Sentula Mining Nkomati Anthracite Mine (Pty) Ltd ... · Underground mining Underground pillar failure Ensure that pillar failure does not re-occur. The underground mine workings are

Sentula Mining

Nkomati Anthracite Mine (Pty) Ltd

Environmental Management Programme Performance Assessment

January 2017

Alta van Dyk Environmental Consultants cc

P.O. Box 1005

Midlands Estates

1692

Tel: +27 12 940 9457

Cell: +27 82 782 4005 [email protected]

Sentula Mining

Nkomati Anthracite Mine (Pty) Ltd

Environmental Legal Compliance Assessment and Performance Assessment Report of the Environmental Management Programme for Nkomati Anthracite Mine (Pty) Ltd

January 2017

Alta van Dyk Environmental Project Ref - 047

Prepared by: Kai Petty

The perusal, use, copying or storing of this Report is intended for the use of the recipient. As such, the information may be legally privileged and the unauthorized use is strictly prohibited and may be unlawful.

The opinions expressed in this Report have been based on the information supplied to Alta van Dyk Environmental Consultants cc (AvDEnvironmental) by company officials. The opinions in this IWULA Report are provided in response to a specific request from company officials to do so. AvDEnvironmental has exercised all due care in reviewing the supplied information. Whilst AvDEnvironmental has compared key supplied data with expected values, the accuracy of the results and conclusions from the review are entirely reliant on the accuracy and completeness of the supplied data. AvDEnvironmental does not accept responsibility for any errors or omissions in the supplied information and does not accept any consequential liability arising from commercial decisions or actions resulting from them. Opinions presented in this report apply to the site conditions and features as they existed at the time of AvDEnvironmental’s investigations, and those reasonably foreseeable. These opinions do not necessarily apply to conditions and features that may arise after the date of this IWULA Report, about which AvDEnvironmental had no prior knowledge nor had the opportunity to evaluate.

VERSION CONTROL

Alta van Dyk Environmental cc

Version: Final

Approved by: Alta van Dyk

Signed:

Position: Environmental Specialist

Date: January 2017

NkomatiAnthraciteMine–PerformanceAssessment

Contents

1 INTRODUCTION AND BACKGROUND ............................................................................................................. 6

1.1 Introduction .......................................................................................................................................... 6

1.2 Site Locality ........................................................................................................................................... 8

1.2.1 Underground Mining Area ......................................................................................................... 11

1.2.2 Processing Plant and adjacent Old Opencast Area: ................................................................... 13

1.2.3 Madadeni Opencast ................................................................................................................... 15

1.3 Structure to the Performance Assessment Report ............................................................................. 17

1.4 Legend to the Performance Assessment ............................................................................................ 17

2 APPLICABLE LEGISLATION ............................................................................................................................. 18

3 DOCUMENT REVIEW ..................................................................................................................................... 19

4 EMP MANAGEMENT COMMITMENTS .......................................................................................................... 21

5 SITE INSPECTION AND COMPLIANCE EVLUATION ........................................................................................ 33

6 ACTION PLAN ................................................................................................................................................ 48

7 References .................................................................................................................................................... 49


Tables Table 1:1 Performance Assessment Colour Coding ‐ Compliance Status ...................................................... 17

Table 2:1 Applicable legislation governing Nkomati Anthracite Mine .......................................................... 18

Table 3:1 Nkomati Mine Environmental Document Review ......................................................................... 19

Table 4:1 2005 EMPR Commitments ‐ Processing Plant, Opencast Mining and Underground Mining ......... 21

Table 4:2 2005 EMPR Commitments – Opencast Mining adjacent to the Processing Plant ......................... 24

Table 4:3 2012 EMPR Commitments – Madadeni Opencast Pit.................................................................... 25

Table 4:4 Post Closure ................................................................................................................................... 31

Table 5:1 Processing Plant Area .................................................................................................................... 33

Table 5:2 Underground Area ......................................................................................................................... 42

Table 5:3 Madadeni Opencast ....................................................................................................................... 45

Table 6:1 Action Plan ‐ Madadeni Opencast ................................................................................................. 55

Table 6:2 Action Plan – Processing Plant ....................................................................................................... 56


Figures Figure 1:1 Nkomati Anthracite Mine ‐ Mining Right Area 8

Figure 1:2 Nkomati Mine Overview 10

Figure 1:3 Underground Mine Area 12

Figure 1:4 Processing Plant and adjacent Old Opencast Area 14

Figure 1:5 Madadeni Opencast Area 16


ABBREVIATIONS

DMR ‐ Department of Mineral Resources

EIA ‐ Environmental Impact Assessment

EMP ‐ Environmental Management Programme

EMPR ‐ Environmental Management Programme Report

MPRDA ‐ Mineral and Petroleum Resources Development Act

NEMA ‐ National Environmental Management Act

PCD Pollution Control Dam

SWMP Storm Water Management Plan

WULA ‐ Water Use Licence Application

WUL ‐ Water Use Licence


1 INTRODUCTIONANDBACKGROUND

1.1 Introduction

Nkomati Anthracite Mine (Pty) Ltd has contracted Alta van Dyk Environmental (Pty) Ltd to

conduct a Performance Assessment for the Nkomati Anthracite Mine operations.

The assessment is a systematic evaluation of activities onsite and aims to determine:

Which elements of the current operations are addressed in the existing

Environmental Management Programme Reports (EMPRs) and amendments,

Where gaps exist,

Where management commitments need to be reconsidered in light of current

management practices,

Where commitments may not be appropriate.

This assessment involved the review of available environmental documentation, as well as a

site inspection of the operations.

The performance assessment included:

Review of existing environmental reports and approvals for Nkomati Mine;

Review of the 2005 EMPR, 2011 EMPR and 2013 amendment;

Review of the 2015 EMP Performance Assessment;

Review of performance in relation to existing management commitments as

documented in the approved EMPRs and amendments;

Site inspection and general environmental audit; and

Creation of a new Action Plan for Nkomati Anthracite Mine

Nkomati Anthracite Mine (Nkomati Mine) is an operational mine located south east of

Komatipoort in the Mpumalanga Province. Nkomati Mine has an existing mining right and an

approved Management Programme (DMR Ref: MP 305/1/1/2/89MR) as well as an approved

EMP issued under Section 22 and 39 of the Mineral and Petroleum Resources Development

Act, 2002 (Act No. 28 of 2002) (MPRDA) to mine coal on portions of unsurveyed land in close

proximity to Madadeni, Sibange and eMangweni Communities.

Nkomati mine was placed on care and maintenance from May 2011 and operations only

resumed in March 2015. In 2010 the mine unlawfully undertook activities at the Madadeni

Opencast which required authorisation in terms of the National Environmental Management

Act (NEMA) listed activities. The mine lodged an application for rectification in terms of

section 24G of the NEMA and received retrospective authorisation in December 2013.

Nkomati Mine operates under an existing Water Use Licence (No.05/X13J/ACGIJ/1864) which

was issued on 24 October 2012 and amended on 13 February 2014, as well as an exemption

(27/2/2/X13J/049) authorising the disposal of dirty water into the Pollution Control Dam at

the Madadeni Opencast.

Since the mine resumed operations in March 2015, only the Madadeni Opencast has been

utilised for anthracite extraction. The underground operations are currently not in operation,

however the mine will be extracting ore from its underground workings in the near future.

Nkomati Anthracite Mine is currently in the EMP consolidation process which will consolidate


all existing EMPs into one document, resulting in one EMP for the entire Nkomati Anthracite

Mine. This will make the EMP more implementable and ensure that it can be easily audited.

NkomatiAnthraciteMine–PerformanceAssessment Page8

1.2 SiteLocality

Figure 1:1 1:60 000 Topographic Map of the mining area


Figure 1:2 Nkomati Anthracite Mine ‐ Mining Right Area


Figure 1:3 Nkomati Mine Overview


1.2.1 Underground Mining Area

The Underground Mine Workings is located North‐East of the processing plant on the East of

the Komati River.

Infrastructure:

Overburden stockpile;

Offices;

Change houses;

Workshop;

Septic tanks.


Figure 1:4 Underground Mine Area


1.2.2 Processing Plant and adjacent Old Opencast Area:

The Processing Plant includes the old opencast area.

Infrastructure:

Processing plant;

Product stockpile area;

Coarse discard;

Slurry settling ponds;

Slurry stockpile;

Sump;

Processing plant pollution control dams;

Fuel bunker;

Workshop;

Offices;

Old void 1;

Old void 2;

Rehabilitated area;

Explosives storage area.


Figure 1:5 Processing Plant and adjacent Old Opencast Area


1.2.3 Madadeni Opencast

The Madadeni Opencast Area consists of the following infrastructure:

Run of mine stockpile;

Topsoil stockpile;

Waste rock dump;

Existing clean water trench/river diversion;

Existing dirty water trench;

Madadeni pollution control dam.


Figure 1:6 Madadeni Opencast Area


1.3 StructuretothePerformanceAssessmentReport

This audit report has been structured as follows:

The EMP and licence conditions have been verified with the site conditions;

For each condition the applicability to the site has been indicated and colour coded;

For each condition of the Licence there is an observation as well as a

recommendation.

1.4 LegendtothePerformanceAssessment

The table below provides the colour used in the audit.

Table 1:1 Performance Assessment Colour Coding ‐ Compliance Status

Legend Colour Coding

Compliance with license condition

Non‐compliance with EMP Commitment. Management measures or strategies have been developed or are in the process of being developed, or there is some evidence of measures

being implemented.

Non‐compliance with EMP Commitment. No management measures or strategies are in place.

Non‐compliance. The EMP Commitment is no longer applicable to the site due to an activity change.

Non‐compliance. The EMP Commitment is of such a nature that it is impossible to implement and require a review.


2 APPLICABLELEGISLATION

Table 2.1 represent the applicable legislation that governs Nkomati Anthracite Mine.

Table 2:1 Applicable legislation governing Nkomati Anthracite Mine

Relevant Act Abbreviation

The Constitution of South Africa, 1996 (Act 108 of 1996)

The Minerals and Petroleum Resources Development Act (Act 28 of 2002) MPRDA

The National Environmental Management Act, 1998 (Act 107 of 1998) NEMA

The Environmental Conservation Act, 1989 (Act 73 of 1989) ECA

The Conservation of Agricultural Resources Act (Act 43 of 1983) CARA

The National Environmental Management: Biodiversity Act, 2004 (Act No. 10 of 2004) NEM:BA

The National Environmental Management: Protected Area Act (Act 57 of 2003) NEM:PAA

The National Environmental Management: Air Quality Act (Act 39 of 2004) NEM:AQA

The National Environmental Management: Waste Management Act (Act 59 of 2008) NHA

The National Water Act, 1998 (Act 25 of 1998) NWA

The Water Services Act, 1997 (Act 108 of 1007) WSA

The National Heritage Act, 1999 (Act 25 of 1999) NHA

The National Veld & Forest Act, 1998 (Act No 101 of 1998) NVFFA

The National Road Traffic Act, 1996 (Act 93 of 1996) NRTA

The Petroleum Products Act, 1977 (Act 120 of 1977) PPA

The National Nuclear Reactor Act, 1999 (Act 47 of 1999) NNRA

The Explosives Act, 2003 (Act 15 of 2003) EA

The Fencing Act, 1963 (Act 31 of 1963) FA

Fertilizers, Farm Feeds, Agricultural Remedies and Stock Remedies Act, 1974 (Act 36 of

1947)

FFARA

The Occupational Health & Safety Act, 1993 (Act 85 of 1993) OHSA

The Mine Health & Safety Act, 1996 (Act 29 of 1996) MHSA

The Consumer Protection Act, 2008 (Act 68 of 2008) CPA

The Second Hands Good Act, 2009 (Act 6 of 2009) SHGA


3 DOCUMENTREVIEWTable 3:1 Nkomati Mine Environmental Document Review

Document Approval Date Observations Recommendations

Mining Right 30 September 2010

Old order mining right: ML 4/1998

New order mining right: 30/5/1/2/2/89 MR o The mining right includes the following properties:

Grobler 479 JU, Guillaume 480 JU, Wildebeest 494 JU, Rusplek 495 JU, Sweet Home 496 JU, Bonnie Vale 497 JU, Excelsior 498 JU, Murray 502 JU, Fig Tree 503 JU and Beginsel 504 JU;

o A total mining area of 11812.4450 hectares has been authorised for mining by this mining right; o Expires 29 September 2020 – renewal application must be submitted to the Regional Manager not later than 60 working days before expiry of this right; o Operations at the entire Nkomati Mine should be conducted in accordance with the Mining Works Programme and an approved Environmental Management

Plan; o This mining right does not exempt Nkomati Mine from complying with the Mine Health and Safety Act, (Act N029 of 1996) and any other law in force in the

Republic of South Africa;

o The mining right was issued to Benicon Coal(Pty) Ltd 60% and Mpumalanga Economic Growth Agency 40%. The Mpumalanga Economic Growth Agency is no longer part of the mine.

Environmental Management Programme – Geovicon cc. Report No 522/2005

November 2005

The EMP includes Opencast Mining through lateral rollover technique, as well as underground mining by Bord and Pillar.

Surface infrastructure: o Haul Roads; o Access roads; o Electricity supply; o Topsoil overburden stockpiling at plant area; o Water management facilities; o Telephone lines; o Workshop; o Washing plant including a crushing and coal preparation plant; o Mine office and; o Substation

The EMP is very generic and no site layout plans is provided in the report. The report does not elaborate on the mining and plant area.

Implementation of the EMP is very difficult due to the fact that it is so generic in nature.

Nkomati Anthracite Mine has entered into the EMP Consolidation phase in order to have one document for the entire Nkomati Anthracite Mine. This is aligned to recommendations made in the 2015 EMP Performance Assessment.

Environmental Impact Assessment Report and Environmental Management Programme Amendment: Madadeni Opencast Project ‐ Geovicon

March 2011

The EIA / EMP process and report was compiled in order to obtain approval for the Madadeni Opencast Mine Operations

Surface infrastructure and activities: o Opencast pit; o Access roads; o Overburden stockpiles; o Run of mine stockpiles; o Pollution control dam; o Stormwater diversion structures; o Filling of final voids;

As with the 2005 EMP the report is very generic and no site layout plan is provided.

No EIA application was lodged so none of the activities were approved in terms of NEMA.

Section 24G Environmental Management Programme – GCS. Report No. 11‐375. DEA Ref: 12/12/20/2545

July 2012

The EIA / EMP process and report was compiled in order to obtain approval for the Section 24G application for the Madadeni Opencast Mine Operations. It is anticipated that this report replaced the 2011 EMPR that was never submitted to the appropriate authorities.

NEMA listed activities applied for: NR R. 386 Item 4 – The dredging, excavation, infilling, removal or moving of soil, sand or rock exceeding 5 cubic metres from a river, in‐stream dam,

floodplain or wetland. GN R.386 Item 12 – The transformation or removal of indigenous vegetation of 3 hectares or more of any size where the transformation or removal would

occur within a critically endangered or endangered ecosystem listed in terms of section 52 of the National Environmental Management Biodiversity Act, 2004 (Act No. 10 of 2004)

GNR. 386 Item 15 – The construction of a road that is wider than 4 metres or that has a reserve wider than 6 metres, excluding roads that fall within the ambit of another listed activity or which are access roads of less than 30 metres long.

GNR. 387 Item 1 – The construction of infrastructure, including associated structures or infrastructure, for any process or activity which requires a permit or licence in terms of legislation governing the generation or release of emissions, pollution, effluent or waste and which is not identified in Government Notice No R.386 of 2006 or including in the list of waste management activities published in terms of Section 19 of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2009) in which case the activity is to be excluded from the list.

The EMP includes Opencast Mining through lateral rollover technique, as well as underground mining by Bord and Pillar.

Section 24G 29 November 2013

The Section 24G authorisation approves the following activities at the Madadeni Opencast: NR R. 386 Item 4, 12 and 15 GNR. 387 Item 1


Document Approval Date Observations Recommendations

Water Use Licence (No. 05/X13J/ACGIJ/1864)

24 October 2012

The Water Use Licence (WUL) authorises the following activities across the Nkomati Mine:

Section 21(a) Taking water from borehole for drinking purposes Taking water from Madadeni opencast pit for reuse in the processing plant Taking water from underground working as make‐up water Taking water from defunct opencast pit as make‐up water

Section 21(c) and (i) Pipeline crossing on Nkomati River, transporting water from the underground mine to the processing plant Diverting the Madadeni drainage channel

Section 21(g) Disposing of dirty water found from underground into a return water dam Disposing of dirty water into a pollution control dam (south dam) Discard dumps Disposal of sewage into septic tanks and french drain Disposal of dirty water into a pollution control dam (north dam) Coal Stockpiling Dust suppression Stockpiling of Run of mine and product of the Madadeni Stockpile area Disposal of dry slurry into a dry slurry stockpiling area Disposal of slurry into slurry settling dam Disposal of dirty water into the discard dumps evaporation dam Backfilling of Madadeni opencast pit during mine closure Backfilling of old void pit 1 Backfilling of old void pit2

Section 21(j) Removing water found in underground working Taking water from Madadeni Opencast pit for reuse in the processing plant

A full external Water Use Licence audit was conducted in May 2015; the audit report addresses all the compliance and related matters with regards to the Nkomati Mine Water Use Licence.

Continual external Water Use License Audits have been conducted since the 2015 EMP Performance Assessment. These should continue into the future in order to ensure continued compliance.

GN 704 Exemption (No. 27/2/2/X13J/049)

25 October 2012 The GN 704 authorises the following activity at the Madadeni Opencast

o Disposal of dirty water into Madadeni pollutions control dam

The current pollution control dam at Madadeni is not constructed according to an approved civil engineering design.

The Mine has committed to upgrade the PCD in order to be constructed and operated in compliance with GN704.

Approval of Water Evaporation System by Inkomati Catchment Management Agency (Ref: 27/2/2/X13J/049)

14 November 2012

The activity is not considered to be a water use in terms of Section 21 of the National Water Act – ICMA issued this letter to give Nkomati Mine the go ahead with the activity.

Water Use Licence Amendment (No. 05/X13J/ACGIJ/1864)

13 February 2014 The amended Water Use Licence was issued in order to rectify certain activities that were incorrectly approved.

The amended Water Use Licence only contains the rectified activities and no other conditions. The amended licence should thus be read in conjunction with the original Water Use Licence.

Directive in terms of Section 19 of the NWA, 1998 by Inkomati Catchment Management Agency

24 June 2014 The directive was issued for a discharge from the Madadeni Opencast pit to the Mgobode drainage channel at a rate of 1200m3 per day for a maximum period of

three (3) months from 1 July 2014 to 30 September 2014.

The Madadeni opencast pit has been emptied in the specified timeframes and the activity and directive is no longer applicable.

Environmental Monitoring

Surface and groundwater monitoring o Surface water monitoring is conducted on a monthly basis and is aligned with the conditions of the approved WUL o Ground water monitoring is conducted on a quarterly basis and is aligned with the conditions of the approved WUL

Bio‐monitoring o Bio‐monitoring is conducted twice a year and is aligned with the conditions of the approved Water Use Licence

Dust monitoring o Dust buckets are installed onsite and dust fallout is monitored on a monthly basis.

Good monitoring practises have been in place and should continue.

Environmental Management Performance Assessments

June 2013 A legal compliance assessment was undertaken by Cabanga Concepts to determine whether Nkomati`s operations and practices were in compliance with

regulatory requirements, procedures, and accepted standards with regards to the environmental aspect of the operations. Reference: Cabanga Concepts, Nkomati Anthracite (PtyL Ltd Legal Compliance Assessment. June 2013.

Financial Liability Assessments & Guarantees

Rehabilitation Madadeni Rehabilitation Report. Nkomati Mine is in the process of updating the Madadeni Rehabilitation Report.

Nkomati Mine is in the process of developing a revised Rehabilitation Strategy Implementation Plan (RSIP) and Storm Water Management Plan (SWMP).


4 EMPMANAGEMENTCOMMITMENTSTable 4:1 2005 EMPR Commitments ‐ Processing Plant, Opencast Mining and Underground Mining

EMPR Aspect EMP EMPR Activity EMPR Impact EMPR mitigation Audit Comment Construction Phase – not applicable as construction at the processing plant is complete and mining has ceased in this area of the Nkomati Mine operations

Operational Phase

Topography 121 Stockpiles and open box cut

Stormwater runoff, visual impact

Ensure that stockpiles and discard dumps have minimum impact on topography.

The opencast mining area adjacent to the processing plant is partially rehabilitated and is not shaped to pre-mining relief. Discard stockpiles are on a rehabilitated are which means the area will have to be re-rehabilitated. Financial provision must be made for this prior to closure of the mine. A storm water management plan has been developed and should be adhered to.

Subsoil and hard overburden stockpiled to 7 meters. ROM stockpiles to always be limited in height to four days production material. Ensure that the removal of the coal seems have minimum impact on topography. The mine surveyor will survey opencast pit. Rehabilitation of the pit will be conducted concurrently with mining. Three cuts will be open at any given time with successive cuts used to systematically backfill preceding cuts, hence minimise the size of the void.

Final rehabilitation to be approximately one meter above ground level and shape to pre-mining relief.

Soil 122 Removal of top- and subsoil and general mining activities

Loss and pollution of top- and subsoil

Topsoil and subsoil removed from successive cuts will be used to backfill preceding cuts. Cuts will be filled with overburden material first, then subsoil and finally topsoil. This will minimise loss of soil and topsoil will be placed to a minimum depth of 300mm.

The opencast mining area adjacent to the processing plant is partially and is not shaped to pre-mining relief. The rehabilitated area to the far South of the offies has taken well and has good vegetation growth. However, discard has been dumped on the previously rehabilitated area to the South-West of the offices.

Rehabilitated workings will be seeded in accordance with identified suitable mixture. This will reduce loss of topsoil to wind and water erosion.

Maintain the topsoil stockpile to a height of four meters to reduce leaching. Ensure that re-vegetation of the stockpiles takes place. Ensure that the fertility of the soils used during rehabilitation is suitable for re-vegetation, if necessary addition of fertilizers will occur.

Ensure that diesel and oil spillages do not impact significantly on soils. Vehicles are being maintained under cover and on protected ground in the workshop area. The diesel filling station has storage tanks enclosed by a bunded area which will prevent major diesel spills. There is a small hole in the wall of the bunded area which needs to be addressed.

Vehicles will not be maintained on unprotected ground.

All oil and diesel fluid must be handled as per recommended oil/diesel spill remediation protocol.

Land Capability 123 Soil movement Reduction of Land

Capability and Land Use

Loss of topsoil will be minimised by filling the cuts with overburden, then subsoil and finally topsoil.

Discard has been dumped on the previously rehabilitated area to the South-West of the offices, resulting in a reduction of land capability and land use, as a well as a loss of natural vegetation. This means that fertile topsoil has been lost and the mine realises that the area will have to be rehabilitated again. Nkomati Mine has developed a Storm Water Management Plan

To ensure rehabilitated land retains its land capability, subsoil will be placed to a minimum depth of 3 meter and arable topsoil used to backfill preceding cuts will be placed to a minimum depth of 300mm.

The rehabilitated workings will be seeded with an appropriate seed mixture. To ensure that the rehabilitated areas are free draining.

Natural vegetation 123 Removal of soil Loss of natural vegetation

Backfill in accordance with a rehabilitation design plan to provide a free draining surface approximating pre-mining conditions.

Backfilled and rehabilitated workings will be seeded with an appropriate seed mixture. Vegetation cover inspection of rehabilitated land will be conducted. Replace overburden, subsoil and topsoil in correct order. Utilise a minimum of 7-meter soft overburden/subsoil to cover hard overburden. Cover with minimum 300mm topsoil.

Ensure that the rehabilitated area is always a maximum of three cuts behind the operating face thus minimising the disturbed area. The product from the opencast area adjacent to the processing plant has

been depleted and is no longer mined.

Surface Water

124 Surface water runoff from mining area

Impact on quantity and quality of surface water

Ensure that construction of storm water diversion trenches have the least possible impact on the surface water runoff patterns, and thus loss of MAR.

The process of reconstructing clean and dirty water trenches has begun. Construction of the said structures are done according to design specifications Stormwater diversion trenches/berms will separate clean and dirty water on the mine. Maintenance and monitoring of the said structures is done on a regular basis.

This condition is not applicable anymore as the product from the opencast area adjacent to the processing plant has been depleted and is no longer mined.

Ensure that the excavation of the initial boxcut has the least possible impact on the surface water runoff patterns, and thus loss of MAR within all catchments.

Development of a comprehensive mining layout plan. Construction of the initial box-cut as per mining layout plan. Stormwater diverted away from the initial box-cut.

125 Chemical leakage from machinery


Ensure that impacts from chemical leakages on surface water quality are minimised. Not all generators have been placed in drip trays yet. The mine must place all generators in drip trays to reduce impacts on water quality.

All filing of machinery will be conducted at the diesel tank area and servicing of all mine equipment will be done on designated areas. The mine follows good filling and servicing practises.

Dirty water from the diesel tank area will be channelled to the oil separator. The mine is in the process of implementing the Storm Water Management Plan.

Inspections will be conducted on the operation of the diesel tank and oil separator. Inspections have been conducted and a hole in the wall of the bunded area has been found.

Ensure that dirty water captured within the mine does not impact on surface water quality. The mine is in the process of implementing the Storm Water Management Plan.


EMPR Aspect EMP EMPR Activity EMPR Impact EMPR mitigation Audit Comment Any dirty water captured within the box-cut will be pumped to the return water dam for dust

suppression. Water from the final void is pumped to the processing plan’s PCD where it is used in the system.

The water quality monitoring program will be initiated.

Groundwater monitoring is underway and reports are submitted to the relevant authorities.

Surface and ground water monitoring points will be sampled.

Groundwater 127

Water from the mining area seeping into the underground water table

Impact on quantity and quality of groundwater

Ensure that impacts from lowering of groundwater levels during mining are minimised. The static groundwater levels in all boreholes in all boreholes within a distance of 2 kilometres must be measured on a quarterly basis.

Continuous monitoring of possible major structures of preferred groundwater flow during mining.

Any major structures of preferred groundwater flow such as dykes and fault zones should be grouted if excessive groundwater inflow is encountered.

In the event of an unacceptable decrease in the yield of any affected boreholes, alternative water supply will be supplied to the affected parties. Alternative water shall be supplied if needed.

Air quality 127 Dust from exposed area and fumes from mining machinery

Impact on local air quality

Ensure that impacts from dust and diesel fumes generated by machinery on local air quality is minimised.

Machinery is regularly serviced to ensure most efficient functionality of machinery. All machinery employed on site will be in good repair, and well maintained.

All machinery will be fitted with the correct exhaust systems, which will be maintained and in good repair.

All trucks transporting material from the exposed mining operation will be required to obey a maximum 40km/h speed limit. This will reduce the generation of dust on the haul roads.

Dust bucket fall-out monitoring is conducted monthly. Numerous dusty buckets have been noted on site. Dust suppression is regularly carried out on all gravel roads around the mining area.

Ensure that impacts from dust generated by blowing wind on local air quality is minimised. Dust suppression will be undertaken during the operational phase on haul roads and stockpiling areas where movement of machinery may generate dust.

Water for dust suppression purposes will be obtained from the evaporation dam.

The rehabilitated workings will be seeded with a recommended seed mix. Some areas have been rehabilitated and vegetation has been established. However, other rehabilitated areas have been poorly managed. The mine has been made aware of this and are investigating remedial action.

Use dust asides for dust suppression on gravel roads outside the mine property. Dust suppression is carried out in an effective manner.

Ensure that impacts from dust generated by blasting on local air quality is minimised. Blasting is conducted in line with these conditions. Blasting holes will be stemmed prior to blasting.

Use minimum amount of explosives.

Noise and Vibrations 129

Noise from blasting and mining machinery

Exposure to noise and damage to surrounding infrastructure due to vibrations

Ensure operators will be issued with earplugs, and instructed how to use them. Operators have been issued with earplugs. Areas with high noise levels have clear signage stating that earplugs should be used. Machine operators will be issued with earplugs, and instructed how to use them.

Ensure impacts from noise generated during blasting are minimised.

Blasting is conducted in line with these conditions.

All residence and structures within a 1km radius of the proposed mining operation will be surveyed and a photographic record of these taken to determine a pre-mining condition.

All such structures will continuously be inspected for signs of any damage. Mine management will repair any damage, which arises as a result of blasting or activities at the mine, at the mine’s expense.

All interested and Affected Parties identified during the Interested and Affected Party survey will be notified within one (1) hour prior to blasting.

The blaster employed, who will be certified in terms of the Mine Safety Act, will utilise the minimum possible explosives to achieve maximum affect.

Blasting will be conducted between the hours of 06h00 and 18h00 to minimise the impact on persons dwelling within close proximity to the mine.

Visual aspects 130 Overall mining scar impacting aesthetic of the area

Impact on aesthetics

Ensure that visual impacts from dust generated during blasting is minimised. Blasting holes will be stemmed. Ensure that dust generated by wind and movement of machinery is minimised.

Dust suppression is carried out regularly. Dust suppression will be conducted on all haul roads and stockpiling areas where movement of machinery takes place.

The rehabilitated workings will be seeded with the seed mix recommended in this document. Some areas have been rehabilitated and vegetation has been established. However, other rehabilitated areas have been poorly managed. The mine has been made aware of this and are investigating remedial action

All trucks transporting material on the proposed mining area will be required to obey a maximum of 40 km/h speed limit. A maximum speed limit is enforced in line with this condition.

The mine will adopt a clean-house policy. All stockpiles will be maintained at specified heights to reduce visual impact. Stockpiles are managed in line with this condition.

Ensure that visual impacts from any mine infrastructure minimised. Impacts have been kept to a minimum. Maintenance of topsoil/subsoil visual constructed around visible areas of the mine. Noted.


EMPR Aspect EMP EMPR Activity EMPR Impact EMPR mitigation Audit Comment

Interested and affected parties

131 Overall mining activity

Impacts on interested and affected parties

Adjacent landowners within 2km radius, which show decreased borehole yields resulting from this mining venture, will be compensated for the drilling of the new/additional boreholes to replace/supplement existing boreholes.

The mine enforces these conditions. The property is fenced and has security for access control.

No squatters will be allowed on the property. Mine management will maintain an open-door policy with all Interested and Affected Parties. Minutes of all meetings will be kept, and made available on request. Community meetings are held and minutes kept for records.

Subsidence Management Underground mining Underground pillar failure

Ensure that pillar failure does not re-occur.

The underground mine workings are currently not in use. The mine intends to re-open the underground workings

Remaining underground pillars will be monitored regularly, for signs of failure and for compliance with required safety factor.

Any pillar failure will be reported to Mine Manager immediately.

Recommendation on required safety factor to avoid re-occurrence of pillar failure requested.

Ensure that the surfaces with subsidence, if any, caused by pillar failure rehabilitated accordingly.

A surveyor will survey the surface that is undermined. Monitoring of the undermined surfaces will be undertaken. In the case of subsidence, topsoil on affected area will be stripped to a minimum depth of 300mm over the affected area.

The affected area will be shaped to be free draining. The removed topsoil will be replaced over the area (minimum thickness 300mm).

Ensure that any fractures that promulgate after settlement has occurred are managed properly.

Fractures will be excavated to a minimum depth of 1.6 meters (stockpiling the upper 300mm topsoil separately).

Fractures will be backfilled using 150mm compacted layers to a minimum thickness of 0.6 meters (Compaction to 93% MOD AASHTO).

Backfilled areas will be backfilled to 300mm below surface level. Finally covered and shaped to conform to the surface surrounding using a minimum 300mm layer of topsoil.

Ensure that the areas with surface water ponding are managed properly.

Conduct a visual monitoring of areas being undermined and that have already been undermined.

Areas with surface water ponding identified and reshaped to free draining topography as described in the above action plan.

Areas reshaped checked for cracks and fractures and if fractures or cracks noticed above-mentioned action plan for fractures will be applied.

Ensure that the areas showing soil erosion are managed properly. Visual monitoring of areas being undermined, areas that have already been undermined conducted and areas rehabilitated as mentioned in the above action plan.

Areas showing signs of soil erosion identified and reshaped to free draining topography as described in the above action plan for surface subsidence and surface fractures.

Ensure that reshaping and backfilling of fractures, surface subsidence, soil erosion and water ponding close not have detrimental impact on natural vegetation.

Visual monitoring of the backfilled and reshaped areas re-establishment of natural vegetation.

In consultation with the land owners the affected areas will be revegetated with appropriate vegetation species.


Table 4:2 2005 EMPR Commitments – Opencast Mining adjacent to the Processing Plant

EMPR Aspect EMP EMPR Activity EMPR Impact EMPR mitigation Audit Comment Decommissioning Phase

Topography 121 Stockpiles and open box cut

Visual impact Final rehabilitation to be approximately one meter above ground level and shape to pre-mining relief

Whilst some areas at the processing plant have been appropriately rehabilitated, there is a rehabilitated area to the South-West of the offices that has been used to dump discard. The mine is in the process of implementing the Storm Water Management Plan and investigating remedial action for the discard area.

Soil 122 Rehabilitation of the mining area

Contamination of surface and groundwater, visual impact.

Topsoil and subsoil removed from successive cuts will be used to backfill preceding cuts. Cuts will be filled with overburden material first, then subsoil and finally topsoil. This will minimise loss of soil and topsoil will be placed to a minimum depth of 300mm.

Rehabilitated workings will be seeded in accordance with identified suitable mixture. This will reduce loss of topsoil to wind and water erosion.

Ensure that the fertility of the soils used during rehabilitation is suitable for re-vegetation, if necessary addition of fertilizers will occur.

Land Capability and Land Use

123 Soil movement Reduction of Land Capability and Land Use

Loss of topsoil will be minimised by filling the cuts with overburden, then subsoil and finally topsoil.

To ensure rehabilitated land retains its land capability, subsoil will be placed to a minimum depth of 3 meter and arable topsoil used to backfill preceding cuts will be placed to a minimum depth of 300mm.

The rehabilitated workings will be seeded with an appropriate seed mixture. To ensure that the rehabilitated areas are free draining.

Natural Vegetation

123 Removal of soil Impact of soil removal on natural vegetation

Backfill in accordance with a rehabilitation design plan to provide a free draining surface approximating pre-mining conditions.

Backfilled and rehabilitated workings will be seeded with an appropriate seed mixture. Vegetation cover inspection of rehabilitated land will be conducted. Replace overburden, subsoil and topsoil in correct order. Utilise a minimum of 7-meter soft overburden/subsoil to cover hard overburden. Cover with minimum 300mm topsoil.

Surface Water 124 Surface water runoff from mining area


Ensure that construction of storm water diversion trenches have the least possible impact on the surface water runoff patterns, and thus loss of MAR.

Construction of the said structures are done according to design specifications. Stormwater diversion trenches/berms will separate clean and dirty water on the mine.

Groundwater 127

Water from the mining area seeping into the underground water table

Impact on quantity and quality of groundwater

The static groundwater levels in all boreholes within a distance of 2 kilometres must be measured on a quarterly basis.

Groundwater monitoring is underway and reports are submitted to the relevant authorities. In the event of an unacceptable decrease in the yield of any affected boreholes, alternative water

supply will be supplied to the affected parties.

Air quality 127 Dust generated by blowing wind

Impact on local air quality

All machinery employed during re-shaping and rehabilitation will be in good repair and fitted with the correct exhaust systems.

All machinery is serviced at the workshop and well maintained.

The rehabilitated workings will be seeded with a recommended seed mix.

Visual aspects 130 Overall mining scar impacting aesthetic of the area

Impact on aesthetics The rehabilitated workings will be seeded with the seed mix recommended in this document.

Whilst some areas at the processing plant have been appropriately rehabilitated, there is a rehabilitated area to the South-West of the offices that has been used to dump discard. The mine is in the process of implementing the Storm Water Management Plan and investigating remedial action for the discard area.

Interested and affected parties

131 Overall mining activity

Impacts on interested and affected parties

Adjacent landowners within 2km radius, which show decreased borehole yields resulting from this mining venture, will be compensated for the drilling of the new/additional boreholes to replace/supplement existing boreholes.

The mine enforces these conditions. The property is fenced and has security for access control.

No squatters will be allowed on the property.

Mine management will maintain an open-door policy with all Interested and Affected Parties. Minutes of all meetings will be kept, and made available on request.

Community meetings are held and minutes kept for records.


Table 4:3 2012 EMPR Commitments – Madadeni Opencast Pit

EMPR Aspect EMP EMPR Activity EMPR Impact Action Plan - Commitment Audit Comment Operational Phase Activity 1: Linear Infrastructure

Geology 78

Removal of coal by opencast mining

Disturbance of the geological profile The Mine Surveyor will survey the opencast pit areas. This will ensure that the operation does not encroach into the sensitive areas that mining is conducted within the demarcated areas.

A survey was conducted at the Opencast area in 2015. An updated survey was conducted in 2016.

78 Stripping of topsoil Result in the current possible land use to cease completely

Topography

78 Stockpiling of R.O.M Activity may result in the formation of a topographical highpoint

The mine manager will ensure that the movement of soil is conducted according to the action plan. This will be done to ensure that the mine, as far as possible reinstate the area to its pre-mining land use. A soil specialist was used to determine a soil utilisation guide for the stripping of removed soil.

Mining is conducted according to an approved mine plan.

79 Formation of voids Alterations of the local topographical patterns within the immediate mining area

Rehabilitation of the pit will be conducted concurrently with mining. Only three cuts for each mining area will be open at any given time with successive cuts used to systematically backfill preceding cuts. This will minimise the size of the voids. This will also ensure that the rehabilitation progress is measured on a regular basis.

A rehabilitation and stormwater management plan has just been completed and the mine is in the process of implementing it.

Geohydrology 79

Dewatering of the aquifer

Impacts of groundwater quantity Groundwater levels should be monitored on a quarterly basis Groundwater monitoring is underway and reports are submitted to the relevant authorities.

79 Groundwater pollution

Impacts on groundwater quality Groundwater quality should be monitored on a quarterly basis

Hydrology

80 Formation of a void Loss of MAR within the Komati River sub catchment, which will result in loss of catchment yield

Design stormwater diversion trenches to separate clean and dirty water on the mine

Significance maintenance work has been done on the river diversion to allow the diversion to cope with a normal rainy season. A stormwater management plan has been completed and the mine is in the process of implementing this plan.

80 Runoff from upslope area at Madadeni

Runoff may enter the rehabilitated area giving rise to increased siltation which in turns runoff into the environment.

Stormwater diverted away from the initial box cuts by means of a diversion berm or trench on the upslope of the initial box cuts.

A rehabilitation and stormwater management plan has just been completed and the mine is in the process of implementing it.

80 Water captured within the opencast pit

Quality of water may be poor and will pollute the environment if allowed to enter the natural environment

All dirty water captured in the opencast will as soon as possible be pumped into the pollution control dam (designed according to DWS specifications).

A rehabilitation and stormwater management plan has just been completed and the mine is in the process of implementing it. This will feed into the water balance to dictate the size of the dam. Suitable locations for this dam have been investigated and designs have commenced.

80 Spillages onsite and access roads

Pollution of surface water Ensure optimal operation and maintenance of clean and dirty water system and ensure that erosion control measures are in place.

Significance maintenance work has been done on the river diversion to allow the diversion to cope with a normal rainy season. A stormwater management plan has been completed and the mine is in the process of implementing this plan.

Soil, land use and land capability

80 Stripping and stockpiling of topsoil

Loss of original spatial distribution of soil types and natural horizon sequences, loss of original fertility, loss of original soil depth, loss of natural functioning of soil, compaction of soil during replacing.

Soil movement and stockpiling must be undertaken as per the soil utilisation guide detailed in the soil report.

Topsoil has been stored in stockpile areas. Discard has been dumped on rehabilitated areas and as such this topsoil has been lost.

81 Removal of topsoil layer

Loss of vegetation cover Soil movement and stockpiling must be undertaken as per the soil utilisation guide detailed in the soil report.

Topsoil is stored in dedicated topsoil stockpile areas. Soil report formed part of the EIA/EMP.


Original land capability classified as arable to cease completely until rehabilitation take place

The mine manager will ensure that the movement of soil is conducted according to the action plan. This will be done to ensure that the mine, as far as possible reinstate the area to its pre-mining land use. A soil specialist was used to determine a soil utilisation guide for the stripping and stockpiling of removed soils

81 Transportation Soil physical and chemical degradation as a result of spillages during operations

A detailed waste management strategy will be established and implemented. Waste should be removed by a licenced waste disposal company.

Waste is removed by a licensed waste disposal company, aligned to a waste collection schedule. This should be formalised into a waste management strategy.

82 Spillage of dirty water from pipeline breakage

Loss of resource Stormwater control measures, bunding of footprint and containment of dirty water and accidental spills. Protocol in place to manage accidental breaks

Pipeline has not been constructed yet.

82 Erosion due to water spillage from pipeline

Loss of soil Minimisation of area potential impact. Bunding, berms and trenching as part of stormwater management – minimise dirty water area


EMPR Aspect EMP EMPR Activity EMPR Impact Action Plan - Commitment Audit Comment

Wetlands

82 Construction and operational procedures

Surface water emanating from the construction site may result in the pollution of the receiving environment including the nearby wetlands and its aquatic ecosystem.

The mine infrastructure i.e. dirty water dam, diversion trenches, will be constructed in a manner that will reduce chances of contamination of the surface water with mine affected water. The mine manager will ensure that these structures are maintained and checked after flood events. If it is found that a watercourse or wetland will be mined a water use licence application will be submitted for authorisation of the activities.

The Madadeni river diversion has recently undergone major maintenance to ensure functionality. A stormwater management plan has been developed and the mine is in the process of implementation.


This activity will result in the original land capability classified as temporary to cease completely until rehabilitation takes place

Soil movement and stockpiling must be undertaken as per the soil utilisation guide detailed in the soil report.

Topsoil is stored in dedicated topsoil stockpile areas. Soil report formed part of the EIA/EMP.

83 Blasting of the overburden and coal seams

Generation of dust may silt and impact surrounding wetlands

In the event that dust issues are identified by employees or other stakeholders, an independent specialist should be appointed to determine the best course of action to ameliorate the situation, which Nkomati will implement.

Dust monitoring is carried out on a monthly basis. Dust suppression regularly carried out to reduce dust issues.

84 Operation of Madadeni opencast

A wetland intersects the mining operation resulting in the disconnection of all hydrological longitudinal processes that took place from the upstream to downstream section of the wetland. The river continuum is interrupted and the longitudinal connectivity is blocked. This can lead to the desiccation of the downstream section of the wetland. The barrier across the water course will obstruct the free migration of fish both upstream and downstream, many of these migrations are essential for the breeding of species.

If any encroachment of wetlands does take place, or within the boundaries of water resource a water use licence will be required from DWS under Section 21 of the National Water Act (Act 36 of 1998)

This condition has been noted and adhered to. Nkomati has a WUL (No: 05/X13J/ACGIJ/1864) to conduct current activities at Madadeni. Any new activities within a wetland will trigger a new WULA.

84 Damming up water upstream of the mining operation

The habitat required by specialised wetland dependent species is frequently lost when a wetland is dammed.

If any encroachment of wetlands does take place, or within the boundaries of water resource, a Water Use Licence will be required from DWS under Section 21 of the National Water Act (Act 36 of 1998).

Nkomati Mine has a WUL (No: 05/X13J/ACGIJ/1864) to conduct current activities at Madadeni. Any new activities within a wetland will trigger a new WULA.

Fauna and Flora

85 Disruption of soil profile and vegetation cover

Loss of animal burrows/microhabitats and migration of animals may occur.

All construction activities must be limited to the footprint of the opencast/adit and surface infrastructure areas. All activities on site must comply with the relevant animal protection legislation. The environmental awareness plan must be implemented to make employees aware of the danger mining can have on animal life within and around the mine.

Mining activities are constructed according to an approved mining plan.

85 Increased vehicular activity

Increase in animal fatalities due to collisions Conduct regular induction and awareness training for workers Training is provided to contractors and new employees.

85 Disturbance and noise

Avifauna: Displacement of taxa Operational activities will be limited to daytime periods only Mining activities occur 24 hours a day at the Madadeni Opencast and processing plant.

Air Quality 85 Overall mining activities

During the transportation and stockpiling of the R.O.M coal, machinery movement and wind blowing over exposed surfaces, the coal loaded on the vehicles will generated diesel fumes and dust. These air particles will during windy days form dust clouds and migrate towards the prominent wind direction, which will eventually settle on nearby vegetation and surrounding area.


Monthly dust bucket fall-out monitoring is conducted on site, and the presence of dust buckets was noted. Dust suppression is regularly carried out.

Noise

86 Operation of the opencast mine workings

Noise levels may continuously be in excess of 85dB

Environmental noise measurements should be conducted by an independent Noise Consultant during six months of operation, thereafter annually. Noise levels will be reduced by maintaining all machinery in a good condition. Mine machinery will be installed with mufflers for the reduction of noise generation

Noise levels have been measured in December of 2016. The mine should continue to monitor noise levels on an annual basis.

86 Blasting Noise levels may exceed 130dBA Environmental noise measurements should be conducted by an independent Noise Consultant during the first six months of operation, thereafter annually.

Traffic 86 Coal transportation Fugitive dust emissions from coal transportation have a negative air quality impact

Ensure optimal implementation and maintenance of the dust suppression programme and monitoring programme The road surface to be maintained on a weekly basis

Dust suppression is regularly carried out on all gravel roads in and around the mining area. Monthly dust bucket fall-out monitoring is conducted.



87 Transportation Vehicle safety (access spacing, road alignment, speed differential, lighting)

Inspect that lighting fixtures are in working order, and replace when necessary

This is conducted as part of the safety measures implemented on site.

Visual 87 Transportation Fugitive dust emissions from coal transportation have a negative air quality impact

Ensure optimal implementation and maintenance of the dust suppression programme and monitoring programme

Dust suppression is regularly carried out on all gravel roads in and around the mining area.

Social

87 Coal transportation Risks to pedestrian safety Implement strict penalty system for speeding incidents This is conducted as part of the safety measures implemented on site.

87 Nuisance Disruption and nuisance factors associated with the actual project such as noise, visual and traffic related impacts

The community forum established during the construction phase and implemented throughout the operational phase of Nkomati should continue.

Nkomati Mine has a good relationship with the community, tribal structures and royal houses. The mine has regular meetings with the chiefs from the surrounding communities.

88 Operation of Madadeni opencast workings

The proposed project will create much needed employment opportunities, which will be enhanced by employing unemployed members of the local communities. Capital and operating expenditure on the proposed mine will benefit the local economy. Further to the above, through the Social and labour Plan the mine will continue developing its employees and will continue with the benefit the community will receive from the current and proposed project

Employment opportunities are given to members of local communities. The mine has an SLP which is implemented.

88 Operation of Madadeni opencast workings

Potential socio-economic impacts of the proposed project include threat of increase in crime and petty theft and poaching, especially if the employees reside on site

The mine will as far as possible utilise people from the surrounding area to minimise the influx of illegal labourers. No squatters will be allowed on the property. The mine will in liaison with the adjacent landowners help with the adjacent properties.

Employment opportunities are given to members of surrounding local communities. There are no squatters on the property. The mine has regular meetings with the chiefs from surrounding communities in which property needs are discussed amongst

Heritage 89 Operation of Madadeni opencast workings

Seven sites of cultural heritage significance were located onsite

An archaeologist should be in site to supervise work in this area and handle the situation. The archaeologist should act according to legislation, taking into account the development and plans for the area at that stage as well as the information that can be obtained once the graves can be seen.

An archaeologist is consulted when work is conducted in areas of archaeological importance.

Operational Phase Activity 2: Control of Clean and Dirty Water Separation Infrastructure

Geology 89 Removal of coal by opencast mining

Disturbance of geological layers The mine surveyor will survey the opencast pit areas. This will ensure that the operation does not encroach into the sensitive areas and that mining is conducted within the demarcated areas.

A survey was conducted on the Madadeni Opencast Pit area in 2016.

Geohydrology 89 Pollution Control Dam

Poor quality seepage may occur into the underlying strata if the PCD is situated on permeable soil formation or on an underground flow path.

Pollution control dams will be inspected regularly to monitored and mitigate the possibility of seepage. Dam levels will be kept at the required levels (GN 704) Surface water monitoring and groundwater programme must be maintained.

The current PCD at Madadeni is not constructed to approved civil designs. The mine is in the process of planning upgrades to this facility as well as to the Slurry Settling Dam/PCD (one facility) at the processing plant. A stormwater management plan has been developed and the mine is in the process of implementation. This will feed into the water balance and indicate the dimensions of the upgraded PCD.

Hydrology

90 Operation of opencast mine workings

Under extreme flood conditions the stormwater may enter the opencast pits resulting in the injury or loss of life to personnel working in the pits, damage to the equipment and in the contamination of clean stormwater

Water quality sampling will be undertaken on a monthly basis and analysed according to the monitoring programme

The commitment to monitoring will not prevent stormwater from entering the pit. Recent maintenance work to the river diversion was conducted in order to prevent water from entering the pit.

90 Clean and dirty water separation infrastructure

Stream flow reduction

Water quality sampling will be undertaken on a monthly basis and analysed according to monitoring programme. Quarterly surface and groundwater monitoring reports will be generated by the mine or through a water quality specialist. In the event that water quality or quantity issues are identified based on the monitoring programme, an independent specialist should be appointed to determine the best course of action to ameliorate the situation which Nkomati will implement. A dynamic water and salt balance will be drawn up by the mine prior to commencing with operational activities.

Monitoring is conducted according to this commitment. The mine is in the process of reworking the water and salt balance.

Soil, Land Use and Land Capability

91 Clean and dirty water separation infrastructure

Stream flow reduction Optimum operation and maintenance of control measures will be conducted to ensure proper flow of clean water from the site

The current PCD at Madadeni is unlined and not constructed according to an approved civil design. A civil design engineer has been appointed to design a new formalised river diversion.



91 Soil stockpile

Loss of resource due to contamination of stored soils by dirty water. Erosion of soils and loss of resource due to spillage of water system

Restrict area of footprint and contain dirty water – stormwater control and cover soil stockpiles

A stormwater management plan has been created and the Mine is in the process of implementation. This will feed into the water balance which will indicate the requirements for the upgrades of the dam.

Fauna and Flora

91 Clean and dirty water separation structures

Peripheral impact relating to human presence and mining related activity will lead to changes in vegetation dynamics and alteration of natural ecological processes and ecosystem functioning

Conduct regular inspection onsite fenced off areas. Implement a strict penalty system for poaching, hunting, killing or trapping incidents

Regular inspections are conducted on fenced off areas. There have been no hunting incidents.


Flora: loss or degradation of natural/pristine habitat

Ensure optimal operation of all infrastructure and proper maintenance and management of clean and dirty water separation system and the erosion control measures.

The mine has conducted major maintenance work on the river diversion and are in the process of upgrading the PCD’s (Processing Plant and Madadeni Opencast).


Flora: loss or disruption of ecological connectivity Conduct regular inspections on the fenced off area Regular inspections are conducted on fenced off areas.


Fauna: Direct Impacts on Red Data Fauna Species Ensure optimal operation of all infrastructure and proper maintenance and management of clean and dirty water separation system and the erosion control measures

A storm water management plan has been developed and the mine is in the process of implementation.


Fauna: Degradation of sensitive faunal habitat in surrounding areas

Conduct regular inspections on the fenced off areas Regular inspections are conducted on fenced off areas.


Fauna: Disruption of ecological connectivity and migration routes

Implement a strict penalty fine system for rule breaking A storm water management plan has been developed and the mine is in the process of implementation.


Fauna: Direct impacts on common fauna species and interactions with structures and personnel

Implement a strict penalty fine system for rule breaking

Wetlands


Surface water emanating from the construction site may result in the pollution of the receiving water environment including the nearby wetlands and its aquatic ecosystem. The pollution may be in the form of silt and hydrocarbons

The mine infrastructure i.e. dirty water dam, diversion trenches, will be constructed in a manner that will reduce chances of contamination of the surface water with mine affected water. The mine manager will ensure that these structures are maintained and checked after flood events. If it is found that a watercourse or wetland will be mined a water use licence application will be submitted for authorisation of the activities

A storm water management plan has been developed and the mine is in the process of implementation. The mine has conducted extensive maintenance on the river diversion and is in the process of upgrading the PCD at the processing plant and the PCD at Madadeni Opencast.


Stripping and stockpiling of topsoil will result in the original temporary wetland to cease until rehabilitation takes place

Soil movement and stockpiling must be undertaken as per the soil utilisation guide detailed in the soil report

Topsoil is stored in dedicated topsoil stockpile areas. Soil Report formed part of the EIA/EMP.


Blasting of the overburden and coal seams will result in the generation of dust, which will migrate towards the prevailing wind direction. The dust will also settle on the surrounding vegetation cover. This dust cloud may impact on the surrounding area


Dust bucket fall-out monitoring is conducted on a monthly basis and will indicate rise in dust levels in around the mine.


A wetland intersects the mining operation resulting in the disconnection of all hydrological longitudinal processes that took place from the upstream to downstream section of the wetland. The river continuum is interrupted and the longitudinal connectivity is blocked. This can lead to the desiccation of the downstream section of the wetland. The barrier across the water course will obstruct the free migration of fish both upstream and downstream, many of these migrations are essential for the breeding of species.

If any encroachment of wetlands does take place, or within the boundaries of water resource a water use licence will be required from DWS under Section 21 of the National Water Act (Act 36 of 1998)

Nkomati Mine has been issued with a WUL (No: 05/X13J/ACGIJ/1864) to conduct the current activities at Madadeni. Any new activities within a wetland will trigger a new WUL application.

94 Damming op water upstream of the mining operation

The habitat required by specialised wetland dependent species is frequently lost when a wetland is dammed.

If any encroachment of wetlands does take place, or within the boundaries of water resource, a Water Use Licence will be required from DWS under Section 21 of the National Water Act (Act 36 of 1998).

Social 94 Overall mining activities

Possibility of decreasing water quality or quantity Ongoing surface and groundwater monitoring programme will be maintained.

Surface and groundwater monitoring is conducted and reports submitted to the relevant authorities.


EMPR Aspect EMP EMPR Activity EMPR Impact Action Plan - Commitment Audit Comment Operational Phase Activity 3: Generation and Handling of Waste

Geohydrology 95 Waste generation Groundwater contamination

Water quality sampling will be undertaken on a monthly basis and analysed according to the monitoring programme Quarterly groundwater monitoring reports will be generated by the mine or through a water quality specialist In the event that water quality or quantity issues are identified based on the monitoring programme, an independent specialist should be appointed to determine the best course of action to ameliorate the situation, which Nkomati will implement

Groundwater monitoring is conducted in line with the commitment and reports are submitted to the relevant authorities.

Hydrology

96 Waste generation Surface water contamination

Water quality sampling will be undertaken on a monthly basis and analysed according to the monitoring programme. Quarterly surface monitoring reports will be generated by the mine or through a water quality specialist. In the event that water quality or quantity issues are identified based on the monitoring programme, an independent specialist should be appointed to determine the best course of action to ameliorate the situation, which Nkomati will implement.

Surface water monitoring is conducted in line with the commitment and reports are submitted to the relevant authorities.

96 Disposal and any type of waste to an area with a waste skip

Dirty water runoff from waste facilities

The mine will adopt a cradle to grave approach to ensure that the waste is removed and disposed of in a prescribed and correct manner, and must be stored in a designated area as part of the waste management strategy. Waste generated will be collected and disposed of in a licenced waste facility and a copy of the valid waste disposal permits will be kept on site.

No waste is disposed or stored at the Madadeni opencast mine. All waste is sorted and stored in separate skips at the processing plant area and collected and disposed of at a licenced waste facility.

Soil, Land Use and Land Capability

96 Waste generation Soil contamination

Water quality sampling will be undertaken on a monthly basis and analysed according to the monitoring programme. Quarterly surface and groundwater monitoring reports will be generated by the mine or through a water quality specialist. In the event that water quality or quantity issues are identified based on the monitoring programme, an independent specialist should be appointed to determine the best course of action to ameliorate the situation which Nkomati will implement. A dynamic water and salt balance will be drawn up by the mine prior to commencing with operational activities.

Surface and ground water monitoring is conducted in line with the commitment and reports are submitted to the relevant authorities. The mine is in the process of finalising a water balance.

97 Waste storage footprint

Loss of resource due to spillage of brine waste Containment. Berms, liners and stormwater control. The mine is in the process of upgrading the PCDs at both the processing plant and the Madadeni Opencast area. The mine has developed a stormwater management plan and are in the process of implementation.

Fauna and Flora

97

Peripheral impact relating to human presence and mining related activity

Changes in vegetation dynamics and alteration to natural ecosystem and ecosystem functioning

Waste management will form a detailed component as part of the induction process provided by the mine and good housekeeping practices will be in place.

Induction training is provided to all new employees entering the mine.

97 Generation and handling of waste

Flora: loss or degradation of natural/pristine habitat

Waste generated will be collected and disposed of in a licenced waste facility

No waste is disposed or stored at the Madadeni opencast mine. All waste is stored at the processing plant area and collected and disposed of at a licenced waste facility.


Flora: loss/degradation of surrounding habitat, species

Implement a strict penalty fine breaking system for rule breaking


Flora: increase in local and regional fragmentation / isolation of habitat

Implement a strict penalty fine breaking system for rule breaking


Fauna: degradation of sensitive faunal habitat surrounding areas

Waste management will form a detailed component as part of the induction process provided by the mine and good housekeeping practices will be in place.

Induction training is provided to all new employees entering the mine.


Fauna: disruption of ecological connectivity and migration routes

Waste generated will be collected and disposed of in a licenced waste facility

No waste is disposed or stored at the Madadeni opencast mine. All waste is stored at the processing plant area and collected and disposed of at a licenced waste facility.


Fauna: direct impacts on common fauna species and interaction with structures and personnel

Implement a strict penalty fine breaking system for rule breaking Some waste is covered whilst waste in other areas is left exposed. A marked improvement has been noted in waste handling methods and the mine is working towards optimum waste handling. 98

Generation and handling of waste

Avifauna: Changes to community structure Remove waste immediately. Prohibit the storage of waste and cover waste.



Wetlands 98 Waste storage Deterioration in water quality

Waste management will form a detailed component as part of the induction process provided by the mine and good housekeeping practices will be in place. Hazardous waste generated will be stored in a bunded area and be collected and disposed of in a licenced waste facility.

Noise 98 Diesel emergency generators

Final position to be determined and evaluated by Environmental Acoustic Consultant

Final position to be determined and evaluated by Environmental Acoustic Consultant

The emergency generator is located at the processing plant.

Social

98 Waste generation Surface water and soil contamination

Water quality sampling will be undertaken on a monthly basis and analysed according to the monitoring programme. Quarterly surface and groundwater monitoring reports will be generated by the mine or through a water quality specialist. In the event that water quality or quantity issues are identified based on the monitoring programme, an independent specialist should be appointed to determine the best course of action to ameliorate the situation.

Surface and ground water monitoring is conducted in line with this commitment and reports are submitted to the relevant authorities.

98 Disruption and nuisance factors

Noise, visual and traffic related impacts

The community forum established during the construction phase and implemented throughout the operational phase of Nkomati should continue through which issues can be addressed, and a representative from Nkomati should become involved.

The mine has a good working relationship with the chiefs from surrounding communities and they meet on a regular basis.


Table 4:4 Post Closure

EMPR Aspect EMP EMPR Activity EMPR Impact Action Plan Audit Comment

Post Closure Phase Activity 1: Generation and Handling of Waste

Geohydrology 101 Waste generation Groundwater contamination

Water quality sampling will be undertaken on a monthly basis and analysed

according to the monitoring programme.

Quarterly surface and groundwater monitoring reports will be generated by the

mine or through a water quality specialist.

In the event that water quality or quantity issues are identified based on the

monitoring programme, an independent specialist should be appointed to

determine the best course of action to ameliorate the situation.

Surface and ground water monitoring is conducted in line with this action plan and reports are submitted to the relevant authorities. This will continue through the closure phase.

Hydrology

101 Waste generation Surface water contamination








101

Disposal and any type

of waste to an area

with a waste skip

Dirty water runoff from waste facilities

The mine will adopt a cradle to grave approach to ensure that the waste is

removed and disposed of in a prescribed and correct manner, and must be stored

in a designated area as part of the waste management strategy.

Waste generated will be collected and disposed of in a licenced waste facility and

a copy of the valid waste disposal permits will be kept on site.

No waste is disposed or stored at the Madadeni opencast mine. All waste is stored

at the processing plant area and collected and disposed of at a licenced waste

facility.

Soil, Land Use

and Land

Capability

101 Waste generation Soil contamination








Surface and ground water monitoring is conducted in line with this action plan and reports are submitted to the relevant authorities.

102 Waste storage footprint Loss of resource due to spillage of brine waste Containment.

Berms, liners and stormwater control.

The mine is in the process of upgrading the PCDs at both the processing plant and the Madadeni Opencast area. The mine has developed a stormwater management plan and are in the process of implementation.

Fauna and

Flora 102

Clean and dirty water

separation

Peripheral impact relating to human presence and

mining related activity will lead to changes in vegetation

dynamics and alteration of natural ecological processes

and ecosystem functioning

Waste management will form a detailed component as part of the induction

process provided by the mine and good housekeeping practices will be in place.

Induction training provided to all new employees entering the mine.

Flora: loss or degradation of natural/pristine habitat Waste generated will be collected and disposed of in a licenced waste facility



facility.

Flora: loss or disruption of ecological connectivity Waste management will form a detailed component as part of the induction

process provided by the mine and good housekeeping practices will be in place. Induction training provided to all new employees entering the mine.

Flora: loss/degradation of surrounding habitat, species Implement a strict penalty fine breaking system for rule breaking

This will be implemented through the closure phase. Flora: Increase in local and regional

fragmentation/isolation of habitat Implement a strict penalty fine breaking system for rule breaking

Fauna: Degradation of sensitive faunal habitat in

surrounding areas



Fauna: Disruption of ecological connectivity and

migration routes Waste generated will be collected and disposed of in a licenced waste facility



facility.

Fauna: Direct impacts on common fauna species and

interactions with structures and personnel Implement a strict penalty fine breaking system for rule breaking This will be implemented through the closure phase.

Avifauna: Changes to community structure Waste management will form a detailed component as part of the induction



EMPR Aspect EMP EMPR Activity EMPR Impact Action Plan Audit Comment

Wetlands 103 Waste storage Deterioration in water quality


process provided by the mine and good housekeeping practices will be in place.

Hazardous waste generated will be stored in a bunded area and be collected and

disposed of in a licenced waste facility.



facility.

Noise 103 Diesel emergency

generators Noise

Final position to be determined and evaluated by and Environmental Acoustic

Consultant Emergency generator located at the processing plant

Social

103 Waste generation Surface water and soil contamination








Surface and ground water monitoring is conducted in line with this action plan and reports are submitted to the relevant authorities.

103 Disruption and

nuisance factors Noise, visual and traffic related impacts

The community forum established during the construction phase and

implemented throughout the operational phase of Nkomati should continue

through which issues can be addressed, and a representative from Nkomati

should become involved.

The mine has a good working relationship with the chiefs from surrounding communities and they meet on a regular basis.


5 SITEINSPECTIONANDCOMPLIANCEEVLUATION

Table 5:1 Processing Plant Area

No Area Compliance Observation Photograph Recommendations

1

Plant

rehabilitated

area

Discard has been dumped on the rehabilitation area. This

is counter‐productive and means that the topsoil that has

been placed there to rehabilitate the area is likely to be

lost. The mine is investigating a co‐disposal facility but this

process is in the formative stages

Determine and implement a plausible solution to deal

with excess discard/slurry.

2 Clean water

trench

Discard is around the clean water trench. During rainfall

events this could cause the clean water to become

contaminated

Discard to be cleared from around the clean water

trenches so that the storm water management plan can

be implemented effectively.

3

Clean/dirty

water

trenches

In the process of implementing the storm water

management plan, the mine has dug clean and dirty water

trenches. These trenches are not defined and full of loose

rubble.

These need to be clearly defined and cleared of rubble.



4 Void The void areas have been partly rehabilitated. There is no

clean water trench at the void.

Complete rehabilitation of these void areas inclusive of a

clean water trench. The storm water management plan

will contribute to the location of this trench.

5 Cleared area

behind offices

A large area has been cleared on the existing rehabilitated

area to be used for loading purposes. This area is new and

does not form part of the EMP or the existing Storm Water

Management Plans.

Include this area in the updated EMP and SWMP. The

mine is in the process of updating the EMP.

6

Old

rehabilitated

area

The old rehabilitated area is being used as a stockpile for

dried slurry. This means that the topsoil is lost along with

the potential for the land to be rehabilitated. The area is

also marked as a clean water area which has water

separation implications.

The mine is aware of the excess slurry issue which has led

to the investigation of a possible site for a slurry disposal

facility.



7 Waste

management

Litter was noted at the security hut at the back of the plant

area.

The back of the plant area is relatively far from the offices

and there is no need for management to frequent this

area. Periodic trips by management to this area will help

to ensure staff/security keep the area clean.

Building rubble has been discarded along the roadside

behind the office buildings.

Building rubble should be appropriately disposed of.

8 Plant process

water dam

Siltation of process water dam. This has negative impacts

on the capacity requirements of the dam.

The mine is in the process of upgrading this facility.



9

Processing

plant

workshop

Parts are serviced appropriately in the workshop area and

not out in the open on exposed soil. Maintain good practise.



10 Waste

disposal

General and hazardous wastes are mixed. There are enough waste disposal containers for general and hazardous waste to be stored separately.

The waste comes from all over the mine to this dumping

point and so the waste needs to be separated at source.

11 Diesel filling

station

The tank enclosure is bunded with a concrete floor. This is

good practise as it will contain any leaks of diesel/oil etc.

There is however a hole in the wall from which a pipe

comes out. This means that the purpose of the bunded

area is not fully achieved as contamination of the soil can

still occur through this hole, especially during rainfall

events where water can collect the harmful oil and diesel

from within the bund and flow out the hole.

The mine is aware of this problem and is investigating the

best way to fix the hole to ensure the integrity of the

bund



12

Vehicle service area/ workshop

Vehicles are serviced in a workshop which is under cover in a roofed area.

Maintain good practise.

13 The oil separation unit is placed directly on the soil, slowly leaking oil into the soil.

Place the unit on a drip tray.



14 Salvage yard

Used oil containers are stored in a bunded area with a sump. Some of these containers do not have lids. Part of the oil storage area is roofed, whilst part of the area is in the open.

Make sure that all containers are either sealed with a lid or placed under a roof.



15 The area has a gate and fence for access control.

Maintain good practise.

16

A bunded area is being constructed next to the salvage

yard. The purpose of this area is to place the waste

disposal containers on it so that there is no leaking of

waste directly into the soil

Investigate the feasibility of constructing a roof over the

area.

17 Septic Tank

One septic tanks were full at the time of conducting a site

visit. The other septic tank was not and was in good

condition. The septic tanks are in sunken concrete bunded

areas that are fenced.

The honey sucker schedule is being re‐evaluated.



18 Processing

Plant PCD

Loss of capacity of the PCD as slurry is making its way into

the PCD complex.

The mine is in the process of improving their slurry

management practises.

19 Access control The mine is fenced and has access control for both

pedestrians and vehicles.

Continue to maintain the fence and gates.


Table 5:2 Underground Area


1 Office / workshop

Domestic waste bins are full and overflowing. This waste can be blown by the wind. The domestic waste bins are collected internally.

This waste should be collected on a more regular basis

2 PCD No PCD has been constructed yet.



3 Generator The generator is placed on wooden logs on top of bare soil. Oil is leaking from the generator directly into the soil.

The generator should be placed on a drip tray



4 Pit

No operations are taking place at the underground pit.

As a result of very little traffic in the area there is little

erosion noted on the roads and ramps.

Maintain good practises when the underground

operations are re‐opened.

5 Septic Tanks Septic tanks are in a concrete bunded area and are in a

good condition.


Table 5:3 Madadeni Opencast


1 Topsoil

stockpile Topsoil erosion at the opencast area. Cover / vegetate topsoil stockpile.

2 Channels Pipes to assist dirty water to flow under the road are

not big enough, causing the channel to become silted

Increase the size of pipes to assist with through‐flow.



3 Livestock

Cattle and goats roam the mine. These animals do not

belong to the mine but rather to surrounding

communities who open the fence to let them in to

feed and drink. The livestock are at risk due to the

movement of machinery and presence of dirty water.

The Mine has Informed the communities of the risks to

the cattle and goats. The mine will continue to make

them aware that the mine accepts no responsibility for

any harm that may come to the cattle as they should not

be there as the fence has been checked and is secure.

The only way the cattle are there is if people force it

open.

4 Current dam

area

Dam and stockpile are in an area of potential flood.

The mine has appointed a civil design engineer and

conducted an aerial land survey. This will ensure the

effective design of the PCD in a suitable location

Continue with the prescribed designs and locations of the

PCD.



5 Water

trenches The banks of the trenches are severely eroded.

Cut and clearly define the channels. Investigate erosion

prevention measures. The mine is in the process of

implementing the storm water management plan. The

SWMP will contribute towards the location and design of

the trenches.

6 Alien species Encroachment of invasive plant species.

Remove invasive plant species. Local community

members can be used for this.


6 PREVIOUSACTIONPLAN(2015)

The following Action Plans was submitted to the Department of Mineral Resources (DMR) on

22 May 2015. The action plan has been audited against the actions implemented by the mine.

The table below provides the colour used in the audit.

Table 6:1 Performance Assessment Colour Coding ‐ Compliance Status

Legend Colour Coding

Compliance with action plan

Non‐compliance with action plan. Management measures or strategies have been developed or are in the process of being developed, or there is some evidence of measures being put in place

to implement the action.

Non‐compliance with action plan. No management measures or strategies are in place to implement the action.

Non‐compliance. The action is no longer applicable to the site due to an activity change.

Non‐compliance. The action is of such a nature that it is impossible to implement and require a review.


Table 6:2 Action Plan ‐ Madadeni Opencast

Priority Risk Profile Component Aspect Description of

Action Risk Identified

Actions Existing Authorisations

Additional Authorisations required

Timeframe Requirement for Regulatory Approvals

Compliance Status

Comment

Task Due Date

1

High Storm Water Management Plan

River Diversion

Mining has been approved within a non-perennial river, The non-perennial river has been diverted around the mining area.

The clean water that originates upstream of the mining area seem to increase significantly in velocity causing the clean water to jump the river diversion upstream from the mining area into the dirty water diversion canal to the temporary PCD. Additional clean water into the dirty water system has caused the dirty water system to break through to the river diversion at a lower point. Effective clean and dirty water separation is required. Ensure that design allows for the protection of both the diversion and the clean water canal system against erosion and scouring.

Care and Maintenance Period May 2011 to December 2014

WUL 05/X/13J/ACGIJ/1864 13 February 2014 NEMA 24G 12/12/20/2543 29 November 2013 GNR 386 Activity 4 Mining through wetland area MPRDA MP30/5/1/2/3/2/1(89)EM Approved 8 April 2011

Meet with the Regulatory Authorities as to ensure that existing approvals will suffice allowing construction to commence. Should existing approvals require an amendment, commence the process.

Concept Design River Diversion - Jones and Wagener Jones and Wagener –JW010/14/D413-Rev0 Indicate a Dam requirement of 49 000 m3 with an active evaporation system. Space and drainage limitations on site.

7 March 2014

New Ownership of the Mine 31 July 2014

Technical Design Phase Obtain the professional input from a Civil Design Engineer with regards to upgrading the river diversion.

18 February 15

Undertake a site inspection of the river diversion to confirm soil disperse properties.

17 March 2015

Obtain a formal cost proposal for Technical Civil Design and Materials Balance

27 March 2015

Formal Appointment to the Civil Engineer as to commence with Technical Design. 6 May 2015 An engineer was

appointed and a survey was conducted. The engineer created draft designs for the diversion.

Detailed 1m contour survey of the area as to determine slopes in order to accommodate gravity controlled clean and dirty water separation structures

20 March 2015

Draft Technical Design Phase (pending laboratory analysis for soil erosion properties)

Concept design presented to Nkomati Mine Management on 02 September 2015

The mine conducted extensive maintenance on the river diversion in the dry season of 2016. This included clearing the channels, supporting the banks and decreasing the angle of the diversion by smoothing out the bend. This maintenance has replaced the immediate need for further detailed designs and tender processes

Final Technical Design Phase 30 September 2015

Approval for the technical designs by the DWS

October / November 2015

Formal Tender process based on the Technical Designs for Construction

Post DWS Design Approval

Environmental approval process

Depending on final design and placement of infrastructure

2

Dirty Water Containment Facility

Temporary PCD to be upgraded to a lined facility

Current dirty water containment facility is authorised through both a NEMA and WULA process. Facility is not designed and constructed in terms of the requirements of the National Environmental Management Waste Act, Norms and Standards as published on 23 August

Care and Maintenance Period May 2011 to December 2014

NEMA – 24G 12/12/20/2543 29 November 2013 Area of 6 844 m2 for PCD WUL 05/X/13J/ACGIJ/1864 13 February 2014 Through Flow 18 615 m3/a

Concept Design Jones and Wagener –JW010/14/D413-Rev0 7 March 2014

New Ownership of the Mining Operations 31 July 2014

Review of the current clean and dirty water separation systems, mine layout, mine design and rehabilitation strategy for the opencast operations.

13 January 2015

Review of the Concept Design for the PCD Proposed positioning of the

permanent PCD does not allow

February / March 2015







Compliance Status

Comment

Task Due Date

2013 (Regulation 634, 635 and 636)

for dirty water run-off to drain freely into the PCD on the northern side of the mine.

Current design incorporates all clean water run-off from current and future rehabilitated areas resulting in a significant requirement for storage. Clean and dirty water must be separated i.t.o the requirements of GN704.

Requirement to re-design the Rehabilitation Implementation Strategy (RSIP) as to reduce the dirty water areas and allow for resizing of the PCD.

MPRDA MP30/5/1/2/3/2/1(89)EM Approved 8 April 2011

Install a rainfall gauge at the Madadeni Opencast Area as to log the rainfall in support of the water balance

March 2015

Detailed 1m contour survey of the area as to confirm the materials balance for rehabilitation purposes, final slopes and drainage taking into account the and end of mine contours (Free draining area post rehabilitation as to reduce the volume of clean water reporting to the PCD during operational and closure phases).

April 2015

Document the updated Rehabilitation Implementation Strategy Plan (RSIP) In progress In progress.

Obtain a formal cost proposal for Technical Civil Design for the revised storage volume design and position of the PCD

June 2015

Formal Appointment to the Civil Engineer as to commence with Technical Design June 2015

Update the hydrology calculations in support of the required storage capacity of the PCD as to contain the 1:50 year 24-hour Storm event that emanated from dirty water areas. Include the pit dewatering volumes in the water balance for the PCD.


Undertake the Technical Design for the PCD based on the requirements of the National Environmental Management Waste Act – Classification of the Waste, Barrier Design.



October / November 2015

Pending.


Depending on approval from DWS

Environmental Approval Process EMP Amendment NEMA Application WUL Application


Additional Dirty Water Containment Facility

EMP Amendment

NEMA Approval WUL Approval

8 Months







Compliance Status

Comment

Task Due Date

3

Rehabilitation Implementation Strategy (RSIP)

Implementation of concurrent rehabilitation as to keep the dirty water footprint as small as possible.

Ensure that the Roll-Over Method of mining is in compliance with the Rehabilitation Implementation Strategy Plan (RSIP).

A too large mining working face contributes significantly to the volume of dirty water generated in pit during a high rainfall event. This will influence the volume of water required to be dewatered and for which there must be a dirty water containment facility.

Review the existing mine plan as to ensure that the minimal box-cut areas are open as working areas and that concurrent rehabilitation is undertaken as part of the roll-over method of mining.

April 2015

Undertake the required material balance as to ensure that rehabilitated areas are sloped in such a manner to be free-draining and away from the dirty water containment facilities. Prevent clean water from entering the dirty water areas

May 2015

The mine is in the process of implementing an updated storm water management plan. This includes demarcated clean and dirty areas on the mine.

Revise the clean and dirty water separation infrastructure based on the mine plan taking into account the RSIP.

Concept presented to Nkomati Mine Management on 02 September 2015

Refer to aspects w.r.t the Dirty Water Containment Facility N/A

Table 6:3 Action Plan – Processing Plant






Compliance Status

Comment

Task Due Date

1 High Slurry Management

Slurry Settling Facility

Slurry from the Washing Plant is routed to two Slurry Settling Sumps from where the supernatant water is discharged to the Process Water Dams (south dams) for re-use. The existing two slurry settling sumps are designed below capacity which results in slurry spilling into the working area at the plant.

An under designed Slurry Settling Sump results in slurry deposition in the Process Water Dams that reduces the overall storage capacity. During rainfall events, runoff from this area will end up either in void 1 or in the depression net to the slurry handling area. Both areas are unlined and do not comply with the 2013 Regulations in terms of the National Environmental Management Waste Act.

Obtain the professional input from a Civil Design Engineer with regards to upgrading the Slurry Management Facilities at the Processing Plant

18 February 2015

WUL 05/X/13J/ACGIJ/1864 13 February 2014 Section 21(g) approval Disposal of slurry

into a slurry settling dam – 25 000 m3/a

Disposal of dry slurry into a dry slurry stockpiling area – 28 000 m3/a

Additional Slurry Disposal Facilities

EMP Amendment

NEMA Approval WUL Approval

Undertake a site inspection of the existing facilities as to investigate all alternatives 17 March 2015

Obtain a formal cost proposal for Technical Civil Design 27 March 2015

Formal Appointment to the Civil Engineer as to commence with Technical Design.

6 May 2015 PO002256

Investigate a Cyclone as Alternative to dewater the slurry April 2015

Concept Technical Design Phase Concept presented to Nkomati Mine Management on 02 September 2015

Final Technical Design Phase 30 September 2015

Approval for the technical designs by the DWS October /

November 2015


Depending on approval from DWS

Based on the new design determine Environmental approval requirements. Depending on

final design and placement of infrastructure

8 months







Compliance Status

Comment

Task Due Date

2 High Storm Water Management


Polluted storm water from the plant area drains into void 2. The plant area requires a dedicated Dirty Water Containment Facility designed in accordance to the requirements of the National Environmental Management Waste Act, Norms and Standards as published on 23 August 2013 (Regulation 634, 635 and 636)

Currently all dirty water run-off is collected within the open void areas. Based on existing berms around the Processing Plant Area there is evidence that rain water falling onto this area drain towards the plant itself for collection in a sump before being transferred to the process water dams. The Processing Plant area requires a dedicated pollution control facility for dirty storm water run-off which is constructed in terms of the requirements of the National Environmental Management, Waste Act as published on 23 August 2013.

Care and Maintenance May 2011 to December 2014

New Lined Facility Additional PCD EMP

Amendment NEMA Approval WUL Approval

Concept Design Jones and Wagener – JW180/13/D413-Rev0 Indicated a Dam capacity requirement for the PCD in the order of 11 000 m3. Design does not take into account product loss or water transferred from Madadeni Opencast area

26 September 2013

Plot existing clean and dirty water trenches in support of the Storm Water Management Plan as to determine additional requirements in an effort to separate rehabilitated areas away from the dirty areas.

April 2015

The mine is in the process of updating the Storm Water Management Plan. The plotting of clean and dirty water trenches forms part of this process.

Reduce the dirty water containment footprint area as small as possible – inclusion of the plant area, PCD and coal loading areas only. Rehabilitate Void area 1 and 2 as to allow the clean water to leave the site.

May / June / July / Aug / Sept 2015

Update the hydrology calculations as to determine the required size of the PCD based on the footprint area. Take into account the requirements of GN704.


A new hydrology report is needed.



The mine has commenced the WUL process and has entered into EMP Consolidation.

Undertake the required Regulatory Approval Process


8 Months

Clean and dirty water separation infrastructures

Ensuring that the Processing Plant footprint area is as small as possible for the purpose of containing dirty storm water run-off.

A significant volume of clean water run-off from the rehabilitated areas forms part of the dirty water system and collects in open void areas. Dirty water run-off is drained to historical void areas for re-use. Based on existing berms around the Processing Plant Area there is evidence that rain water falling onto this area drain towards the plant itself for collection in a sump before being transferred to the process water dams Dirty water footprint area (including


April 2015

GN704 Requirement The mine is in the process of updating the Storm Water Management Plan. The plotting of clean and dirty water trenches forms part of this process.

Reduce the dirty water containment footprint area as small as possible – inclusion of the plant area, PCD and coal loading areas only.

May / June / July Aug / Sept 2015

Prepare Civil Design drawings for sign off by DWS prior to construction








Compliance Status

Comment

Task Due Date

the rehabilitated area) is too large and should be reduced – Refer RSIP.

3 Hight


Backfilling and rehabilitation of Void 1 (Void north of washing plant

The void should be backfilled, top soiled and vegetated as to be free draining and reduce rain water ingress. With the completion of rehabilitation this area should become a clean water system

Clean water finding its way into the dirty water system

Immediately clean up existing topsoil areas where there may be evidence of discard or carbonaceous material spillage

In Progress WUL 05/X/13J/ACGIJ/1864 13 February 2014 Section 21(g) approval

Backfill the area and slope as to be free draining. Prevent ponding of water onto the backfilled area as to reduce recharge. Slope in contours as to prevent erosion of the topsoil.

In Progress

Topsoil and hydroseed with indigenous seed mix of grass species indigenous to the area ready for the rainy season

In Progress

Refer to the requirement under clean and dirty water separation as to ensure that this area becomes a clean water system.

N/A

The mine is in the process of updating the Storm Water Management Plan. This will involve updated clean and dirty water areas.

Backfilling and rehabilitation of Void 2 (Void south of washing plant





Backfill the area and slope as to be free draining. Prevent ponding of water onto the backfilled area as to reduce recharge. Slope in contours as to prevent erosion of the topsoil.

In Progress

Topsoil and hydroseed with indigenous seed mix of grass species indigenous to the area ready for the rainy season

In Progress


N/A

The mine is in the process of updating the Storm Water Management Plan. This will involve updated clean and dirty water areas.

4 High Overall Water Management

Water and Salt Balance

Quantification of water used, stored and re-used on site as to confirm the requirements for dirty water containment

Estimated volumes may result in inaccuracies which may lead to the under design of the dirty water containment facility.

Install Flow Meters at the main inlet and outlet points where water is moved between facilities

February 2015

Commence with logging actual metered water use in a formal reporting system March 2015

Install rainfall gauges at the Processing Plant and the Madadeni opencast Areas March 2015

Compile a site specific active water balance based on the data received from both the flow meters as well as the rainfall gauges

On-going

Use the water quality data from the sampling program as to populate the salt balance tied to the water balance

On-going

Identify additional monitoring requirements in support of the water and salt balance

On-going

Use the data as to inform the design requirement for dirty water containment facilities

On-going


7 2017ACTIONPLAN

A new action plan was developed to assist Nkomati Anthracite Mine in plotting a way forward to ensure

compliance.


Table 7:1 Action Plan ‐ Madadeni Opencast

Priority Risk Profile Component Aspect Description of Action Risk Identified




Task Due Date

1 Storm Water Management Plan


Temporary PCD to be upgraded to a lined facility

Current dirty water containment facility is authorised through both a NEMA and WULA process. Facility is not designed and constructed in terms of the requirements of the National Environmental Management Waste Act, Norms and Standards as published on 23 August 2013 (Regulation 634, 635 and 636)

Document the updated Rehabilitation Implementation Strategy Plan (RSIP) In progress

MPRDA MP30/5/1/2/3/2/1(89)EM Approved 8 April 2011

Additional Dirty Water Containment Facility

EMP Amendment NEMA Approval WUL Approval

Approval for the technical designs by the DWS 2018

8 Months

Formal Tender process based on the Technical Designs for Construction 2018

Environmental Approval Process EMP Amendment NEMA Application WUL Application

Depending on final design and placement of infrastructure. Likely to be finalised in 2018.

2


Implementation of concurrent rehabilitation as to keep the dirty water footprint as small as possible.

Ensure that the Roll-Over Method of mining is in compliance with the Rehabilitation Implementation Strategy Plan (RSIP).

Too large a mining working face contributes significantly to the volume of dirty water generated in pit during a high rainfall event. This will influence the volume of water required to be dewatered and for which there must be a dirty water containment facility.

Undertake the required material balance as to ensure that rehabilitated areas are sloped in such a manner to be free-draining and away from the dirty water containment facilities. Prevent clean water from entering the dirty water areas

2018

Revise the clean and dirty water separation infrastructure based on the mine plan taking into account the RSIP.

2018

Refer to aspects w.r.t the Dirty Water Containment Facility N/A


Table 7:2 Action Plan – Processing Plant





Task Due Date

1 Slurry Management

Slurry Settling Facility

Slurry from the Washing Plant is routed to two Slurry Settling Sumps from where the supernatant water is discharged to the Process Water Dams (south dams) for re-use. The existing two slurry settling sumps are designed below capacity which results in slurry spilling into the working area at the plant.

An under designed Slurry Settling Sump results in slurry deposition in the Process Water Dams that reduces the overall storage capacity. During rainfall events, runoff from this area will end up either in void 1 or in the depression net to the slurry handling area. Both areas are unlined and do not comply with the 2013 Regulations in terms of the National Environmental Management Waste Act.

Final Technical Design Phase

Depending on final design and placement of infrastructure. Likely to be completed in 2018.

WUL 05/X/13J/ACGIJ/1864 13 February 2014 Section 21(g) approval Disposal of

slurry into a slurry settling dam – 25 000 m3/a

Disposal of dry slurry into a dry slurry stockpiling area – 28 000 m3/a

Additional Slurry Disposal Facilities

EMP Amendment NEMA Approval WUL Approval



Based on the new design determine Environmental approval requirements.

2

Storm Water Management


Polluted storm water from the plant area drains into void 2. The plant area requires a dedicated Dirty Water Containment Facility designed in accordance to the requirements of the National Environmental Management Waste Act, Norms and Standards as published on 23 August 2013 (Regulation 634, 635 and 636)

Currently all dirty water run-off is collected within the open void areas. Based on existing berms around the Processing Plant Area there is evidence that rain water falling onto this area drain towards the plant itself for collection in a sump before being transferred to the process water dams. The Processing Plant area requires a dedicated pollution control facility for dirty storm water run-off which is constructed in terms of the requirements of the National Environmental Management, Waste Act as published on 23 August 2013.


Concept presented to Nkomati Mine Management on 02 September 2015. Depending on final design and placement of infrastructure this can be completed in 2018.

New Lined Facility

Additional PCD EMP Amendment NEMA Approval WUL Approval

Reduce the dirty water containment footprint area as small as possible – inclusion of the plant area, PCD and coal loading areas only. Rehabilitate Void area 1 and 2 as to allow the clean water to leave the site.

Update the hydrology calculations as to determine the required size of the PCD based on the footprint area. Take into account the requirements of GN704.


Undertake the required Regulatory Approval Process

Clean and dirty water separation infrastructures

Ensuring that the Processing Plant footprint area is as small as possible for the purpose of containing dirty storm water run-off.

A significant volume of clean water run-off from the rehabilitated areas forms part of the dirty water system and collects in open void areas. Dirty water run-off is drained to historical void areas for re-use. Based on existing berms around the Processing Plant Area there is evidence that rain water falling onto this area drain towards the plant itself for collection in a sump before being transferred to the process water dams Dirty water footprint area (including the rehabilitated area) is too large and should be reduced – Refer RSIP.

Plot existing clean and dirty water trenches in support of the Storm Water Management Plan as to determine additional requirements in an effort to separate rehabilitated areas away from the dirty areas. Concept presented to

Nkomati Mine Management on 02 September 2015. Depending on final design and placement of infrastructure this can be completed in 2018.

GN704 Requirement

Reduce the dirty water containment footprint area as small as possible – inclusion of the plant area, PCD and coal loading areas only.

Prepare Civil Design drawings for sign off by DWS prior to construction

3


Backfilling and rehabilitation of Void 1 (Void north of washing plant

The void should be backfilled, top soiled and vegetated as to be free draining and reduce rain water ingress.



N/A

WUL 05/X/13J/ACGIJ/1864 13 February 2014 Section 21(g)


With the completion of rehabilitation this area should become a clean water system

approval

4

Backfilling and rehabilitation of Void 2 (Void south of washing plant






N/A


Table 7:3 Action Plan – Mangweni Underground





Task Due Date

1

Re-opening Mangweni Underground Operations

Re-opening Mangweni Underground Operations

The mine has lodged an application to DMR to rehabilitate and safeguard the underground workings.

Underground workings may not be safe for operations to re-commence

Upgrade and maintenance of change houses, workshops, offices and related infrastructure.

Prior to re-opening of Mangweni Underground 3 Approved EMPs:

Geovicon 2005 Geovicon 2011 GCS 2012

Consolidated EMP, NEMA Basic Assessment

Transport all excess run of mine product located on the floor of the underground workings to the processing plant to be processed.

On-going

Register and license the borehole located at the underground workings.

Prior to re-opening of Mangweni Underground

WUL 05/X/13J/ACGIJ/1864 13 February 2014 Section 21(g) approval

Pump water from underground operations to old voids On-going

Establish additional ROM at the surface with a conveyor belt transporting ore from the underground mine workings to the surface. Approval must be obtained through the NEMA Basic Assessment Process.

On-going

3 Approved EMPs: Geovicon 2005 Geovicon 2011 GCS 2012

2 Ecology Flora Implement a Plant Rescue and Recovery Programme

Loss of vegetation, habitat and land capability

Implement a Plant Rescue and Recovery Programme for sensitive areas and protected plant species.

Construction Phase

Final Basic Assessment Report and Consolidated Environmental Management Plan (Submitted to DMR on 7 March 2017)

3

Hazardous Materials Spills Contingency Plan

Soil Contamination

The Mine needs to implement a Hazardous Materials Spill Contingency Plan to allow for the effective and timeous clean-up of spills.

Pollution of soils through the use, handling, transport and storage of hazardous materials (hydrocarbons, cement, chemicals)

Create and implement Hazardous Materials Spills Contingency Plan.

Construction phase of Mangweni Underground

IWWMP Storm Water An IWWMP needs to be implemented to effectively manage storm water.

Erosion, sedimentation and potential pollution caused by surface water run-off.

Compile and implement a site specific IWWMP.

Dewatering the aquifer Groundwater

Implement a dewatering programme to allow for safe underground mine rehabilitation and safety

Fissure water may become contaminated into mine workings, reducing safety and ability to conduct rehabilitation

Implement a dewatering programme for the underground mine workings.

Visual Airborne Litter

The construction site for the underground needs to be kept neat, tidy and litter free.

Airborne litter blows from the underground construction site to surrounding areas.

Implement a waste management plan to ensure waste is disposed of at the skips (at the processing plant). Reuse and recycle as far as practically possible.


8 REFERENCES

GCS, 2012 EMPR Nkomati Anthracite Madadeni Opencast Section. Environmental Impact

Assessment and Environmental management Plan Report Rectification in terms of Section

24G of the Environmental Management Act, 1998 (Act No. 107 of 1998)

DWS, 2012. Water Use Licence, Licence 05/X/13J/ACGIJ/1864 File No 27/2/2/X13J/049

Geovicon cc, 2005. Nkomati Anthracite Mine. Environmental Impact Assessment and

Environmental Management Programme. Report No 522/2005.

Geovicon Environmental, 2011 EMPR Amendment: Ref: MP 30/5/1/2/3/2/1 (89) EM

Environmental Impact Assessment Madadeni Opencast Mining Project.

Documents

Sentula Mining Nkomati Anthracite Mine (Pty) Ltd ... · Underground mining Underground pillar failure Ensure that pillar failure does not re-occur. The underground mine workings are