resources

Revision of water conservation strategy

Within first year of mining. Any substantial changes to mining plan/schedule

Revision of energy conservation strategy

Within first year of mining. Any substantial changes to mining plan/schedule

Revision of waste minimisation strategy

Within first year of mining. Any substantial changes to mining plan/schedule

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Aspect Programme/Audit Schedule/Frequency Comments

Geology Update/revision of geological/structural plans

Annually

Mining plan/schedule Revision of mining plan/schedule and materials balance

Monthly

Rehabilitation plan Development and ongoing revision of rehabilitation plan

Within 18 months of commencement. Any substantial changes to mining plan/schedule

Monitoring programme Revision of monitoring programme, including inter-mine flow monitoring protocol

Annually Including Tables 4.1 and 4.2. Reporting protocol to DWAF to be finalised.

Standard Operating Procedures (SOPs)

Revision of all environmental SOPs to include the proposed new mining area, ensuring that the environmental objectives and strategies (Chapter 4) are addressed adequately.

Within first year of mining. Any substantial changes to mining plan/schedule

The necessary inspection and auditing programmes and procedures will be included in the revised SOPs.

Operational mine water balance

Operational surface water balance Within 3 years of operation Any substantial changes to mining plan/schedule

Groundwater balance Within 5 years of operation Any substantial changes to mining plan/schedule

Post -closure water - and salt -balance

Post-closure water balance Within 5 years of operation Any substantial changes to mining plan/schedule

Inter-mine flow modelling Within 5 years of operation Detailed geochemical assessment Within first year of mining

Revision after 5 years

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Aspect Programme/Audit Schedule/Frequency Comments

AUDITING PROGRAMME

Implementation programme Conformance to environmental objectives and strategies and the implementation thereof

Six monthly, as part of the BHP Billiton HSEC reporting schedule

Internal audit

EMP performance assessment To determine conformance with the Douglas EMP amendment, including effectiveness and appropriateness of EMP

Biennially External audit As required by the MPRDA Submitted to DME

ISO 14001 Continuation of certification audit Annually External audit Vegetation audit To determine effectiveness of land

use management plan and long-term sustainability of vegetated areas

Annually External audit

Legal compliance Environmental legal compliance audit Annually External audit Financial provision Revision of closure cost assessment

for immediate (unplanned) closure Annually Internal assessment

External audit every 5 years

REPORTING SCHEDULE

Environmental monitoring Review and analyses of monitoring data for:

- Surface water - Mine water balance - Land use management - Air quality - Environmental noise - Blasting - Natural resources

Monthly Develop reporting protocol Report to Mine Management

Review and analyses of monitoring data for:

- Groundwater - Inter-mine flow - Biomonitoring

Six monthly Develop reporting protocol (refer to groundwater specialist report for groundwater reporting protocol) Report to Mine Management

EMP performance Reporting to DME Biennially HSEC performance Reporting to BHP Billiton Energy Coal

South Africa (Pty) Limited Corporate

Six monthly

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*The documentation in the above tables has been extracted from the supporting documentation for the Douglas Colliery Integrated Water Use License Application, 2010

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SECTION 8: PUBLIC PARTICIPATION The water use license application forms and associated information is to be released into the public domain. The public comment period will be open from Tuesday, 29 July 2014 until Tuesday, 30 September 2 014. The public consultation protocol will be undertaken in line with the requirements laid out in Section 41 (4) of the NWA, 1998. This will include the following:

• Notification of the application for authorisation by way of: o An advertisement in a local newspaper; o The erection of site notices in conspicuous locations surrounding the location of the proposed

activities; and o Notification letters to bring the application to the attention of relevant organs on state,

interested persons and the general public. The notifications outlined above will describe the license being applied for, state that written objections may be lodged against the application within 60 days of the publications of the notifications, and will include the address to which written objections should be lodged. All of the comments and responses received will be collated and a comments and responses report produced as part of the Public Participation process and this document will be submitted to the Department of Water Affairs together with the final WULA submission.

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SECTION 9: REFERENCES

Department of Water Affairs and Forestry, South Africa. 2004. Olifants Water Management Area: Internal Strategic Perspective. Prepared by GMKS, Tlou and Matji and WMB on behalf of the Directorate: National Water Resource Planning. DWAF Report No P WMA 04/000/00/0304 Department of Water Affairs and Forestry (2003). Olifants Water Management Area: Overview of Water Resources Availability and utilisation. Report No.: P WMA 04/000/00/0203, September 2003 Mucina, L and Rutherford, M.C. (eds), South Africa. 2006. The vegetation of South Africa, Lesotho and Swaziland. Strelitzia 19. South African National Biodiversity Institute, Pretoria Reconciliation Strategy for the Olifants River Water Supply, http://www.dwaf.gov.za/Projects/OlifantsRecon/default.aspx (accessed 6 March 2014) Strategic Environmental Focus, South Africa. 2009. Douglas Colliery, BHP Billiton: Biodiversity Action Plan. Prepared by Byron Grant. SEF Reference Number: 502041