Appendix 17 Aquatic Ecology and Wetlands Report

APPENDIX 17 AQUATIC ECOLOGY AND WETLANDS REPORT

FRESHWATER ECOLOGICAL ASSESSMENT AS PART OF THE ENVIRONMENTAL AUTHORISATION AND WATER USE LICENSE APPLICATION PROCESS FOR THE PROPOSED ERPM EXPANSION AREA 2 MINE, BRAKPAN SOUTH, GAUTENG PROVINCE

Prepared for

Prime Resources Environmental Consultants

June 2019

Prepared by: Scientific Aquatic Services Report author: L. Robson (Cand. Sci. Nat) Report reviewers: K. Marais (Pr. Sci. Nat) S. van Staden (Pr. Sci. Nat) Report reference: SAS 219104 Date: June 2019

Scientific Aquatic Services CC CC Reg No 2003/078943/23 Vat Reg. No. 4020235273 PO Box 751779 Gardenview 2047 Tel: 011 616 7893 Fax: 086 724 3132 E-mail: [email protected] SAS 219104 June 2019

EXECUTIVE SUMMARY

Based on the findings of the freshwater ecological assessment and the results of the risk assessment it is the opinion of the ecologist that the proposed East Rand Proprietary Mines (ERPM) expansion poses a moderate risk to the integrity of the wetlands associated with the Windmill and Witpoortjie Vent Shafts. Adherence to cogent, well-conceived and ecologically sensitive site development plans, the mitigation measures provided in this report as well as general good construction practice and ongoing management, maintenance and monitoring, are essential if the significance of perceived impacts is to be reduced to limit further degradation of the freshwater environment.

It is the opinion of the freshwater specialist that the proposed ERPM expansion, from a freshwater resource management perspective, is considered acceptable, with the proviso that no development takes place within the wetlands or the associated 100m GN704 Zone of Regulation and that strict adherence to mitigation measures is enforced to ensure that the ecological integrity of the freshwater environment is not further compromised.

MANAGEMENT SUMMARY

Scientific Aquatic Services (SAS) was appointed to conduct a freshwater ecological assessment as part of the Environmental Authorisation and Water Use Licence Application (WULA) process for the proposed East Rand Proprietary Mines (ERPM) Expansion Area 2 Mine, Gauteng Province, hereafter referred to as the ‘proposed ERPM expansion’. ERPM holds a prospecting right for the ERPM Extension 1 area, which ERPM intends to convert into a mining right and plans to consolidate the underground resources. In order to do so, this would require the development of the Windmill Shaft (a twin shaft including both access and vent shafts) and the Witpoortjie Vent Shaft (an existing ventilation shaft to be refurbished) to allow access to the underground operations.

A desktop study was conducted in which watercourses were identified for on-site investigation, and relevant national and provincial databases were consulted. The results of the desktop study are contained in Section 4 of this report. In order to identify all watercourses that may potentially be impacted by the proposed ERPM expansion, a 500m “zone of investigation” around the proposed ERPM expansion, in accordance with Government Notice (GN) 509 of 2016 as it relates to the National Water Act, 1998 (Act No. 36 of 1998), was used as a guide in which to assess possible sensitivities of the receiving freshwater environment. This area – i.e. the 500m zone of investigation around the proposed ERPM expansion - will henceforth be referred to as the “investigation area”.

During the site assessment undertaken on the 9th of May 2019, a single watercourse was identified within the investigation area of the Windmill Shaft, a Hillslope Seep (HSS) wetland, while a single watercourse, a Channelled Valley Bottom (CVB) wetland, was identified within the investigation area of the Witpoortjie Vent Shaft. The HSS wetland associated with the Windmill Shaft is located along the northern boundary of the investigation area and drains in a northerly direction. The CVB wetland associated with the Witpoortjie Vent Shaft is located within the eastern and southern portions of the investigation area and drains in a south westerly direction towards an unnamed tributary of the Rietspruit River. A summary of the assessment of the wetlands is provided in Table A below: Table A: Summary of results of the field assessment of the wetlands associated with the proposed ERPM expansion. Watercourse PES Ecoservices EIS REC and RMO REC: D (Largely modified) CVB wetland D (Largely modified) Intermediate Moderate RMO: Maintain C (Moderately REC: C (Moderately modified) HSS wetland Moderately low Low/marginal modified) RMO: Maintain

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Following the ecological assessment of the wetlands, the Department of Water and Sanitation (DWS) Risk Assessment Matrix (2016) as it relates to activities as stipulated in Section 21(c) and (i) of the National Water Act, 1998 (Act No. 36 of 1998) was applied to ascertain the significance of possible impacts which may occur as a result of the proposed ERPM expansion. As the delineated wetlands do not fall within the proposed Windmill or Witpoortjie Vent areas, and as it is assumed that no development will therefore take place within the wetland or the associated 100m GN704 Zone of Regulation, some activities pertaining to the proposed ERPM expansion, such as site preparation and construction of surface infrastructure, are anticipated to pose a low risk to the wetlands. However, the outcome of the Risk Assessment indicated that certain activities associated with the proposed ERPM expansion, such as the development of the shafts and clean and dirty water separation systems, will pose a moderate risk to the receiving freshwater environment during the construction phase. The results of the risk assessment are summarised in Table B below.

Table B: Summary of the results of the risk assessment applied to the wetlands associated with the proposed ERPM expansion.

No. Activity Aspect Impact

Phase

Risk Rating

Significance Site preparation prior to construction activities related *Vehicular movement *Runoff with high sediment loads entering the to the proposed and access to the site; wetlands as a result of exposed soil from new Windmill *Removal of terrestrial cleared areas, smothering the wetland Shaft and the vegetation and vegetation and thus altering the habitat of the rehabilitation of associated wetlands, leading to areas within the wetlands the existing disturbances (rubble more suited to terrestrial vegetation; 1 Witpoortjie Vent and litter) to soil; and *Compaction of soil due to the movement of 52.3 L Shaft, including *Possible unplanned construction machinery leading to alterations proposed surface and uncontrolled of runoff patterns into the wetlands; infrastructure, movement of *Proliferation of alien vegetation as a result of and the construction machinery disturbances; and placement of through the CVB and *Vegetation degradation, and the subsequent contractor HSS wetland. loss of habitat for wetland species. laydown areas and storage facilities. *Movement of construction machinery within the 100m

Construction Phase GN704 Zone of *Loss of wetland habitat and ecological Regulation (HSS structure as a result of edge effects associated wetland); with the ERPM expansion; Construction of *Ground-breaking and *Impacts to the ecoservice provision of the surface earthworks relating to wetland; infrastructure foundations; *Potential impacts on the hydrology and associated with *Mixing and casting of sedimentation of the wetland, leading to 2 the Windmill 54 L concrete for alteration of the flood regime; Shaft, such as construction purposes; *Potential impacts on the water quality of buildings, *Stockpiling of runoff which may potentially enter the structures and construction materials; downgradient wetland and contamination of internal roads. *Creation of a topsoil soils due to concrete being cast; and stockpile and a Waste *Proliferation of alien and invasive plant Rock Dump (WRD); species within the wetlands. *Increased likelihood of dust generation due to exposed soils; and

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No. Activity Aspect Impact

Phase

Risk Rating

Significance *Changes to stormwater runoff in the landscape as a result of construction activities and increased impermeable surfaces. *Movement of Construction of construction machinery surface within the 100m infrastructure GN704 Zone of associated with Regulation (CVB the Witpoortjie wetland); Vent Shaft, *Stockpiling of including construction materials; refurbishment of *Increased likelihood of 45 L the existing dust generation due to ventilation shaft, exposed soils; and surface *Changes to ventilation fans, stormwater runoff in an access road the landscape as a and a generator result of construction and compressor. activities and increased impermeable surfaces. Loss of catchment yield resulting from stormwater containment, leading to: *Ground-breaking *Increased flood peaks as a result of associated with the formalisation and concentration of surface Development of excavation of trenches; runoff in clean water diversion structures; clean and dirty *Removal of topsoil; *Potential for erosion, leading to sedimentation 3 87.8 M water separation and of the wetlands; systems. *Excavation activities *Reduction in volume of water entering the leading to the wetlands, leading to loss of recharge of the stockpiling of soil. wetlands; and *Altered vegetation community structure and diversity due to moisture stress. *Potential subsidence of surrounding environment if pillars are insufficient to support the ground; *Excavation, drilling *Potential creation of a cone of depression, Sinking of the and blasting in order to which may drain water from surrounding Windmill Shafts, sink the shafts, leading wetland habitats, thus resulting in desiccation and associated to stockpiling of rock of the wetlands; 4 removal of waste 44 L and topsoil; and *Water entering the shafts as a result of material and *Operation of ingress may necessitate dewatering of the other excavated construction equipment shafts, which may result in the discharge of materials. on site. dirty water into the surrounding wetland environment; *Potential spillage of oils/hydrocarbons from construction vehicles.

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No. Activity Aspect Impact

Phase

Risk Rating

Significance *Nitrates from blasting leaching from the WRD, leading to eutrophication of the receiving environment and resulting in loss of potable *Below-ground blasting water within the catchment; and and storage of waste *Increased risk of pollution of surface water 100 M rock within the WRD. and groundwater, which may affect the wetland areas, leading to impaired water quality and salinisation of soils within the wetlands. *The potential failure of the PCD infrastructure may result in leakages and possible Operation of the PCD contamination of surface and groundwater, Operation of the associated with the increased flow into the HSS wetland, and 104 M Windmill and Windmill Shaft. lowered water quality (increase in salts and 5 Witpoortjie specific contaminants of concern and reduced Shafts. pH) within the wetland. *Impacts to the hydrological processes of the wetlands due to removal of interflow soils; *Potential creation of a *Changes in wetland hydroperiod and cone of depression; vegetation structure; *Dewatering of the *As a result of dewatering, contaminated water shafts; and may enter the receiving environment leading to 108 M *Potential decant from altered water quality; and the shafts to the *Alteration (increase) of flow regimes, receiving freshwater reduction in water quality (increase in salts and

Operational Phase environment. specific contaminants of concern and reduced pH) and subsequent loss of biodiversity of the wetlands due to decant of contaminated water. Loss of catchment yield due to stormwater containment is expected to occur, which could lead to the following impacts: *Increased flood peaks into the wetlands as a *Containment/diversion result of formalisation and concentration of of runoff into the clean surface runoff; and dirty water system; *Potential for erosion of terrestrial areas as a Operation of the *Discharge of clean result of the formation of preferential flow clean and dirty water into the 6 paths, leading to sedimentation of the 51 L water separation surrounding wetland wetlands; systems. systems; and *Reduction in volume of water entering the *Potential of wetlands, leading to loss of recharge (and thus malfunctioning of the potential desiccation) of the wetland systems; dirty water system. *Erosion and sedimentation of the wetlands at the outlet of the clean water trench; and *Altered vegetation communities due to moisture stress. Rehabilitation of *Re-vegetation of the the wetlands and *Temporarily altered flow regime, leading to wetland and 100m 100m GN704 possible loss of recharge to downgradient GDARD setback area 7 Zones of areas, impacting on downgradient biota; and 45 L and removal of Regulation *Possible sedimentation of downgradient construction material associated with areas. and waste. the shafts.

Closure Phase Rehabilitation of *Sealing and backfilling *Compaction of soils due to vehicular 8 surface 55 L of the shafts; movement; infrastructure

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No. Activity Aspect Impact

Phase

Risk Rating

Significance footprint areas, *Rehabilitation of *Compacted soils underneath the surface with specific disturbed areas by infrastructure which have been removed; focus on the contouring and *Latent impacts of vegetation losses; shafts. revegetating them to *Increased runoff volumes and formation of blend into the natural preferential surface flow paths as a result of landscape which compacted soils, leading to alteration of should be free hydrological recharge paths; and draining; and *Increased sedimentation and erosion. *Removal of stormwater management infrastructure to ensure a free draining landscape. *Contamination of water within the receiving freshwater environment, and subsequent Decant of reduction in water quality (increase in salts and contaminated water specific contaminants of concern and reduced Post-closure from the rehabilitated pH); 9 management 55 L shaft area into the *Subsequent negative impacts on biota and activities. receiving freshwater vegetation; environment. *Altered flow regimes (increased hydroperiod); and *Habitat degradation.

Based on the findings of the freshwater ecological assessment, several recommended mitigation measures are made to minimise the impact on the watercourses. Key mitigation measures include (but are not limited to):  No construction may take place within the wetlands or 100m GN704 Zone of Regulation. Additionally, the wetlands and 100m GN704 Zone of Regulation must be demarcated as a no- go area;  No stockpiles are to be permitted within the 100m GN704 Zone of Regulation;  Exposed soil and stockpiles must be protected from wind by covering with a suitable geotextile such as hessian sheeting and ensure no stockpiles are higher than 2m;  Dust suppression measures must be implemented throughout construction to prevent excessive dust which may smother wetland vegetation;  Clean and dirty water areas should be kept separate;  The dirty water systems should be adequately sized as per the GN704 Regulatory Requirements, to prevent failure thereof and ultimately, discharge of contaminated water into the wetlands;  Any Pollution Control Dams (PCDs) must have capacity to cater for a 1:50 year flood occurring over a 24 hour period and the PCDs must be lined with an appropriate liner;  Clean water captured in the clean water system should be returned back into the surrounding wetland systems. However, the wetlands must be protected against erosion arising from the discharge of clean water in a concentrated manner;  The clean water outlet should be constructed with the use of energy dissipating structures to slow down the velocity of water inflow into the wetland;  A site-specific rehabilitation plan, including an alien invasive plant (AIP) management plan, must be compiled and implemented. AIPs should be removed by hand and no machinery should be allowed in the wetlands; and  The 100m GN704 Zone of Regulation must be rehabilitated with indigenous vegetation, thus incorporating faunal and floral habitats. This will ensure that the current levels of ecological service provision of the wetlands are maintained and where feasible, improved.

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DOCUMENT GUIDE

The following table indicates the requirements for Specialist Studies as per Appendix 6 of Government Notice 326 of 2017, amendments to the Environmental Impact Assessment (EIA) Regulations, 2014 as it relates to the National Environmental Management Act, 1998 (Act No. 107 of 1998), promulgated in Government Notice 40772 of 2017. No. Requirement Section in report a) Details of - (i) The specialist who prepared the report Appendix G (ii) The expertise of that specialist to compile a specialist report including a curriculum vitae Appendix G b) A declaration that the specialist is independent Appendix G c) An indication of the scope of, and the purpose for which, the report was prepared Section 1.2 cA) An indication of the quality and age of base data used for the specialist report Section 2.1 cB) A description of existing impacts on the site, cumulative impacts of the proposed Section 4.1 and 5.1 development and levels of acceptable change d) The duration, date and season of the site investigation and the relevance of the season Section 3.1 to the outcome of the assessment e) A description of the methodology adopted in preparing the report or carrying out the Appendix C specialised process inclusive of equipment and modelling used f) Details of an assessment of the specific identified sensitivity of the site related to the Section 5 proposed activity or activities and its associated structures and infrastructure, inclusive of a site plan identifying site alternatives g) An identification of any areas to be avoided, including buffers Section 5.3 h) A map superimposing the activity including the associated structure and infrastructure on Section 5.3 the environmental sensitivities of the site including areas to be avoided, including buffers i) A description of any assumption made and any uncertainties or gaps in knowledge Section 1.3 j) A description the findings and potential implication\s of such findings on the impact of the Section 5, 6, and 7 proposed activity, including identified alternatives on the environment or activities k) Any mitigation measures for inclusion in the EMPr Section 6.1 l) Any conditions for inclusion in the environmental authorisation Section 6 m) Any monitoring requirements for inclusion in the EMPr or environmental authorisation Section 6 n) A reasoned opinion - (i) As to whether the proposed activity, activities or portions thereof should be authorised Section 7 (iA) Regarding the acceptability of the proposed activity or activities Section 7 (ii) If the opinion is that the proposed activity, activities or portions thereof should be Section 7 authorised, any avoidance, management and mitigation measures that should be included in the EMPr, and where applicable, the closure plan o) A description of any consultation process that was undertaken during the course of N/A preparing the specialist report p) A summary and copies of any comments received during any consultation process and N/A where applicable all responses thereto; and q) Any other information requested by the competent authority N/A

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TABLE OF CONTENTS

EXECUTIVE SUMMARY ...... ii TABLE OF CONTENTS ...... ix LIST OF FIGURES ...... x LIST OF TABLES ...... x GLOSSARY OF TERMS ...... xi ACRONYMS ...... xii 1 INTRODUCTION ...... 1 1.1 Background ...... 1 1.2 Scope of Work ...... 2 1.3 Assumptions and Limitations ...... 3 1.4 Legislative Requirements and Provincial Guidelines ...... 4 2 PROJECT DESCRIPTION ...... 4 3 ASSESSMENT APPROACH ...... 7 3.1 Watercourse Field Verification ...... 7 3.2 Sensitivity Mapping ...... 8 3.3 Risk Assessment and Recommendations...... 8 4 RESULTS OF THE DESKTOP ANALYSIS ...... 9 4.1 Analyses of Relevant Databases ...... 9 5 RESULTS: WATERCOURSE ASSESSMENT ...... 19 5.1 Watercourse Delineation ...... 19 5.2 Watercourse System Characterisation ...... 20 5.2.1 Existing Impacts ...... 23 5.3 Field Verification Results ...... 23 5.4 Sensitivity Mapping ...... 28 5.4.1 Legislative Requirements, National and Provincial guidelines pertaining to the application of buffer zones ...... 28 6 RISK ASSESSMENT ...... 32 6.1 Risk Analyses ...... 32 6.1.1 Consideration of impacts and application of mitigation measures ...... 32 6.1.2 Impact discussion and essential mitigation measures...... 33 7 CONCLUSION ...... 41 REFERENCES ...... 42 APPENDIX A – Terms of Use and Indemnity ...... 43 APPENDIX B – Legislation ...... 44 APPENDIX C – Method of Assessment ...... 46 APPENDIX D – Risk Assessment Methodology ...... 54 APPENDIX E – Results of Field Investigation ...... 58 APPENDIX F – Risk Assessment and Mitigation Measures ...... 60 APPENDIX G – Specialist information ...... 68

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LIST OF FIGURES

Figure 1: A digital satellite image depicting the location of the ERPM expansion and investigation area in relation to the surrounding environment...... 5 Figure 2: The ERPM expansion and investigation area depicted on a 1:50 000 topographical map in relation to the surrounding environment...... 6 Figure 3: The wetlands and rivers associated with the proposed ERPM expansion according to the NFEPA Database (NFEPA, 2011)...... 12 Figure 4: The wetland vegetation types associated with the proposed ERPM expansion...... 13 Figure 5: The river and wetland buffers associated with the proposed ERPM expansion according to the Gauteng C-Plan V3.3 (2011)...... 14 Figure 6: CBAs and ESAs associated with the proposed ERPM expansion according to the Gauteng C-Plan V3.3 (2011)...... 15 Figure 7: Gauteng Environmental Management Framework zones (EMF, 2015) associated with the proposed ERPM expansion...... 16 Figure 8: Underlying geology associated with the proposed ERPM expansion...... 17 Figure 9: Relevant sub-quaternary catchment reach (SQR) associated with the proposed ERPM expansion...... 18 Figure 10: Distinct mottling (left) and obligate wetland species (Schoenoplectus brachyceras), (right) used to aid in the delineation of the watercourses...... 19 Figure 11: The delineated HSS wetland associated with the Windmill Shaft...... 21 Figure 12: The delineated CVB wetland associated with the Witporrtjie Vent Shaft...... 22 Figure 13: An informal road and pipelines traversing the CVB wetland (left); an excavated trench and infilling of an area of the wetland with gravel (red dotted line) (right)...... 23 Figure 14: Conceptual presentation of the zone of regulation in terms of GN509 of 2016 and GN704 of 1999 as it relates to the National Water Act, 1998 (Act No. 36 of 1998), and the relevant GDARD setback area in relation to the HSS wetland. ... 30 Figure 15: Conceptual presentation of the zone of regulation in terms of GN509 of 2016 as it relates to the National Water Act, 1998 (Act No. 36 of 1998), and the relevant GDARD setback area in relation to the CVB wetland...... 31

LIST OF TABLES

Table 1: Desktop data relating to the character of the watercourses associated with the proposed ERPM expansion...... 10 Table 2: Characterisation of the watercourses associated with the proposed ERPM expansion according to the Classification System (Ollis et. al., 2013)...... 20 Table 3: Summary of the assessment of the Channelled Valley Bottom (CVB) wetland associated with the Witpoortjie Vent Shaft...... 24 Table 4: Summary of the assessment of the hillslope seep (HSS) wetland associated with the Windmill Shaft...... 26 Table 5: Articles of Legislation and the relevant zones of regulation applicable to each article...... 28 Table 6: Summary of the results of the risk assessment applied to wetlands associated with the proposed ERPM expansion...... 34 Table 7: Summary of results of the field assessment as discussed in Section 5...... 41

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GLOSSARY OF TERMS

Alien vegetation: Plants that do not occur naturally within the area but have been introduced either intentionally or unintentionally. Vegetation species that originate from outside of the borders of the biome -usually international in origin. Biodiversity: The number and variety of living organisms on earth, the millions of plants, animans and micro- organisms, the genes they contain, the evolutionary history and potential they encompass and the ecosystems, ecological processes and landscape of which they are integral parts. Buffer: A strip of land surrounding a wetland or riparian area in which activities are controlled or restricted, in order to reduce the impact of adjacent land uses on the wetland or riparian area. Catchment: The area where water is collected by the natural landscape, where all rain and run-off water ultimately flows into a river, wetland, lake, and ocean or contributes to the groundwater system. Delineation (of a wetland): To determine the boundary of a wetland based on soil, vegetation and/or hydrological indicators. Ecoregion: An ecoregion is a "recurring pattern of ecosystems associated with characteristic combinations of soil and landform that characterise that region”. Facultative species: Species usually found in wetlands (76%-99% of occurrences) but occasionally found in non- wetland areas Fluvial: Resulting from water movement. Gleying: A soil process resulting from prolonged soil saturation which is manifested by the presence of neutral grey, bluish or greenish colours in the soil matrix. Groundwater: Subsurface water in the saturated zone below the water table. Hydromorphic soil: A soil that in its undrained condition is saturated or flooded long enough to develop anaerobic conditions favouring the growth and regeneration of hydrophytic vegetation (vegetation adapted to living in anaerobic soils). Hydrology: The study of the occurrence, distribution and movement of water over, on and under the land surface. Hydrophyte: Any plant that grows in water or on a substratum that is at least periodically deficient of oxygen as a result of soil saturation or flooding; plants typically found in wet habitats. Intermittent flow: Flows only for short periods. Indigenous vegetation: Vegetation occurring naturally within a defined area. Mottles: Soils with variegated colour patterns are described as being mottled, with the “background colour” referred to as the matrix and the spots or blotches of colour referred to as mottles. Obligate species: Species almost always found in wetlands (>99% of occurences). Perched water table: The upper limit of a zone of saturation that is perched on an unsaturated zone by an impermeable layer, hence separating it from the main body of groundwater Perennial: Flows all year round. RDL (Red Data listed) species: Organisms that fall into the Extinct in the Wild (EW), critically endangered (CR), Endangered (EN), Vulnerable (VU) categories of ecological status Seasonal zone of wetness: The zone of a wetland that lies between the Temporary and Permanent zones and is characterised by saturation from three to ten months of the year, within 50cm of the surface Temporary zone of wetness: the outer zone of a wetland characterised by saturation within 50cm of the surface for less than three months of the year Watercourse: In terms of the definition contained within the National Water Act, a watercourse means:  A river or spring;  A natural channel which water flows regularly or intermittently;  A wetland, dam or lake into which, or from which, water flows; and  Any collection of water which the Minister may, by notice in the Gazette, declare to be a watercourse;  and a reference to a watercourse includes, where relevant, its bed and banks Wetland Vegetation (WetVeg) Broad groupings of wetland vegetation, reflecting differences in regional context, such as geology, type: climate, and soils, which may in turn have an influence on the ecological characteristics and functioning of wetlands.

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ACRONYMS

BAR Basic Assessment Report BAS Best Attainable State BGIS Biodiversity Geographic Information Systems °C Degrees Celsius. CBA Critical Biodiversity Area C-Plan Conservation Plan CVB Channelled Valley Bottom DWA Department of Water Affairs DWAF Department of Water Affairs and Forestry DWS Department of Water and Sanitation EAP Environmental Assessment Practitioner EC Ecological Class or Electrical Conductivity (use to be defined in relevant sections) EIA Environmental Impact Assessment EIS Ecological Importance and Sensitivity EMP Environmental Management Program ERPM East Rand Proprietary Mines ESA Ecological Support Area EWR Ecological Water Requirements FEPA Freshwater Ecosystem Priority Areas GDARD Gauteng Department of Agriculture and Rural Development GIS Geographic Information System GN Government Notice GPS Global Positioning System HGM Hydrogeomorphic HSS Hillslope Seep m Meter MAP Mean Annual Precipitation NEMA National Environmental Management Act NFEPA National Freshwater Ecosystem Priority Areas NWA National Water Act PCD Pollution Control Dam PES Present Ecological State REC Recommended Ecological Category RQIS Research Quality Information Services SACNASP South African Council for Natural Scientific Professions SANBI South African National Biodiversity Institute SANParks South African National Parks SA RHP South Africa River Health Programme SAS Scientific Aquatic Services SQR Sub quaternary catchment reach subWMA Sub-Water Management Area WetVeg Groups Wetland Vegetation Groups WMA Water Management Areas WMS Water Management System WRC Water Research Commission WRD Waste Rock Dump WULA Water Use License Application

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1 INTRODUCTION

1.1 Background

In order to identify all watercourses that may potentially be impacted by the proposed ERPM expansion, a 500m “zone of investigation” around the proposed ERPM expansion, in accordance with Government Notice (GN) 509 of 2016 as it relates to the National Water Act, 1998 (Act No. 36 of 1998), was used as a guide in which to assess possible sensitivities of the receiving freshwater environment. This area – i.e. the 500m zone of investigation around the proposed ERPM expansion - will henceforth be referred to as the “investigation area”.

The purpose of this report is to define the ecology of the area in terms of watercourse characteristics, including mapping of the watercourses, defining areas of increased Ecological Importance and Sensitivity (EIS), and to define the Present Ecological State (PES) of the watercourses associated with the proposed ERPM expansion. Additionally, this report aims to define the socio-cultural and ecological service provision of the watercourses and the Recommended Management Objectives (RMO) and Recommended Ecological Category (REC) for the watercourses. It is a further objective of this study to provide detailed information when considering the proposed ERPM expansion in the vicinity of the watercourses, to ensure the ongoing functioning of the ecosystem, such that local and regional conservation requirements and the provision of ecological services in the local area are supported while considering the need for sustainable economic development.

The Department of Water and Sanitation (DWS) Risk Assessment Matrix (2016) as it relates to activities as stipulated in Section 21(c) and (i) of the National Water Act, 1998 (Act No. 36 of 1998) was applied to determine the significance of the perceived impacts associated with the proposed ERPM expansion, and the operational activities impact on the receiving freshwater environment. In addition, mitigatory measures were developed which aim to minimise the perceived impacts associated with the proposed ERPM expansion, followed by

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an assessment of the significance of the impacts after mitigation, assuming that they are fully implemented.

This report, after consideration and a description of the ecological integrity of any watercourses associated with the proposed ERPM expansion, must guide the relevant authorities, by means of a reasoned opinion and recommendations, as to the viability of the proposed ERPM expansion from a watercourse management point of view.

1.2 Scope of Work

Specific outcomes in terms of this report are outlined below:  A background study of relevant national, provincial and municipal datasets (such as the National Freshwater Ecosystem Priority Areas [NFEPA] 2011 database; the Department of Water and Sanitation Research Quality Information Services [DWS RQIS PES/EIS], 2014 database and the Gauteng Department of Agriculture and Rural Development [GDARD] Gauteng Conservation Plan, 2011 database) was undertaken to aid in defining the PES and EIS of the watercourses;  All watercourses within the investigation area were delineated using desktop methods in accordance with GN509 of 2016 as it relates to activities as stipulated in Section 21 (c) and (i) of the National Water Act, 1998 (Act No. 36 of 1998) and verified according to the “Department of Water Affairs and Forestry (DWAF)1 (2005)2: A practical field procedure for identification of wetlands and riparian areas”. Aspects such as soil morphological characteristics, vegetation types and wetness were used to verify the watercourses;  The watercourse classification assessment was undertaken according to the Classification System for Wetlands and other Aquatic Ecosystems in South Africa. User Manual: Inland systems (Ollis et al., 2013);  The EIS of the watercourses was determined according to the method described by Rountree & Kotze (2013);  The PES of the watercourses was determined according to the resource-directed measures guideline of Macfarlane et al. (2008);  The watercourses were mapped according to the ecological sensitivity of each hydrogeomorphic unit in relation to the proposed ERPM expansion. In addition to the

1 The Department of Water Affairs and Forestry (DWAF) was formerly known as the Department of Water Affairs (DWA). At present, the Department is known as the Department of Water and Sanitation (DWS). For the purposes of referencing in this report, the name under which the Department was known during the time of publication of reference material, will be used. 2 Even though an updated manual is available since 2008 (Updated Manual for the Identification and Delineation of Wetlands and Riparian Areas), this is still considered a draft document currently under review.

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watercourse boundaries, the appropriate provincial recommended buffers and legislated zones of regulation were depicted where applicable;  Allocation of a suitable RMO, REC and Best Attainable State (BAS) to the watercourses based on the results obtained from the PES and EIS assessments;  The DWS Risk Assessment Matrix (2016) was applied to identify potential impacts that may affect the watercourses as a result of the proposed ERPM expansion, and to aim to quantify the significance thereof; and  To present management and mitigation measures which should be implemented during the various development phases to assist in minimising the impact on the receiving freshwater environment.

1.3 Assumptions and Limitations

The following assumptions and limitations are applicable to this report:  All watercourses identified within 500m of the proposed ERPM expansion were delineated in fulfilment of GN509 as it relates to the National Water Act, 1998 (Act No. 36 of 1998) using desktop methods and verification thereof undertaken according to “Department of Water Affairs and Forestry (DWAF) (2008): Updated Manual for the Identification and Delineation of Wetlands and Riparian Areas”. The general surroundings were considered in the desktop assessment of the study area;  Due to the degree to which the site has been disturbed, the watercourse delineations as presented in this report are regarded as a best estimate of the watercourse boundaries, based on the site conditions present at the time of assessment. Global Positioning System (GPS) technology is inherently inaccurate and some inaccuracies due to the use of handheld GPS instrumentation may occur however, the delineations as provided in this report are deemed accurate enough to fulfil the authorisation requirements as well as implementation of the mitigation measures provided. If more accurate assessments are required, the watercourses will need to be surveyed and pegged according to surveying principles;  Freshwater and terrestrial zones create transitional areas where an ecotone is formed as vegetation species change from terrestrial to obligate/facultative species. Within this transition zone, some variation of opinion on the watercourse boundary may occur. However, if the DWAF (2008) method is followed, all assessors should get largely similar results; and  With ecology being dynamic and complex, certain aspects (some of which may be important) may have been overlooked. However, it is expected that the proposed

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ERPM expansion activities have been accurately assessed and considered, based on the field observations in terms of freshwater ecology.

1.4 Legislative Requirements and Provincial Guidelines

The following legislative requirements and relevant provincial guidelines were taken into consideration during the assessment. A detailed description of these legislative requirements is presented in Appendix B:  The Constitution of the Republic of South Africa, 1996 (Act No. 108 of 1996);  The National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA);  The National Water Act, 1998 (Act No. 36 of 1998) (NWA);  Government Notice 509 as published in the Government Gazette 40229 of 2016 as it relates to the National Water Act, 1998 (Act No. 36 of 1998);  Government Notice 704 as published in the Government Gazette 20119 of 1999 as it relates to the National Water Act, 1998 (Act No. 36 of 1998) regarding the use of water for mining and related activities aimed at the protection of water resources; and  The Gauteng Department of Agriculture and Rural Development (GDARD) Requirements for Biodiversity Assessments, Version 3 (GDARD, 2014).

2 PROJECT DESCRIPTION

ERPM holds a prospecting right for the ERPM Extension 1 area, which ERPM intends to convert into a mining right and plans to consolidate the underground resources. In order to do so, this would require the development of the Windmill Shaft (a twin shaft including both access and vent shafts) and the Witpoortjie Vent Shaft (an existing ventilation shaft to be refurbished) to allow access to the underground operations. For the purposes of this study, the proposed ERPM expansion comprises the development of the Windmill and Witpoortjie Vent shafts.

Both shafts are situated within the suburb of Brakpan, with the Windmill Shaft situated approximately 1.5km south of the M43 motorway and the Witpoortjie Vent Shaft situated approximately 1.1km east of the R23 (Heidelberg Road). The Witpoortjie Vent Shaft is located approximately 6.3km east of the Windmill Shaft (Figure 1 and 2).

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Figure 1: A digital satellite image depicting the location of the ERPM expansion and investigation area in relation to the surrounding environment.

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Figure 2: The ERPM expansion and investigation area depicted on a 1:50 000 topographical map in relation to the surrounding environment.

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3 ASSESSMENT APPROACH

3.1 Watercourse Field Verification

For the purposes of this investigation, the definition of a watercourse and a wetland were taken as per that in the National Water Act, 1998 (Act No. 36 of 1998). The definitions are as follows:

A watercourse means: (a) a river or spring; (b) a natural channel in which water flows regularly or intermittently; (c) a wetland, lake or dam into which, or from which, water flows; and (d) any collection of water which the Minister may, by notice in the Gazette, declare to be a watercourse, and a reference to a watercourse includes where relevant, its bed and banks.

Wetland habitat is “land which is transitional between terrestrial and aquatic systems where the water table is usually at or near the surface, or the land is periodically covered with shallow water, and which land in normal circumstances supports or would support vegetation typically adapted to life in saturated soil.”

A field assessment was undertaken in May 2019, during which the presence of any freshwater characteristics as defined by DWAF (2008) and by the National Water Act, 1998 (Act No. 36 of 1998), were noted (please refer to Section 4 of this report). The watercourse delineation took place, as far as possible, according to the method presented in “A practical field procedure for identification and delineation of wetlands and riparian areas” published by DWAF in 20053. The foundation of the method is based on the fact that watercourses have several distinguishing factors including the following:  Landscape position;  The presence of water at or near the ground surface;  Distinctive hydromorphic soils; and  Vegetation adapted to saturated soils.

In addition to the delineation process, a detailed assessment of the watercourses associated with the proposed ERPM expansion was undertaken, whereby factors affecting the integrity

3 Even though an updated manual is available since 2008 (Updated Manual for the Identification and Delineation of Wetlands and Riparian Areas), this is still considered a draft document currently under review.

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of the watercourses were taken into consideration and aided in the determination of the functioning as well as the provision of ecological and socio-cultural services by the watercourses. A detailed explanation of the methods of assessment undertaken is provided in Appendix C of this report.

3.2 Sensitivity Mapping

The watercourses associated with the proposed ERPM expansion were delineated with the use of a Global Positioning System (GPS). Geographic Information System (GIS) was used to project the features onto digital satellite imagery and topographic maps. The sensitivity maps presented in Section 5.3 should guide the design and layout of the proposed ERPM expansion.

3.3 Risk Assessment and Recommendations

Following the completion of the assessment, the DWS risk assessment was conducted (please refer to Appendix D for the method of approach) and recommendations were developed to address and mitigate impacts associated with the proposed ERPM expansion. These recommendations also include general ‘best practice’ management measures, which apply to the proposed ERPM expansion as a whole, and which are presented in Appendix F. Mitigation measures have been developed to address issues in all phases throughout the life of the operation including planning, construction and operation. The detailed site-specific mitigation measures are outlined in Section 6 of this report.

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4 RESULTS OF THE DESKTOP ANALYSIS

4.1 Analyses of Relevant Databases

The following section contains data accessed as part of the desktop assessment and are presented as a “dashboard style” report below (Table 1). The dashboard report aims to present concise summaries of the data on as few pages as possible to allow for integration of results by the reader to take place.

It is important to note that although all data sources used provide useful and often verifiable, high quality data, the various databases used do not always provide an entirely accurate indication of the ERPM expansion area’s actual site characteristics at the scale required to inform the environmental authorisation and/or water use licencing processes. However, this information is considered to be useful as background information to the study. Thus, this data was used as a guideline to inform the assessment and to focus on areas and aspects of increased conservation importance.

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Table 1: Desktop data relating to the character of the watercourses associated with the proposed ERPM expansion. Aquatic ecoregion and sub-regions in which the proposed ERPM expansion area is located Detail of the proposed ERPM expansion area in terms of the Gauteng Conservation Plan (C-Plan V3.3, 2011) Ecoregion Highveld The eastern portion of the Witpoortjie Vent Shaft is situated within a CBA considered Catchment Vaal Critical important for “Orange” listed plant habitat, “Red” listed bird habitat and for primary vegetation. Quaternary Catchment C22C Biodiversity CBAs are considered to be 'best design' areas where options exist for meeting biodiversity WMA Vaal Area (CBA) targets, but where the identified network meets the targets in a spatially efficient and (Figure 6) ecologically robust way that avoids conflict with other land uses where possible. No CBAs subWMA Downstream Vaal Dam are located within the Windmill Shaft. Detail of the proposed ERPM expansion area in terms of the National Freshwater Ecosystem Ecological The western portion of the Witpoortjie Vent Shaft falls within an ESA. ESAs are natural, near- Priority Area (NFEPA) (2011) database Support Area natural, degraded or heavily modified areas required to be maintained in an ecologically (ESA) (Figure functional state to support CBAs and/or Protected Areas (PA). No ESAs are located within The study area is located within a subWMA currently not considered FEPACODE 6) the Windmill Shaft. important in terms of fish or freshwater conservation. According the Gauteng C-Plan, no river or wetland buffers are indicated within the Windmill According to the NFEPA database, no wetlands are associated with the Wetland and Shaft; however, a small portion of the Witpoortjie Vent Shaft, located along the eastern NFEPA Windmill Shaft; however, a single natural seep wetland and a single artificial River Buffers boundary, traverses a wetland buffer. Additionally, A non-perennial river buffer, wetland Wetlands seep wetland are indicated within the investigation area of the Witpoortjie (Figure 5) buffer and waterbodies are located within the southern portion of the Witpoortjie Vent Shaft (Figure 3) Vent Shaft. Both seep wetlands have been considered by the NFEPA investigation area. database as heavily to critically modified. Although rescinded as a policy document in the Gauteng Spatial Development Framework Both proposed shafts are situated within the Mesic Highveld Grassland Group Wetland in 2011, the Urban Edge nevertheless remains a useful indicator of where concentration of 2 (critically endangered), while the north western portion of the investigation development should occur. According to the Gauteng C-Plan (2011), both shafts are located Vegetation Urban Area area of the Windmill Shaft falls within the Dry Highveld Grassland Group 5 outside of the urban edge. Additionally, according to the Gauteng Environmental Type (Figure 4) (Figure 7) (least threatened). The threat statuses were provided by Mbona et al. (2014). Management Framework (EMF, 2015), the Windmill Shaft is situated within the Normal Control Zone (Zone 4), while the Witpoortjie Vent Shaft falls predominantly within the High Control Zone outside the Urban Development Zone (Zone 3). According to the NFEPA Database, no NFEPA rivers are indicated within the NFEPA Rivers Underlying Geology of the ERPM expansion area (Figure 8) Windmill or Witpoortjie Shafts, nor within the investigation area. The Rietspruit (Figure 3) The Witpoortjie Vent Shaft and the eastern portion of the Windmill Shaft are underlain by sandstone, greywacke River is located approximately 1.1km south east of the Windmill Shaft. and arkose formations, while the western portion of the Windmill Shaft is underlain by limestone and other carbonate rocks. Dominant characteristics of the Highveld Ecoregion Level 2 (11.01 & 11.03) (Kleynhans et al., 2007) Level II Code 11.01 11.03 Dominant primary terrain morphology Plains; low relief Plains; low and moderate relief, few hills Dominant primary vegetation types Rocky Highveld Grassland, Mixed Bushveld Moist Cool Highveld Grassland Altitude (m a.m.s.l) 1300 to 1900 1300 to 2100 MAP (mm) 500 to 700 400 to 800 Coefficient of Variation (% of MAP) 20 to 34 20 to 34 Rainfall concentration index 55 to 64 45 to 64 Rainfall seasonality Early to mid-summer Early to late summer Mean annual temp. (°C) 14 to 18 12 to 18

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Winter temperature (July) 0 to 20 -2 to 18 Summer temperature (Feb) 12 to 30 10 to 28 Median annual simulated runoff (mm) 30 to 60 5 to 10 (limited); 10 to 150 Ecological Status of the most proximal sub-quaternary reach (DWS, 2014) (Figure 9) Sub-quaternary reach C22C – 01381 (Rietspruit River) C22C – 01405 (Tributary of Rietspruit River) Proximity to ERPM expansion area Approximately 2.4km east of the Windmill Shaft Approximately 3.2km south of the Witpoortjie Vent Shaft Assessed by expert? Yes Yes PES Category Median Seriously Modified (Class E) Largely Modified (Class D) Mean Ecological Importance (EI) Class Low Moderate Mean Ecological Sensitivity (ES) Class Moderate Moderate Stream Order 1 1 Default Ecological Class (based on median PES and highest EI or ES mean) Moderate (Class C) Moderate (Class C) CBA = Critical Biodiversity Areas; DWS = Department of Water and Sanitation; EI = Ecological Importance; EMF = Environmental Management Framework; ES = Ecological Sensitivity; ESA = Ecological Support Area; FEPA = Freshwater Ecosystem Priority Area; m.a.m.s.l = Meters Above Mean Sea Level; MAP = Mean Annual Precipitation; NFEPA = National Freshwater Ecosystem Priority Areas; WMA = Water Management Area.

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Figure 3: The wetlands and rivers associated with the proposed ERPM expansion according to the NFEPA Database (NFEPA, 2011).

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Figure 4: The wetland vegetation types associated with the proposed ERPM expansion.

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Figure 5: The river and wetland buffers associated with the proposed ERPM expansion according to the Gauteng C-Plan V3.3 (2011).

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Figure 6: CBAs and ESAs associated with the proposed ERPM expansion according to the Gauteng C-Plan V3.3 (2011).

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Figure 7: Gauteng Environmental Management Framework zones (EMF, 2015) associated with the proposed ERPM expansion.

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Figure 8: Underlying geology associated with the proposed ERPM expansion.

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Figure 9: Relevant sub-quaternary catchment reach (SQR) associated with the proposed ERPM expansion.

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5 RESULTS: WATERCOURSE ASSESSMENT

5.1 Watercourse Delineation

Due to the degree to which the site has been disturbed, the watercourse delineations as presented in this report are regarded as a best estimate of the watercourse boundaries based on the site conditions present at the time.

During the assessment, the following indicators were used to delineate the boundary of the temporary wetland zone:  Topography/elevation was used to determine in which parts of the landscape the watercourses were most likely to occur;  Obligate and facultative wetland species were used in conjunction with terrain units as well as the point where a distinct change in the vegetation composition was observed to determine the wetland zone boundary (Figure 10); and  The soil form indicator was used to determine whether wetland characteristics were present within the ERPM expansion (Windmill and Witpoortjie Shafts) and investigation area. In order to confirm the presence of a wetland, the soil needs to present redoxymorphic soil features, which are morphological signatures that appear in soils with prolonged periods of saturation and water level fluctuation (due to the resultant anaerobic conditions). These redoxymorphic soil features would be identifiable in the soil irrespective of the season in which the soil sample is taken, as they are not determined by how ‘wet’ the soil is, but rather by the mottling or signs of gleying that has occurred over a period of time within the soil (Figure 10).

Figure 10: Distinct mottling (left) and obligate wetland species (Schoenoplectus brachyceras), (right) used to aid in the delineation of the watercourses.

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5.2 Watercourse System Characterisation

In preparation for the field assessment, digital satellite imagery and provincial and national watercourse databases (as outlined in Section 4 of this report) were used to identify areas of interest at a desktop level. During the site assessment undertaken on the 9th of May 2019, a single watercourse was identified within the investigation area of the Windmill Shaft, a Hillslope Seep (HSS) wetland, while a single watercourse, a Channelled Valley Bottom (CVB) wetland, was identified within the investigation area of the Witpoortjie Vent Shaft. The HSS wetland associated with the Windmill Shaft is located along the northern boundary of the investigation area and drains in a northerly direction. The CVB wetland associated with the Witpoortjie Vent Shaft is located within the eastern and southern portions of the investigation area and drains in a south westerly direction towards an unnamed tributary of the Rietspruit River. The locality of the HSS and CVB wetlands in relation to the proposed ERPM expansion is depicted in Figures 11 and 12.

The identified wetlands were characterised according to the classification system (Ollis, et al., 2013) as inland systems (i.e. a system having no existing connection to the ocean, but which is inundated or saturated with water, either permanently or periodically), falling within the Highveld Aquatic Ecoregion, and the Mesic Highveld Grassland Group 2 (critically endangered) wetland vegetation (WetVeg) group, as summarised in the table below.

Table 2: Characterisation of the watercourses associated with the proposed ERPM expansion according to the Classification System (Ollis et. al., 2013). Watercourse Level 3: Landscape unit Level 4: HGM Type Valley floor: The base of a valley, Channelled valley-bottom wetland: a valley-bottom wetland CVB Wetland situated between two distinct valley with a river channel running through it. side-slopes. Hillslope Seep: a wetland area located on (gently to steeply) Slope: an included stretch of sloping land, which is dominated by the colluvial (i.e. gravity- ground that is not part of a valley HSS Wetland driven), unidirectional movement of material down-slope. Seeps floor, which is typically located on are often located on the side-slopes of a valley, but they do not, the side of a mountain, hill or valley. typically, extend into a valley floor.

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Figure 11: The delineated HSS wetland associated with the Windmill Shaft.

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Figure 12: The delineated CVB wetland associated with the Witporrtjie Vent Shaft.

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5.2.1 Existing Impacts

The wetlands have been impacted upon by extensive historical and current mining activities within the greater catchment. In some areas of the CVB wetland associated with the Witpoortjie Vent Shaft, it appears that current mining activities have encroached into the boundary of the wetland. Additional impacts to the wetland include the construction of an artificial instream impoundment and an excavated trench and pipelines that traverses the CVB wetland (Figure 13). The HSS wetland has been impacted upon by informal farm roads which traverse the wetland and historical and current agricultural activities within the greater catchment.

Figure 13: An informal road and pipelines traversing the CVB wetland (left); an excavated trench and infilling of an area of the wetland with gravel (red dotted line) (right).

5.3 Field Verification Results

Following the site visit, various assessments were undertaken to determine the following:  PES, incorporating aspects such as hydrology, vegetation and geomorphology;  Service provision of the wetlands, which incorporates biodiversity maintenance, flood attenuation, streamflow regulation and assimilation, to name a few;  The EIS was guided by the results obtained from the assessment of PES and service provision of the wetlands;  An appropriate REC, RMO and BAS to guide the management of the wetlands with the intent of enhancing the ecological integrity of the wetlands, where feasible; and  Assessment of impacts of the construction and operation of the proposed ERPM expansion on the wetlands.

The results of the assessments of the wetlands are presented in the “dashboard style” reports below.

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Table 3: Summary of the assessment of the Channelled Valley Bottom (CVB) wetland associated with the Witpoortjie Vent Shaft.

Photograph Notes

The CVB wetland is well vegetated and although alien invasive plant species such as Arundo donnax (left) and Cortaderia selloana (middle) were present, indigenous wetland vegetation such as Juncus rigidus (left) was observed on site.

PES Category: D (Largely modified) Ecological & socio-cultural service provision graph: The hydrological processes and vegetation of the wetland have undergone the most significant alteration, primarily due to impacts associated with the PES extensive historical and current mining activities in the greater catchment. discussion Additionally, impacts such as informal and municipal road and pipeline crossings have resulted in soil disturbances, leading to proliferation of alien invasive plant species. Thus, the assessed reach of the wetland is deemed to be in a largely modified condition. Intermediate Despite the significantly decreased ecological integrity of the wetland, the wetland still provides an intermediate level of ecoservices. Ecoservices such Ecoservice as streamflow regulation, erosion control and the assimilation of nitrates, provision phosphates and toxicants are provided by the wetland at an intermediate to moderately high level. This is primarily due to characteristics of the wetland such as moderately high surface roughness due to extensive vegetation cover which aid in the provision of these services. Watercourse drivers: EIS Category: Moderate a) Hydrology The results of the EIS assessment indicate that the wetland is deemed to be The wetland is primarily hydrologically driven by overland flow from the greater catchment. The hydrological regime of the wetland has EIS of moderate ecological importance and sensitivity (Category C). This is largely been largely modified, predominantly as a result of modifications to the active channel by the construction of artificial instream discussion attributable to the hydro-functional importance of the system, primarily due to impoundments, as well as increased water inputs from altered runoff patterns in the greater catchment as a result of the extensive mining the ability of the system to regulate streamflow, assimilate nitrates, activities in the area, some of which traverse the wetland. Additional modifiers to the hydrology of the system include the construction of phosphates and toxicants, and to control erosion. informal and municipal road and pipeline crossings which have altered flow patterns. Additionally, a trench has been excavated along the north western boundary of the wetland which has resulted in erosion due to the concentrated flow of water.

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b) Water quality REC Category: D (Largely modified) The following in situ water quality parameters were measured during the site assessment: pH – 7.48; electrical conductivity – 207mS/m; BAS Category: D (Largely modified) and temperature – 12.6°C. According to the Resource Water Quality Objectives (RWQO) of South Africa (DWA, 2011), the pH falls within RMO: D (Maintain) the ideal range limit. The electrical conductivity, however, falls within the unacceptable range limit. It is anticipated that the water quality REC The Recommended Management Objective (RMO) for the wetland based on of the wetland is thus impacted upon by the extensive mining practices, and industrial and residential development in the greater Category the PES and EIS scores is to maintain an ecological Category D (Largely catchment. modified). No further degradation should be permitted and thus, mitigation measures should be implemented during all phases of the proposed ERPM expansion to minimise the risk of further negative impacts on the wetland. c) Topography: Geomorphology and sediment balance The historic construction of artificial impoundments within the active channel of the wetland, as well as infilling and excavation due to mining activities, have had a significant impact on the geomorphological processes of the wetland. Increased water inputs, and thus increased sediment inputs, arising from the road infrastructure that traverse the system has likely resulted in greater sediment loads within Possible significant impacts, Business case, Conclusion and Mitigation Requirements: the wetland. The results of the risk assessment are presented in Section 6 of this report and show that, assuming mitigation measures are strictly enforced, impact significance is of low to moderate levels during both construction and operational phases. It is considered imperative that suitable d) Habitat and biota mitigation measures, as provided for in Section 6 and Appendix F of this report, are strictly The wetland vegetation community is considered to be modified due to proliferation of alien and invasive plant species within the adhered to in order to minimise the impacts associated with the proposed ERPM expansion and permanent, seasonal and temporary zones of the wetland. Despite these modifications to the vegetation community, the wetland is well decrease the significance of cumulative impacts on the CVB wetland. vegetated with various indigenous species such as Phragmites australis, which plays an important ecological role for wetlands as it offers shelter and nesting material for birds and other faunal species. According to the Gauteng C-Plan (2011), the CVB wetland is situated within a CBA considered important for “Orange” listed plant habitat, “Red” listed bird habitat and for primary vegetation.

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Table 4: Summary of the assessment of the hillslope seep (HSS) wetland associated with the Windmill Shaft. Ecological & socio-cultural service provision graph:

PES Category: C (Moderately modified) Representative photographs of the reach of the hillslope seep wetland associated with the proposed ERPM The natural wetland vegetation has undergone the most significant Photograph notes expansion (Windmill Shaft). Note the proposed Windmill Shaft development area is located approximately 400m impacts; however, the hydrological and geomorphological processes of away. the wetland have also been modified. The main modifiers to the wetland Watercourse drivers: PES include impacts associated with historical agricultural practices and the a) Hydrology discussion construction of informal road infrastructure. Additionally, the wetland is It is likely that the wetland is primarily hydrologically driven by hydropedological hillslope processes. Runoff from the surrounding area, mainly located downgradient of and within close proximity to (approximately dominated by open areas which were historically cultivated, enters the wetland. Additionally, it is anticpated that the wetland may receive some 600m) an existing mine which is likely to impact upon the ecological runoff from the mining activities situated upgradient of and in close proximity to (approximately 600m) the wetland, thus altering the hydrological integrity of the wetland. Thus, the assessed reach of the wetland is processes of the wetland. deemed to be in a moderately modified condition. Moderately low b) Water quality Due to the moderately decreased ecological integrity of the wetland, the No surface water was present during the time of assessment and thus, water quality parameters were not measured on site. It is, however, wetland functions at a moderately low level in terms of the provision of anticipated that the water quality of the wetland may likely impacted upon by contaminated runoff in the form of sediment from the surrounding Ecoservice ecological services. Despite this, some ecoservices such as erosion open land, as well as potential contaminants from the existing upgradient mining area. provision control and streamflow regulation are provided by the wetland at an c) Topography: Geomorphology and sediment balance

intermediate level. Characteristics of the wetland such as moderately The historic cultivation of the Windmill Shaft area for agriculture has had a significant impact on the geomorphology of the wetland. Increased high surface roughness due to extensive vegetation cover aid in the water inputs from the surrounding open land, and thus increased sediment inputs, have likely resulted in greater sediment loads within the provision of these services. wetland. EIS Category: Low/marginal d) Habitat and biota The results of the EIS assessment indicate that the wetland is deemed The wetland vegetation community is considered to be modified since alien invasive plant species were present within the wetland. Despite to be of low/marginal ecological importance and sensitivity (Category D). these modifications to the vegetation community, the wetland is well vegetated and is still considered to provide habitat for faunal and floral EIS The wetland is not considered important in terms of direct human species. According to the Gauteng C-Plan (2011), the HSS wetland falls within an ESA, which are natural, near-natural, degraded or heavily discussion benefits. The wetland is, however, considered of low/marginal hydro- modified areas required to be maintained in an ecologically functional state to support CBAs and/or Protected Areas (PA). functional importance due to the ability of the wetland to control erosion and regulate streamflow.

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REC Category: C (Moderately modified) Possible significant impacts, Business case, Conclusion and Mitigation Requirements: BAS Category: C (Moderately modified) Although the HSS wetland is situated within the 500m investigation area around the proposed Windmill Shaft development area, the wetland RMO: Maintain is located approximately 400m north and downgradient of the proposed shaft. Due to the distance between the proposed shaft and the wetland, The Recommended Management Objective (RMO) for the wetland the proposed location of the Windmill Shaft is considered ideal given the position of the wetland in the landscape. REC based on the PES and EIS scores is to maintain an ecological category Category of C. No further degradation should be permitted and thus, mitigation measures should be implemented during all phases of the proposed ERPM expansion to minimise the risk of further negative impacts on the wetland.

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5.4 Sensitivity Mapping

5.4.1 Legislative Requirements, National and Provincial guidelines pertaining to the application of buffer zones

According to Macfarlane et al. (2015) the definition of a buffer zone is variable, depending on the purpose of the buffer zone, however in summary, it is considered to be “a strip of land with a use, function or zoning specifically designed to protect one area of land against impacts from another”. Buffer zones are considered to be important to provide protection of basic ecosystem processes (in this case, the protection of aquatic and wetland ecological services), reduce impacts on water resources arising from upstream activities (e.g. by removing or filtering sediment and pollutants), provision of habitat for aquatic and wetland species as well as for certain terrestrial species, and a range of ancillary societal benefits (Macfarlane et. al, 2015). It should be noted however that buffer zones are not considered to be effective mitigation against impacts such as hydrological changes arising from stream flow reduction, impoundments or abstraction, nor are they considered to be effective in the management of point-source discharges or contamination of groundwater, both of which require site-specific mitigation measures (Macfarlane et. al, 2015).

Legislative requirements were taken into consideration when determining a suitable buffer zone for the wetlands. The definition and motivation for a regulated zone of activity as well as buffer zone for the protection of the wetlands can be summarised as follows:

Table 5: Articles of Legislation and the relevant zones of regulation applicable to each article.

Regulatory authorisation required Zone of applicability  Activity 12 of Listing Notice 1 (GN 327) of the National Environmental Management Act, 1998 (Act No. 107 of 1998) Environmental Impact Assessment (EIA) regulations, 2014 (as amended) states that: The development of: Listed activities in terms of the National Environmental Management Act, 1998 (xii) infrastructure or structures with a physical footprint of 100 (Act No. 107 of 1998) (NEMA) square metres or more; Environmental Impact Assessment (EIA) Where such development occurs— Regulations, 2014 (as amended). The Department of Environmental a) Within a watercourse; Affairs b) In front of a development setback; or c) If no development setback has been adopted, within 32 meters of a watercourse, measured from the edge of a watercourse. In accordance with GN509 of 2016 as it relates to the National Water Act, Water Use License Application in terms of 1998 (Act No. 36 of 1998), a regulated area of a watercourse for Section 21 the National Water Act, 1998 (Act No. 36 (c) and 21 (i) of the National Water Act, 1998 (Act No, 36 of 1998) is defined of 1998) (NWA). as:

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Regulatory authorisation required Zone of applicability The Department of Water and  the outer edge of the 1 in 100 year flood line and/or delineated riparian Sanitation habitat, whichever is the greatest distance, measured from the middle of the watercourse of a river, spring, natural channel, lake or dam;  in the absence of a determined 1 in 100 year flood line or riparian area the area within 100 m from the edge of a watercourse where the edge of the watercourse is the first identifiable annual bank fill flood bench; or  a 500 m radius from the delineated boundary (extent) of any wetland or pan in terms of this regulation. Water Use License Application in terms of In accordance with GN704 of 1999 as it relates to the National Water Act, the National Water Act, 1998 (Act No. 36 1998 (Act No. 36 of 1998), a 100m zone of regulation around the of 1998) (NWA). watercourses is required. If any mining activities are to take place within 100m The Department of Water and or the 1: 100-year flood line of a watercourse, exemption in terms of this Sanitation regulation will apply and therefore a Water Use License will be required. In terms of GDARD Requirements for Biodiversity Assessments (2014), a specific buffer zone is stipulated for watercourses, depending whether it is located within or outside an Urban Area. Although rescinded as a policy document in the Gauteng Spatial Development Framework in 2011, the Urban Edge nevertheless remains a useful indicator of where concentration of Gauteng Department of Agriculture and development should occur. According to the Gauteng C-Plan (2011), the Rural Development Requirements for proposed ERPM expansion is situated outside the Urban Edge. Additionally, Biodiversity Assessments (2014). according to the Gauteng Environmental Management Framework (EMF, 2015), the Windmill Shaft is situated within the Normal Control Zone (Zone 4), while the Witpoortjie Vent Shaft falls predominantly within the High Control Zone outside the Urban Development Zone (Zone 3). Thus, a 50m GDARD setback area is applicable to the CVB and HSS wetlands.

The delineated wetlands and the applicable Zones of Regulation (ZoR) in terms of GN509 of 2016 and GN704 of 1999 as they relate to the National Water Act, 1998 (Act No. 36 of 1998) as well as the relevant GDARD setback areas are conceptually depicted in Figures 14 and 15 below.

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Figure 14: Conceptual presentation of the zone of regulation in terms of GN509 of 2016 and GN704 of 1999 as it relates to the National Water Act, 1998 (Act No. 36 of 1998), and the relevant GDARD setback area in relation to the HSS wetland.

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Figure 15: Conceptual presentation of the zone of regulation in terms of GN509 of 2016 as it relates to the National Water Act, 1998 (Act No. 36 of 1998), and the relevant GDARD setback area in relation to the CVB wetland.

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6 RISK ASSESSMENT

This section presents the significance of potential impacts on the freshwater ecology of the identified wetlands associated with the proposed ERPM expansion (all details are provided in Section 2: Project Description). In addition, it also indicates the required mitigatory measures needed to minimise the perceived impacts of the proposed ERPM expansion and presents an assessment of the significance of the impacts taking into consideration the available mitigatory measures and assuming that they are fully implemented.

No layout plan of the proposed ERPM expansion (comprising the development of the Windmill and Witpoortjie Vent Shafts) was available at the time of assessment. However, the risk assessment was based on the assumption that no development (location of shafts, access roads or other relevant services required) will take place within the wetlands or the associated 100m GN704 Zone of Regulation. However, it is still imperative that strict mitigation measures be implemented throughout all phases of the proposed ERPM expansion in order to reduce the impact significance of associated activities on the receiving freshwater environment.

6.1 Risk Analyses

6.1.1 Consideration of impacts and application of mitigation measures

Following the assessment of the wetlands, the DWS approved Risk Assessment Matrix (2016) was applied to ascertain the significance of perceived impacts on the key drivers and receptors (hydrology, water quality, geomorphology, habitat and biota) of the wetlands associated with the proposed ERPM expansion. These results are summarised in Table 6 presented in Section 6.1.2 of this report.

Following the risk assessment, mitigation measures were compiled to serve as guidance throughout the construction and operational phases. The points below summarise the considerations undertaken:  The risk assessment was applied assuming that a high level of mitigation is implemented, thus the results of the risk assessment provided in this report presents the perceived impact significance post-mitigation;  In applying the risk assessment, it was assumed that the mitigation hierarchy as advocated by the Department of Environmental Affairs (DEA) et al (2013) would be followed, i.e. the impacts would be avoided, minimised if avoidance is not feasible, rehabilitated as necessary and offset if required;

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 At the time of this assessment, the assessed reaches of the wetlands associated with the proposed ERPM expansion were considered to be in a moderately to largely modified ecological state, and of low/marginal to moderate importance and sensitivity;  The activities are all highly site specific, not of a significant extent relative to the area of the wetlands assessed, and therefore have a limited spatial extent;  While the operation of the proposed ERPM expansion will be a permanent activity, the construction thereof is envisioned to take no more than a few months. However, the frequency of the construction impacts may be daily during this time;  Most impacts are considered to be easily detectable;  The considered mitigation measures are easily practicable;  It is highly recommended that the proponent make provision for small-scale rehabilitation of the reaches of the wetland which may be directly impacted upon by the proposed ERPM expansion. The area must preferably be rehabilitated to conditions as close as possible to the “natural” state, not the pre-construction state since the state of the wetlands is deemed to be altered from a reference condition. This will ensure that the current levels of ecological service provision of the wetlands are maintained and where feasible, improved; and  Since no geohydrological data specifically pertaining to the proposed ERPM expansion were available at the time of the compilation of this report, the risk significance of decant was not assessed in detail as part of this study.

6.1.2 Impact discussion and essential mitigation measures

There are four key ecological impacts on the wetlands that are anticipated to occur, namely:  Loss of wetland habitat and ecological structure;  Changes to the sociocultural and service provision;  Impacts on the hydrology and sediment balance of the wetlands; and  Impacts on water quality.

Various activities and development aspects may lead to these impacts, however, provided that the mitigation hierarchy is followed, these impacts can be avoided or adequately minimised where avoidance is not feasible. The mitigation measures provided in this report have been developed with the mitigation hierarchy in mind, and the implementation of and strict adherence to these measures will assist in minimising the significance of impacts on the receiving freshwater environment. A summary of the risk assessment is provided in the table below, followed by a discussion of the outcome thereof.

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Table 6: Summary of the results of the risk assessment applied to wetlands associated with the proposed ERPM expansion.

No. Activity Aspect Impact Mitigation Measures to be implemented

Phase

Severity

Likelihood

Risk Rating

Significance

Consequence *Construction should be initiated by first constructing clean and dirty water separation systems thus ensuring Site preparation prior that as site clearing takes place, dirty water runoff is to construction *Runoff with high sediment loads entering the appropriately managed (refer to Activities 3 and 6); activities related to *Vehicular movement and wetlands as a result of exposed soil from *Limit clearing of vegetation and associated soil the proposed new access to the site; cleared areas, smothering the wetland disturbances to essential areas only (outside of the Windmill Shaft and *Removal of terrestrial vegetation and thus altering the habitat of the wetlands and 100m GN704 Zone of Regulation); the rehabilitation of vegetation and associated wetlands, leading to areas within the wetlands *Protect exposed soils by means of a geotextile such as the existing disturbances (rubble and more suited to terrestrial vegetation; hessian sheeting; 1 Witpoortjie Vent litter) to soil; and *Compaction of soil due to the movement of 1.75 4.75 11 52.3 L *Ensure contractor laydown areas are placed outside of Shaft, including *Possible unplanned and construction machinery leading to alterations the wetlands and the associated 100m GN704 Zone of proposed surface uncontrolled movement of of runoff patterns into the wetlands; Regulation. A designated area should be approved by the infrastructure, and construction machinery *Proliferation of alien vegetation as a result of Environmental Control Officer (ECO) prior to use;

the placement of through the CVB and HSS disturbances; and *Ensure that indiscriminate vehicle driving does not occur contractor laydown wetland. *Vegetation degradation, and the subsequent within the wetlands or the 100m GN704 Zone of areas and storage loss of habitat for wetland species. Regulation; and facilities. *Dust suppression measures must be implemented throughout construction to prevent excessive dust which may smother wetland vegetation. *Movement of construction *No construction may take place within the wetlands or

Construction Phase *Loss of wetland habitat and ecological machinery within the 100m 100m GN704 Zone of Regulation. Additionally, the structure as a result of edge effects associated GN704 Zone of Regulation wetlands and 100m GN704 Zone of Regulation must be with the ERPM expansion; (HSS wetland); demarcated as a no-go area; *Impacts to the ecoservice provision of the Construction of *Ground-breaking and *No indiscriminate movement of machinery or personnel wetland; surface infrastructure earthworks relating to is allowed within the wetlands or associated 100m GN704 *Potential impacts on the hydrology and associated with the foundations; Zone of Regulation. Careful planning of all construction sedimentation of the wetland, leading to 2 Windmill Shaft, such *Mixing and casting of 1.5 4.5 12 54 L machinery must be undertaken beforehand to ensure that alteration of the flood regime; as buildings, concrete for construction the minimum impact on the wetlands occur; *Potential impacts on the water quality of structures and purposes; *No stockpiles are to be permitted within the 100m runoff which may potentially enter the internal roads. *Stockpiling of construction GN704 Zone of Regulation; downgradient wetland and contamination of materials; *Exposed soil and stockpiles must be protected from wind soils due to concrete being cast; and *Creation of a topsoil by covering with a suitable geotextile such as hessian *Proliferation of alien and invasive plant stockpile and a Waste sheeting; species within the wetlands. Rock Dump (WRD); *Ensure no stockpiles are higher than 2m;

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No. Activity Aspect Impact Mitigation Measures to be implemented

Phase

Severity

Likelihood

Risk Rating

Significance

Consequence *Increased likelihood of *Any concrete mixing/temporary storage must be dust generation due to undertaken in bunded areas or on batter boards only. exposed soils; and Care must be taken to prevent any spillage within the *Changes to stormwater wetlands or surrounding environment; runoff in the landscape as *Dust suppression measures must be implemented a result of construction throughout construction to prevent excessive dust which activities and increased may smother wetland vegetation; and impermeable surfaces. *Strict monitoring of the footprint area and the height of *Movement of construction the Waste Rock Dumps (WRDs) should be implemented Construction of machinery within the 100m to prevent encroachment thereof into the 100m GN704 surface infrastructure GN704 Zone of Regulation Zone of Regulation or into the wetland, particularly in the associated with the (CVB wetland); case of the Witpoortjie Shaft, where the eastern portion Witpoortjie Vent *Stockpiling of construction of the shaft surface development area falls within the Shaft, including materials; 100m GN704 Zone of Regulation of the CVB wetland. refurbishment of the *Increased likelihood of 1.5 4.5 10 45 L existing ventilation dust generation due to shaft, surface exposed soils; and ventilation fans, an *Changes to stormwater access road and a runoff in the landscape as generator and a result of construction compressor. activities and increased impermeable surfaces. *Clean and dirty water areas should be kept separate at Loss of catchment yield resulting from all times; stormwater containment, leading to: *Dirty water areas should be kept as small as possible *Increased flood peaks as a result of and should be expanded progressively to ensure that the *Ground-breaking formalisation and concentration of surface volume of clean surface runoff supplying the wetlands is associated with the runoff in clean water diversion structures; optimised; Development of clean excavation of trenches; *Potential for erosion, leading to *The dirty water systems should be adequately sized as 3 and dirty water *Removal of topsoil; and 1.75 6.75 13 87.8 M sedimentation of the wetlands; per the GN704 Regulatory Requirements, to prevent separation systems. *Excavation activities *Reduction in volume of water entering the failure thereof and ultimately, discharge of contaminated leading to the stockpiling of wetlands, leading to loss of recharge of the water into the wetlands; soil. wetlands; and *Any Pollution Control Dams (PCDs) must have capacity *Altered vegetation community structure and to cater for a 1:50 year flood occurring over a 24-hour diversity due to moisture stress. period and the PCDs must be lined with an appropriate liner;

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No. Activity Aspect Impact Mitigation Measures to be implemented

Phase

Severity

Likelihood

Risk Rating

Significance

Consequence *Clean water captured in the clean water system should be returned back into the surrounding wetland systems. However, the wetlands must be protected against erosion arising from the discharge of clean water; *The clean water outlet should be constructed with the use of energy dissipating structures to slow down the velocity of water inflow into the wetland; and *After construction of the outlet, the area surrounding the outlet should be re-seeded with indigenous wetland vegetation. *Potential subsidence of surrounding environment if pillars are insufficient to support *No stockpiles are to be permitted within the 100m the ground; GN704 Zone of Regulation; *Potential creation of a cone of depression, *Exposed soil and stockpiles must be protected from wind *Excavation, drilling and Sinking of the which may drain water from surrounding by covering with a suitable geotextile such as hessian blasting in order to sink the Windmill Shafts, and wetland habitats, thus resulting in desiccation sheeting; shafts, leading to associated removal of the wetlands; *Ensure no stockpiles are higher than 2m; 4 stockpiling of rock and 1 4 11 44 L of waste material and *Water entering the shafts as a result of *Excavated materials should not be contaminated and topsoil; and other excavated ingress may necessitate dewatering of the mixture of the lower and upper layers of the excavated *Operation of construction materials. shafts, which may result in the discharge of soil should be kept to a minimum; and equipment on site. dirty water into the surrounding wetland *All exposed soil must be protected for the duration of the environment; construction phase in order to prevent erosion and *Potential spillage of oils/hydrocarbons from sedimentation of the downgradient wetlands. construction vehicles.

*Nitrates from blasting leaching from the WRD, leading to eutrophication of the *Pollution prevention through infrastructure design, to receiving environment and resulting in loss of prevent, eliminate and/or control potential pollution of Operation of the *Below-ground blasting potable water within the catchment; and soils, groundwater and surface water should be 5 Windmill and and storage of waste rock *Increased risk of pollution of surface water 2.25 6.25 16 100 M implemented; and Witpoortjie Shafts. within the WRD. and groundwater, which may affect the *A monitoring programme to detect, manage and prevent wetland areas, leading to impaired water the pollution of soils, surface water and groundwater, as

Operational Phase quality and 36ormalizatio of soils within the well as wetland monitoring, should be implemented. wetlands.

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No. Activity Aspect Impact Mitigation Measures to be implemented

Phase

Severity

Likelihood

Risk Rating

Significance

Consequence *Proactive monitoring to ensure structural integrity is *The potential failure of the PCD infrastructure maintained; may result in leakages and possible *It is recommended that the infrastructure be regularly Operation of the PCD contamination of surface and groundwater, inspected for leaks, or more often should there be any associated with the increased flow into the HSS wetland, and 2.5 6.5 16 104 M sign or reports of a leak; and Windmill Shaft. lowered water quality (increase in salts and *Should leakage occur all possible steps are to be taken specific contaminants of concern and reduced to prevent the pollution of the downgradient wetland pH) within the wetland. systems during repair. *The operation of the shafts may result in the formation of a cone of depression, pulling water towards the shafts over time; *Impacts to the hydrological processes of the *Any areas where decant points may be determined by a wetlands due to removal of interflow soils; geohydrological assessment, need to be carefully *Potential creation of a *Changes in wetland hydroperiod and managed throughout the life of the operation; cone of depression; vegetation structure; *Water levels need to be strictly managed to ensure they *Dewatering of the shafts; *As a result of dewatering, contaminated water are kept below any decant level while ensuring that a and 2.75 6.75 16 108 M may enter the receiving environment leading significant cone of depression impact does not take place; *Potential decant from the to altered water quality; and and shafts to the receiving *Alteration (increase) of flow regimes, *If decant does occur, all water is to be treated to the freshwater environment. reduction in water quality (increase in salts background water quality values prior to release into the and specific contaminants of concern and receiving freshwater environment. reduced pH) and subsequent loss of biodiversity of the wetlands due to decant of contaminated water. Loss of catchment yield due to stormwater *Containment/diversion of containment is expected to occur, which could *The clean and dirty water separation systems should be runoff into the clean and lead to the following impacts: regularly inspected to ensure that there is no mixing of dirty water system; *Increased flood peaks into the wetlands as a clean and dirty water and that the systems are functioning Operation of the *Discharge of clean water result of 37ormalization and concentration of efficiently; and 6 clean and dirty water into the surrounding 1.25 4.25 12 51 L surface runoff; *The energy dissipating structures at the clean water separation systems. wetland systems; and *Potential for erosion of terrestrial areas as a outlets should be regularly inspected to ensure that the *Potential of result of the formation of preferential flow release of clean water into the wetlands has not resulted malfunctioning of the dirty paths, leading to sedimentation of the in erosion. water system. wetlands;

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No. Activity Aspect Impact Mitigation Measures to be implemented

Phase

Severity

Likelihood

Risk Rating

Significance

Consequence *Reduction in volume of water entering the wetlands, leading to loss of recharge (and thus potential desiccation) of the wetland systems; *Erosion and sedimentation of the wetlands at the outlet of the clean water trench; and *Altered vegetation communities due to moisture stress. *A site-specific rehabilitation plan, including an alien invasive plant (AIP) management plan, must be compiled and implemented. AIPs should be removed by hand and Rehabilitation of the *Re-vegetation of the *Temporarily altered flow regime, leading to no machinery should be allowed in the wetlands; wetlands and 100m wetland and 100m GDARD possible loss of recharge to downgradient *The 100m GN704 Zone of Regulation must be GN704 Zones of 7 setback area and removal areas, impacting on downgradient biota; and 1.5 4.5 10 45 L rehabilitated with indigenous vegetation, thus reinstating Regulation of construction material *Possible sedimentation of downgradient faunal and floral habitats. This will ensure that the current associated with the and waste. areas. levels of ecological service provision of the wetlands are shafts. maintained and where feasible, improved; and *No hard infrastructure should be allowed below the 100m GN704 Zone of Regulation.

*The final backfilled landscape should be free draining so as to allow recharge of the wetlands in the landscape and *Sealing and backfilling of the greater catchment. The post-closure recharge of the the shafts; *Compaction of soils due to vehicular catchment should also be as near natural as possible;

Closure Phase *Rehabilitation of disturbed movement; *Ensure that soils are replaced in the correct layers, areas by contouring and *Compacted soils underneath the surface ripped and re-profiled post-closure, and that vegetation is Rehabilitation of revegetating them to blend infrastructure which have been removed; restored to a point where succession will lead to the same surface infrastructure into the natural landscape *Latent impacts of vegetation losses; conditions as the pre-mining state as a minimum; 8 footprint areas, with 2.5 5.5 10 55 L which should be free *Increased runoff volumes and formation of *Bare areas should be revegetated within suitable specific focus on the draining; and preferential surface flow paths as a result of indigenous vegetation species; and shafts. *Removal of stormwater compacted soils, leading to alteration of *Rehabilitation measures stipulated in the Environmental management infrastructure hydrological recharge paths; and Management Programme (EMP) must be implemented. to ensure a free draining *Increased sedimentation and erosion. Implementation must be overseen by a suitably qualified landscape. Environmental Site Officer (ESO) with wetland rehabilitation experience and the ESO must sign off the rehabilitation before the relevant contractors leave site.

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No. Activity Aspect Impact Mitigation Measures to be implemented

Phase

Severity

Likelihood

Risk Rating

Significance

Consequence *Since no geohydrological data specifically pertaining to *Contamination of water within the receiving the proposed ERPM expansion were available at the time freshwater environment, and subsequent of the compilation of this report, the risk significance of reduction in water quality (increase in salts Decant of contaminated decant was not assessed in detail. As such, the risk and specific contaminants of concern and Post-closure water from the significance of decant may have to be re-assessed based reduced pH); 9 management rehabilitated shaft area into 1.5 5.5 10 55 L on the outcome of the geohydrological study; and *Subsequent negative impacts on biota and activities. the receiving freshwater *The management and mitigation measures as vegetation; environment. recommended in the geohydrological study and EMP *Altered flow regimes (increased hydroperiod); should be implemented to mitigate the potential impacts and arising from decant of contaminated water from the shafts *Habitat degradation. into the receiving freshwater environment.

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As the delineated wetlands do not fall within the proposed Windmill or Witpoortjie Vent areas, and as it is assumed that no development will therefore take place within the wetland or the associated 100m GN704 Zone of Regulation, some activities pertaining to the proposed ERPM expansion, such as site preparation and construction of surface infrastructure, are anticipated to pose a low risk to the wetlands. However, the outcome of the Risk Assessment indicated that certain activities associated with the proposed ERPM expansion, such as the development of the shafts and clean and dirty water separation systems, will pose a moderate risk to the receiving freshwater environment during the construction phase.

Operational impacts associated with the proposed ERPM expansion resulting from the dewatering of the shafts and other operational activities such as that of the clean and dirty water separation systems, are also anticipated to pose a moderate risk to the wetlands. These impacts include the potential creation of a cone of depression, as well as the loss of catchment yield. Thus, it is considered imperative that suitable mitigation measures, as provided for in Section 6 and Appendix F of this report are strictly adhered to, to minimise the impacts associated with the proposed ERPM expansion and decrease the significance of cumulative impacts on the freshwater environment.

Assuming that strict enforcement of cogent, well-developed mitigation measures takes place, the impacts arising from the proposed ERPM expansion are likely to be of low to moderate significance during the construction and operational phases assuming that a high level of mitigation takes place. It is also recommended that ongoing alien vegetation control is implemented during the operational phase to enhance the ecological state of the wetlands associated within the proposed ERPM expansion.

Additional “good practice” mitigation measures applicable to a project of this nature are provided in Appendix F of this report.

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7 CONCLUSION

During the site assessment undertaken on the 9th of May 2019, a single watercourse was identified within the investigation area of the Windmill Shaft, a Hillslope Seep (HSS) wetland, while a single watercourse, a Channelled Valley Bottom (CVB) wetland, was identified within the investigation area of the Witpoortjie Vent Shaft. The HSS wetland associated with the Windmill Shaft is located along the northern boundary of the investigation area and drains in a northerly direction. The CVB wetland associated with the Witpoortjie Vent Shaft is located within the eastern and southern portions of the investigation area and drains in a south westerly direction towards an unnamed tributary of the Rietspruit River. The results of the assessments discussed in Section 5 of this report are summarised in the table below:

Table 7: Summary of results of the field assessment as discussed in Section 5. Watercourse PES Ecoservices EIS REC and RMO REC: D (Largely modified) CVB wetland D (Largely modified) Intermediate Moderate RMO: Maintain REC: C (Moderately HSS wetland C (Moderately modified) Moderately low Low/marginal modified) RMO: Maintain

Based on the findings of the freshwater ecological assessment and the results of the risk assessment, it is the opinion of the ecologist that the proposed ERPM expansion poses a moderate risk to the integrity of the wetlands associated with the Windmill and Witpoortjie Vent Shafts. Adherence to cogent, well-conceived and ecologically sensitive site development plans, the mitigation measures provided in this report as well as general good construction practice and ongoing management, maintenance and monitoring, are essential if the significance of perceived impacts is to be reduced to limit further degradation of the freshwater environment.

It is the opinion of the freshwater specialist that the proposed ERPM expansion, from a freshwater resource managment perspective, is considered acceptable, with the proviso that no development takes place within the wetlands or the associated 100m GN704 Zone of Regulation and that strict adherence to mitigation measures is enforced to ensure that the ecological integrity of the freshwater environment is not further compromised.

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REFERENCES

Department of Water Affairs (DWA). (2011). Directorate Water Resource Planning Systems: Water Quality Planning. Resource Directed Management of Water Quality. Planning Level Review of Water Quality in South Africa. Sub-series No. WQP 2.0. Pretoria, South Africa. Department of Water Affairs and Forestry (DWAF). 2008. Updated Manual for the Identification and Delineation of Wetlands and Riparian Areas, prepared by M. Rountree, A. L. Batchelor, J. MacKenzie and D. Hoare. Report no. X. Stream Flow Reduction Activities, Department of Water Affairs and Forestry, Pretoria, South Africa. Department of Water Affairs and Forestry (DWAF). 2005. Final draft: A practical field procedure for identification and delineation of wetlands and Riparian areas. Gauteng Department of Agriculture and Rural Development (GDARD). 2011. GIS Data – C-Plan Version 3.3 Gauteng Department of Agriculture and Rural Development (GDARD). 2011. Technical Report: Gauteng Conservation Plan Version 3.3 (C-Plan 3.3). Gauteng Department of Agriculture and Rural Development (GDARD): Nature Conservation Directorate. 2014. Technical Report for the Gauteng Conservation Plan Version 3.3 (Gauteng C-Plan 3.3). Gauteng Department of Agriculture and Rural Development (GDARD). 2014. Minimum Requirements for Biodiversity Assessments. Version 3. Johannesburg. Kleynhans C.J., Thirion C. and Moolman J. 2005. A Level 1 Ecoregion Classification System for South Africa, Lesotho and Swaziland. Report No. N/0000/00/REQ0104. Resource Quality Services, Department of Water Affairs and Forestry, Pretoria Kotze D.C., Marneweck G.C., Batchelor, A.L., Lindley D.S. and Collins N.B. 2009. WET- EcoServices: A technique for rapidly assessing ecosystem services supplied by wetlands. WRC Report No TT 339/08, Water Research Commission, Pretoria. Mbona, N., Job, N., Smith, J., Nel, J., Holness, S., Memani, S., and Dini, J. 2015. Supporting better decision making around coal mining in the Mpumalanga Highveld through the development of mapping tools and refinement of spatial data on wetlands. Pretoria. WRC Report TT614/14. National Environmental Management Act (NEMA) 107 of 1998 National Water Act (NWA) 36 of 1998. Nel, JL, Driver, A., Strydom W.F., Maherry, A., Petersen, C., Hill, L., Roux, D.J, Nienaber, S., Van Deventer, H., Swartz, E. & Smith-Adao, L.B. 2011. Atlas of Freshwater Ecosystem Priority Areas in South Africa: Maps to support sustainable development of water resources. Water Research Commission Report No. TT 500/11, Water Research Commission, Pretoria. NFEPA: Driver, A., Nel, J.L., Snaddon, K., Murruy, K., Roux, D.J., Hill, L., Swartz, E.R., Manuel, J. and Funke, N. 2011. Implementation Manual for Freshwater Ecosystem Priority Areas. Water Research Commission. Report No. 1801/1/11. Online available: http://bgis.sanbi.org/nfepa/project.asp Ollis, D.J., Snaddon, C.D., Job, N.M. & Mbona, N. 2013. Classification System for Wetlands and other Aquatic Ecosystems in South Africa. User Manual: Inland Systems. SANBI Biodiversity Series 22. South African Biodiversity Institute, Pretoria. Rountree, M.W. and Kotze, D.C. 2013. Appendix A3: Ecological Importance and Sensitivity Assessment. In: Rountree, M. W., Malan, H.L., and Weston, B.C. Eds. Manual for the Rapid Ecological Reserve Determination of Inland Wetlands (Version 2.0). WRC Report No. 1788/1/12. Pretoria.

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APPENDIX A – Terms of Use and Indemnity

INDEMNITY AND TERMS OF USE OF THIS REPORT

The findings, results, observations, conclusions and recommendations given in this report are based on the author’s best scientific and professional knowledge as well as available information. The report is based on survey and assessment techniques which are limited by time and budgetary constraints relevant to the type and level of investigation undertaken and SAS CC and its staff reserve the right to modify aspects of the report including the recommendations if and when new information may become available from ongoing research or further work in this field, or pertaining to this investigation.

Although SAS CC exercises due care and diligence in rendering services and preparing documents, SAS CC accepts no liability and the client, by receiving this document, indemnifies SAS CC and its directors, managers, agents and employees against all actions, claims, demands, losses, liabilities, costs, damages and expenses arising from or in connection with services rendered, directly or indirectly by SAS CC and by the use of the information contained in this document.

This report must not be altered or added to without the prior written consent of the author. This also refers to electronic copies of this report which are supplied for the purposes of inclusion as part of other reports, including main reports. Similarly, any recommendations, statements or conclusions drawn from or based on this report must make reference to this report. If these form part of a main report relating to this investigation or report, this report must be included in its entirety as an appendix or separate section to the main report.

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APPENDIX B – Legislation

LEGISLATIVE REQUIREMENTS The Constitution of the The environment and the health and well-being of people are safeguarded under the Republic of South Constitution of the Republic of South Africa, 1996 (Act No. 108 of 1996) by way of section 24. Africa, 1996 (Act No. Section 24(a) guarantees a right to an environment that is not harmful to human health or well- 108 of 1996) being and to environmental protection for the benefit of present and future generations. Section 24(b) directs the state to take reasonable legislative and other measures to prevent pollution, promote conservation, and secure the ecologically sustainable development and use of natural resources (including water and mineral resources) while promoting justifiable economic and social development. Section 27 guarantees every person the right of access to sufficient water, and the state is obliged to take reasonable legislative and other measures within its available resources to achieve the progressive 44ormalizati of this right. Section 27 is defined as a socio-economic right and not an environmental right. However, read with section 24 it requires of the state to ensure that water is conserved and protected and that sufficient access to the resource is provided. Water regulation in South Africa places a great emphasis on protecting the resource and on providing access to water for everyone. The National The National Environmental Management Act, 1998 (Act 107 of 1998) (NEMA) and the Environmental associated EIA Regulations, 2014 (as amended), states that prior to any development taking Management Act, 1998 place within a wetland or riparian area, an environmental authorisation process needs to be (Act No. 107 of 1998) followed. This could follow either the Basic Assessment Report (BAR) process or the (NEMA) Environmental Impact Assessment (EIA) process depending on the scale of the impact. Provincial regulations must also be considered. The National Water Act The NWA recognises that the entire ecosystem and not just the water itself in any given water 1998 (Act No. 36 of resource constitutes the resource and as such needs to be conserved. No activity may 1998) (NWA) therefore take place within a watercourse unless it is authorised by the Department of Water and Sanitation (DWS). Any area within a wetland or riparian zone is therefore excluded from development unless authorisation is obtained from the DWS in terms of Section 21 I & (i). Government Notice 509 In accordance with Regulation GN509 of 2016, a regulated area of a watercourse for section as published in the 21c and 21i of the NWA is defined as: Government Gazette 1. The outer edge of the 1 in 100 year flood line and/or delineated riparian habitat, 40229 of 2016 as it whichever is the greatest distance, measured from the middle of the watercourse of a relates to the NWA river, spring, natural channel, lake or dam; 2. In the absence of a determined 1 in 100 year flood line or riparian area the area within 100 m from the edge of a watercourse where the edge of the watercourse is the first identifiable annual bank fill flood bench; or 3. A 500 m radius from the delineated boundary (extent) of any wetland or pan. This notice replaces GN1199 and may be exercised as follows:  Exercise the water use activities in terms of Section 21I and (i) of the Act as set out in the table below, subject to the conditions of this authorisation;  Use water in terms of section 21I or (i) of the Act if it has a low risk class as determines through the Risk Matrix;  Do maintenance with their existing lawful water use in terms of section 21I or (i) of the Act that has a LOW risk class as determined through the Risk Matrix;  Conduct river and stormwater management activities as contained in a river management plan;  Conduct rehabilitation of wetlands or rivers where such rehabilitation activities has a LOW risk class as determined through the Risk Matrix; and  Conduct emergency work arising from an emergency situation or incident associated with the persons’ existing lawful water use, provided that all work is executed and reported in the manner prescribed in the Emergency protocol. A General Authorisation (GA) issued as per this notice will require the proponent to adhere with specific conditions, rehabilitation criteria and monitoring and reporting programme. Furthermore, the water user must ensure that there is a sufficient budget to complete, rehabilitate and maintain the water use as set out in this GA.

Upon completion of the registration, the responsible authority will provide a certificate of registration to the water user within 30 working days of the submission. On written receipt of

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a registration certificate from the Department, the person will be regarded as a registered water user and can commence within the water use as contemplated in the GA.

Government Notice 704 These Regulations were put in place in order to prevent the pollution of water resources and – Regulations on the protect water resources in areas where mining activity is taking place from impacts generally use of water for mining associated with mining. It is recommended that the proposed project complies with Regulation and related activities GN 704 of the NWA which contains regulations on the use of water for mining and related aimed at the protection activities aimed at the protection of water resources. GN 704 states that: of water resources, No person in control of a mine or activity may: 1999 (a) locate or place any residue deposit, dam, reservoir, together with any associated structure or any other facility within the 1:100 year floodline or within a horizontal distance of 100 metres from any watercourse or estuary, borehole or well, excluding boreholes or wells drilled specifically to monitor the pollution of groundwater, or on waterlogged ground, or on ground likely to become waterlogged, undermined, unstable or cracked;  According to the above, the activity footprint must fall outside of the 1:100 year floodline of the watercourse or 100m from the edge of the watercourse, whichever distance is the greatest. GDARD Requirements The biodiversity assessment must comply with the minimum requirements as stipulated by for Biodiversity GDARD Version 3 of 2014 and must contain the following information: Assessments Version 3  The wetland delineation procedure must identify the outer edge of the temporary zone (GDARD, 2014). of the wetland, which marks the boundary between the wetland and adjacent terrestrial areas;  The delineation must be undertaken according to the DWAF guidelines;  The wetland and a protective buffer zone, beginning from the outer edge of the wetland temporary zone, must be designated as sensitive in a sensitivity map. Rules for buffer zone widths are as follows:  30m for wetlands occurring inside urban areas;  50m for wetlands occurring outside urban areas; and 50m for priority pans.

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APPENDIX C – Method of Assessment

WATERCOURSE METHOD OF ASSESSMENT 1. Desktop Study Prior to the commencement of the field assessment, a background study, including a literature review, was conducted in order to determine the ecoregion and ecostatus of the larger aquatic system within which the freshwater features present or in close proximity of the proposed study area are located. Aspects considered as part of the literature review are discussed in the sections that follow.

1.1 National Freshwater Ecosystem Priority Areas (NFEPA, 2011) The NFEPA project is a multi-partner project between the Council of Scientific and Industrial Research (CSIR), Water Research Commission (WRC), South African National Biodiversity Institute (SANBI), DWA, South African Institute of Aquatic Biodiversity (SAIAB) and South African National Parks (SANParks). The project responds to the reported degradation of freshwater ecosystem condition and associated biodiversity, both globally and in South Africa. It uses systematic conservation planning to provide strategic spatial priorities of conserving South Africa’s freshwater biodiversity, within the context of equitable social and economic development.

The NFEPA project aims to identify a national network of freshwater conservation areas and to explore institutional mechanisms for their implementation. Freshwater ecosystems provide a valuable, natural resource with economic, aesthetic, spiritual, cultural and recreational value. However, the integrity of freshwater ecosystems in South Africa is declining at an alarming rate, largely as a consequence of a variety of challenges that are practical (managing vast areas of land to maintain connectivity between freshwater ecosystems), socio-economic (competition between stakeholders for utilisation) and institutional (building appropriate governance and co-management mechanisms).

The NFEPA database was searched for information in terms of conservation status of rivers, wetland habitat and wetland features present in the vicinity of or within the proposed study area.

2. Classification System for Wetlands and other Aquatic Ecosystems in South Africa The freshwater features encountered within the proposed study area were assessed using the Classification System for Wetlands and other Aquatic Ecosystems in South Africa. User Manual: Inland Systems (Ollis et al., 2013), hereafter referred to as the “Classification System”. A summary of Levels 1 to 4 of the classification system are presented in Table C1 and C2, below.

Table C1: Proposed classification structure for Inland Systems, up to Level 3.

WETLAND / AQUATIC ECOSYSTEM CONTEXT LEVEL 1: LEVEL 2: LEVEL 3: SYSTEM REGIONAL SETTING LANDSCAPE UNIT Valley Floor DWA Level 1 Ecoregions OR Slope Inland Systems NFEPA WetVeg Groups Plain OR Other special framework Bench (Hilltop / Saddle / Shelf)

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Table C2: Hydrogeomorphic (HGM) Unit for the Inland System, showing the primary HGM Types at Level 4A and the subcategories at Level 4B to 4C.

FUNCTIONAL UNIT LEVEL 4: HYDROGEOMORPHIC (HGM) UNIT Longitudinal zonation/ Landform / HGM type Landform / Inflow drainage Outflow drainage A B C Active channel Mountain headwater stream Riparian zone Active channel Mountain stream Riparian zone Active channel Transitional Riparian zone Active channel Upper foothills Riparian zone Active channel River Lower foothills Riparian zone Active channel Lowland river Riparian zone Active channel Rejuvenated bedrock fall Riparian zone Active channel Rejuvenated foothills Riparian zone Active channel Upland floodplain Riparian zone Channelled valley-bottom wetland (not applicable) (not applicable) Unchannelled valley-bottom wetland (not applicable) (not applicable) Floodplain depression (not applicable) Floodplain wetland Floodplain flat (not applicable) With channelled inflow Exorheic Without channelled inflow With channelled inflow Depression Endorheic Without channelled inflow With channelled inflow Dammed Without channelled inflow With channelled outflow (not applicable) Seep Without channelled outflow (not applicable) Wetland flat (not applicable) (not applicable)

Level 1: Inland systems From the Classification System, Inland Systems are defined as aquatic ecosystems that have no existing connection to the ocean4 (i.e. characterised by the complete absence of marine exchange and/or tidal influence) but which are inundated or saturated with water, either permanently or periodically. It is important to bear in mind, however, that certain Inland Systems may have had a historical connection to the ocean, which in some cases may have been relatively recent.

Level 2: Ecoregions & NFEPA Wetland Vegetation Groups For Inland Systems, the regional spatial framework that has been included at Level 2 of the classification system is that of DWA’s Level 1 Ecoregions for aquatic ecosystems (Kleynhans et al., 2005). There is a total of 31 Ecoregions across South Africa, including Lesotho and Swaziland. DWA Ecoregions have

4 Most rivers are indirectly connected to the ocean via an estuary at the downstream end, but where marine exchange (i.e. the presence of seawater) or tidal fluctuations are detectable in a river channel that is permanently or periodically connected to the ocean, it is defined as part of the estuary.

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most commonly been used to categorise the regional setting for national and regional water resource management applications, especially in relation to rivers. The Vegetation Map of South Africa, Swaziland and Lesotho (Mucina & Rutherford, 2006) group’s vegetation types across the country according to Biomes, which are then divided into Bioregions. To categorise the regional setting for the wetland component of the National Freshwater Ecosystem Priority Areas (NFEPA) project, wetland vegetation groups (referred to as WetVeg Groups) were derived by further splitting bioregions into smaller groups through expert input (Nel et al., 2011). There are currently 133 NFEPA WetVeg Groups. It is envisaged that these groups could be used as a special framework for the classification of wetlands in national- and regional-scale conservation planning and wetland management initiatives.

Level 3: Landscape Setting At Level 3 of the Classification System, for Inland Systems, a distinction is made between four Landscape Units (Table C1) on the basis of the landscape setting (i.e. topographical position) within which an HGM Unit is situated, as follows (Ollis et al., 2013):  Slope: an included stretch of ground that is not part of a valley floor, which is typically located on the side of a mountain, hill or valley;  Valley floor: The base of a valley, situated between two distinct valley side-slopes;  Plain: an extensive area of low relief characterised by relatively level, gently undulating or uniformly sloping land; and  Bench (hilltop/saddle/shelf): an area of mostly level or nearly level high ground (relative to the broad surroundings), including hilltops/crests (areas at the top of a mountain or hill flanked by down-slopes in all directions), saddles (relatively high-lying areas flanked by down-slopes on two sides in one direction and up-slopes on two sides in an approximately perpendicular direction), and shelves/terraces/ledges (relatively high-lying, localised flat areas along a slope, representing a break in slope with an up-slope one side and a down-slope on the other side in the same direction).

Level 4: Hydrogeomorphic Units Seven primary HGM Types are recognised for Inland Systems at Level 4A of the Classification System (Table C2), on the basis of hydrology and geomorphology (Ollis et al., 2013), namely:  River: a linear landform with clearly discernible bed and banks, which permanently or periodically carries a concentrated flow of water;  Channelled valley-bottom wetland: a valley-bottom wetland with a river channel running through it;  Unchannelled valley-bottom wetland: a valley-bottom wetland without a river channel running through it;  Floodplain wetland: the mostly flat or gently sloping land adjacent to and formed by an alluvial river channel, under its present climate and sediment load, which is subject to periodic inundation by over-topping of the channel bank;  Depression: a landform with closed elevation contours that increases in depth from the perimeter to a central area of greatest depth, and within which water typically accumulates.  Wetland Flat: a level or near-level wetland area that is not fed by water from a river channel, and which is typically situated on a plain or a bench. Closed elevation contours are not evident around the edge of a wetland flat; and  Seep: a wetland area located on (gently to steeply) sloping land, which is dominated by the colluvial (i.e. gravity-driven), unidirectional movement of material down-slope. Seeps are often located on the side-slopes of a valley but they do not, typically, extend into a valley floor.

The above terms have been used for the primary HGM Units in the classification system to try and ensure consistency with the wetland classification terms currently in common usage in South Africa. Similar terminology (but excluding categories for “channel”, “flat” and “valleyhead seep”) is used, for example, in the recently developed tools produced as part of the Wetland Management Series including WET-Health (Macfarlane et al., 2008), WET-IHI (DWAF, 2007) and WET-EcoServices (Kotze et al., 2009).

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3. WET-Health Healthy wetlands are known to provide important habitats for wildlife and to deliver a range of important goods and services to society. Management of these systems is therefore essential if these attributes are to be retained within an ever-changing landscape. The primary purpose of this assessment is to evaluate the eco-physical health of wetlands, and in so doing to promote their conservation and wise management.

Level of Evaluation Two levels of assessment are provided by WET-Health:  Level 1: Desktop evaluation, with limited field verification. This is generally applicable to situations where a large number of wetlands need to be assessed at a very low resolution; or  Level 2: On-site evaluation. This involves structured sampling and data collection in a single wetland and its surrounding catchment.

Framework for the Assessment A set of three modules has been synthesised from the set of processes, interactions and interventions that take place in wetland systems and their catchments: hydrology (water inputs, distribution and retention, and outputs), geomorphology (sediment inputs, retention and outputs) and vegetation (transformation and presence of introduced alien species).

Units of Assessment Central to WET-Health is the characterisation of HGM Units, which have been defined based on geomorphic setting (e.g. hillslope or valley-bottom; whether drainage is open or closed), water source (surface water dominated or sub-surface water dominated) and pattern of water flow through the wetland unit (diffusely or channelled) as described under the Classification System for Wetlands and other Aquatic Ecosystems above.

Quantification of Present State of a wetland The overall approach is to quantify the impacts of human activity or clearly visible impacts on wetland health, and then to convert the impact scores to a Present State score. This takes the form of assessing the spatial extent of the impact of individual activities and then separately assessing the intensity of the impact of each activity in the affected area. The extent and intensity are then combined to determine an overall magnitude of impact. The impact scores, and Present State categories are provided in the table below. Table C3: Impact scores and categories of Present State used by WET-Health for describing the integrity of wetlands. Impact Present Impact Description score State category range category None Unmodified, natural 0-0.9 A Small Largely natural with few modifications. A slight change in ecosystem 1-1.9 B processes is discernible and a small loss of natural habitats and biota may have taken place. Moderate Moderately modified. A moderate change in ecosystem processes and loss 2-3.9 C of natural habitats has taken place, but the natural habitat remains predominantly intact. Large Largely modified. A large change in ecosystem processes and loss of 4-5.9 D natural habitat and biota and has occurred. Serious The change in ecosystem processes and loss of natural habitat and biota 6-7.9 E is great, but some remaining natural habitat features are still recognisable. Critical Modifications have reached a critical level and the ecosystem processes 8-10 F have been completely modified with an almost complete loss of natural habitat and biota.

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Assessing the Anticipated Trajectory of Change As is the case with the Present State, future threats to the state of the wetland may arise from activities in the catchment upstream of the unit or within the wetland itself or from processes downstream of the wetland. In each of the individual sections for hydrology, geomorphology and vegetation, five potential situations exist depending upon the direction and likely extent of change (table below).

Table C4: Trajectory of Change classes and scores used to evaluate likely future changes to the present state of the wetland. HGM Change Class Description change Symbol score Substantial State is likely to improve substantially over the next 5 years 2 ↑↑ improvement Slight improvement State is likely to improve slightly over the next 5 years 1 ↑ Remain stable State is likely to remain stable over the next 5 years 0 → Slight deterioration State is likely to deteriorate slightly over the next 5 years -1 ↓ Substantial State is expected to deteriorate substantially over the next 5 years -2 ↓↓ deterioration

Overall health of the wetland Once all HGM Units have been assessed, a summary of health for the wetland as a whole needs to be calculated. This is achieved by calculating a combined score for each component by area-weighting the scores calculated for each HGM Unit. Recording the health assessments for the hydrology, geomorphology and vegetation components provide a summary of impacts, Present State, Trajectory of Change and Health for individual HGM Units and for the entire wetland.

4. Wetland Function Assessment “The importance of a water resource, in ecological social or economic terms, acts as a modifying or motivating determinant in the selection of the management class”.5 The assessment of the ecosystem services supplied by the identified freshwater features was conducted according to the guidelines as described by Kotze et al. (2009). An assessment was undertaken that examines and rates the following services according to their degree of importance and the degree to which the service is provided:  Flood attenuation;  Stream flow regulation;  Sediment trapping;  Phosphate trapping;  Nitrate removal;  Toxicant removal;  Erosion control;  Carbon storage;  Maintenance of biodiversity;  Water supply for human use;  Natural resources;  Cultivated foods;  Cultural significance;  Tourism and recreation; and  Education and research.

The characteristics were used to quantitatively determine the value, and by extension sensitivity, of the freshwater features. Each characteristic was scored to give the likelihood that the service is being

5 Department of Water Affairs and Forestry, South Africa Version 1.0 of Resource Directed Measures for Protection of Water Resources, 1999

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provided. The scores for each service were then averaged to give an overall score to the freshwater features.

Table C5: Classes for determining the likely extent to which a benefit is being supplied. Score Rating of the likely extent to which the benefit is being supplied <0.5 Low 0.6-1.2 Moderately low 1.3-2 Intermediate 2.1-3 Moderately high >3 High

5. Ecological Importance and Sensitivity (EIS) (Rountree & Kotze, 2013) The purposed of assessing importance and sensitivity of water resources is to be able to identify those systems that provide higher than average ecosystem services, biodiversity support functions or are especially sensitive to impacts. Water resources with higher ecological importance may require managing such water resources in a better condition than the present to ensure the continued provision of ecosystem benefits in the long term (Rountree & Kotze, 2013). In order to align the outputs of the Ecoservices assessment (i.e. ecological and socio-cultural service provision) with methods used by the DWA (now the DWS) used to assess the EIS of other watercourse types, a tool was developed using criteria from both WET-Ecoservices (Kotze, et, al, 2009) and earlier DWA EIA assessment tools. Thus, three proposed suites of important criteria for assessing the Importance and Sensitivity for wetlands were proposed, namely:  Ecological Importance and Sensitivity, incorporating the traditionally examined criteria used in EIS assessments of other water resources by DWA and thus enabling consistent assessment approaches across water resource types;  Hydro-functional importance, taking into consideration water quality, flood attenuation and sediment trapping ecosystem services that the wetland may provide; and  Importance in terms of socio-cultural benefits, including the subsistence and cultural benefits provided by the wetland system. The highest of these three suites of scores is then used to determine the overall Importance and Sensitivity category (Table C8) of the wetland system being assessed. Table C6: Ecological Importance and Sensitivity Categories and the interpretation of median scores for biota and habitat determinants (adapted from Kleynhans, 1999). Range of Recommended Ecological EIS Category Mean Management Class Very high Wetlands that are considered ecologically important and sensitive on a >3 and <=4 A national or even international level. The biodiversity of these wetlands is usually very sensitive to flow and habitat modifications. High Wetlands that are considered to be ecologically important and sensitive. >2 and <=3 B The biodiversity of these wetlands may be sensitive to flow and habitat modifications. Moderate Wetlands that are considered to be ecologically important and sensitive >1 and <=2 C on a provincial or local scale. The biodiversity of these wetlands is not usually sensitive to flow and habitat modifications. Low/marginal Wetlands that are not ecologically important and sensitive at any scale. >0 and <=1 D The biodiversity of these wetlands is ubiquitous and not sensitive to flow and habitat modifications.

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6. Recommended Management Objective (RMO) and Recommended Ecological Category (REC) Determination “A high management class relates to the flow that will ensure a high degree of sustainability and a low risk of ecosystem failure. A low management class will ensure marginal maintenance of sustainability but carries a higher risk of ecosystem failure” (DWA, 1999).

The RMO (table below) was determined based on the results obtained from the PES, reference conditions and EIS of the watercourse (sections above), with the objective of either maintaining, or improving the ecological integrity of the watercourse in order to ensure continued ecological functionality.

A watercourse may receive the same class for the REC as the PES if the watercourse is deemed in good condition, and therefore must stay in good condition. Otherwise, an appropriate REC should be assigned in order to prevent any further degradation as well as enhance the PES of the watercourse.

Table C7: Recommended management objectives (RMO) for water resources based on PES & EIS scores. Ecological and Importance Sensitivity (EIS) Very High High Moderate Low A Pristine A A A A Maintain Maintain Maintain Maintain B Natural A A/B B B Improve Improve Maintain Maintain C Good A B/C C C Improve Improve Maintain Maintain

D Fair C C/D D D Improve Improve Maintain Maintain

PES E/F Poor D* E/F* E/F* E/F* Improve Improve Maintain Maintain *PES Categories E and F are considered ecologically unnacceptable (Malan and Day, 2012) and therefore, should a watercourse fall into one of these PES categories, an REC class D is allocated by default, as the minimum acceptable PES category.

Table C8: Description of Recommended Ecological Category (REC) classes.

Class Description A Unmodified, natural B Largely natural with few modifications C Moderately modified D Largely modified

7. Wetland Delineation The watercourse delineation took place according to the method presented in the “Updated manual for the identification and delineation of wetland and riparian resources” published by DWAF in 2008. The foundation of the method is based on the fact that wetlands and riparian zones have several distinguishing factors including the following:  The presence of water at or near the ground surface;  Distinctive hydromorphic soils;  Vegetation adapted to saturated soils; and  The presence of alluvial soils in stream systems.

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According to the DWA (2005) like wetlands, riparian areas have their own unique set of indicators. It is possible to delineate riparian areas by checking for the presence of these indicators. Some areas may display both wetland and riparian indicators, and can accordingly be classified as both. If you are adjacent to a watercourse, it is important to check for the presence of the riparian indicators described below, in addition to checking for wetland indicators, to detect riparian areas that do not qualify as wetlands. The delineation process requires that the following be taken into account:  topography associated with the watercourse;  vegetation; and  alluvial soils and deposited material.

By observing the evidence of these features in the form of indicators, wetlands and riparian zones can be delineated and identified. If the use of these indicators and the interpretation of the findings are applied correctly, then the resulting delineation can be considered accurate (DWA, 2005).

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APPENDIX D – Risk Assessment Methodology

In order for the EAP to allow for sufficient consideration of all environmental impacts, impacts were assessed using a common, defensible method of assessing significance that will enable comparisons to be made between risks/impacts and will enable authorities, stakeholders and the client to understand the process and rationale upon which risks/impacts have been assessed. The method to be used for assessing risks/impacts is outlined in the sections below. The first stage of the risk/impact assessment is the identification of environmental activities, aspects and impacts. This is supported by the identification of receptors and resources, which allows for an understanding of the impact pathway and an assessment of the sensitivity to change. The definitions used in the impact assessment are presented below.  An activity is a distinct process or task undertaken by an organisation for which a responsibility can be assigned. Activities also include facilities or infrastructure that is possessed by an organisation.  An environmental aspect is an ‘element of an organizations activities, products and services which can interact with the environment’6. The interaction of an aspect with the environment may result in an impact.  Environmental risks/impacts are the consequences of these aspects on environmental resources or receptors of particular value or sensitivity, for example, disturbance due to noise and health effects due to poorer air quality. In the case where the impact is on human health or wellbeing, this should be stated. Similarly, where the receptor is not anthropogenic, then it should, where possible, be stipulated what the receptor is.  Receptors can comprise, but are not limited to, people or human-made systems, such as local residents, communities and social infrastructure, as well as components of the biophysical environment such as freshwater features, flora and riverine systems.  Resources include components of the biophysical environment.  Frequency of activity refers to how often the proposed activity will take place.  Frequency of impact refers to the frequency with which a stressor (aspect) will impact on the receptor.  Severity refers to the degree of change to the receptor status in terms of the reversibility of the impact; sensitivity of receptor to stressor; duration of impact (increasing or decreasing with time); controversy potential and precedent setting; threat to environmental and health standards.  Spatial extent refers to the geographical scale of the impact.  Duration refers to the length of time over which the stressor will cause a change in the resource or receptor.

The significance of the impact is then assessed by rating each variable numerically according to the defined criteria (refer to the table below). The purpose of the rating is to develop a clear understanding of influences and processes associated with each impact. The severity, spatial scope and duration of the impact together comprise the consequence of the impact and when summed can obtain a maximum value of 15. The frequency of the activity, impact, legal issues and the detection of the impact together comprise the likelihood of the impact occurring and can obtain a maximum value of 20. The values for likelihood and consequence of the impact are then read off a significance rating matrix and are used to determine whether mitigation is necessary7.

The model outcome of the impacts was then assessed in terms of impact certainty and consideration of available information. The Precautionary Principle is applied in line with South Africa’s National

6 The definition has been aligned with that used in the ISO 14001 Standard. 7 Some risks/impacts that have low significance will however still require mitigation

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Environmental Management Act (No. 108 of 1997) in instances of uncertainty or lack of information, by increasing assigned ratings or adjusting final model outcomes. In certain instances, where a variable or outcome requires rational adjustment due to model limitations, the model outcomes have been adjusted.

“RISK ASSESSMENT KEY” (Based on DWS 2015 publication: Section 21 c and i water use Risk Assessment Protocol) Table D1: Severity (How severe does the aspects impact on the resource quality (flow regime, water quality, geomorphology, biota, habitat) Insignificant / non-harmful 1 Small / potentially harmful 2 Significant / slightly harmful 3 Great / harmful 4 Disastrous / extremely harmful and/or wetland(s) involved 5 Where “or wetland(s) are involved” it means that the activity is located within the delineated boundary of any wetland. The score of 5 is only compulsory for the significance rating. Table D2: Spatial Scale (How big is the area that the aspect is impacting on) Area specific (at impact site) 1 Whole site (entire surface right) 2 Regional / neighbouring areas (downstream within quaternary catchment) 3 National (impacting beyond secondary catchment or provinces) 4 Global (impacting beyond SA boundary) 5 Table D3: Duration (How long does the aspect impact on the resource quality) One day to one month, PES, EIS and/or REC not impacted 1 One month to one year, PES, EIS and/or REC impacted but no change in status 2 One year to 10 years, PES, EIS and/or REC impacted to a lower status but can be improved over this period through mitigation 3 Life of the activity, PES, EIS and/or REC permanently lowered 4 More than life of the organisation/facility, PES and EIS scores, a E or F 5 PES and EIS (sensitivity) must be considered. Table D4: Frequency of the activity (How often do you do the specific activity) Annually or less 1 6 monthly 2 Monthly 3 Weekly 4 Daily 5 Table D5: The frequency of the incident or impact (How often does the activity impact on the resource quality) Almost never / almost impossible / >20% 1 Very seldom / highly unlikely / >40% 2 Infrequent / unlikely / seldom / >60% 3 Often / regularly / likely / possible / >80% 4 Daily / highly likely / definitely / >100% 5 Table D6: Legal issues (How is the activity governed by legislation) No legislation 1 Fully covered by legislation (wetlands are legally governed) 5 Located within the regulated areas

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Table D7: Detection (How quickly or easily can the impacts/risks of the activity be observed on the resource quality, people and resource) Immediately 1 Without much effort 2 Need some effort 3 Remote and difficult to observe 4 Covered 5 Table D8: Rating Classes RATING CLASS MANAGEMENT DESCRIPTION Acceptable as is or consider requirement for mitigation. Impact to 1 – 55 (L) Low Risk watercourses and resource quality small and easily mitigated. Risk and impact on watercourses are notably and require mitigation measures 56 – 169 M) Moderate Risk on a higher level, which costs more and require specialist input. Licence required. Watercourse(s) impacts by the activity are such that they impose a long-term 170 – 300 (H) High Risk threat on a large scale and lowering of the Reserve. Licence required. A low risk class must be obtained for all activities to be considered for a GA Table D9: Calculations

Consequence = Severity + Spatial Scale + Duration

Likelihood = Frequency of Activity + Frequency of Incident + Legal Issues + Detection Significance\Risk = Consequence X Likelihood

The following points were considered when undertaking the assessment:  Risks and impacts were analysed in the context of the project’s area of influence encompassing:  Primary project site and related facilities that the client and its contractors develops or controls;  Areas potentially impacted by cumulative impacts for further planned development of the project, any existing project or condition and other project-related developments; and  Areas potentially affected by impacts from unplanned but predictable developments caused by the project that may occur later or at a different location. i) Risks/Impacts were assessed for construction phase and operational phase; and  Individuals or groups who may be differentially or disproportionately affected by the project because of their disadvantaged or vulnerable status were assessed.

Control Measure Development The following points presents the key concepts considered in the development of mitigation measures for the proposed construction:  Mitigation and performance improvement measures and actions that address the risks and impacts8 are identified and described in as much detail as possible. Mitigating measures are investigated according to the impact minimisation hierarchy as follows:  Avoidance or prevention of impact;  Minimisation of impact;  Rehabilitation; and  Offsetting.  Measures and actions to address negative impacts will favour avoidance and prevention over minimisation, mitigation or compensation; and

8 Mitigation measures should address both positive and negative impacts

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 Desired outcomes are defined, and have been developed in such a way as to be measurable events with performance indicators, targets and acceptable criteria that can be tracked over defined periods, wherever possible.

Recommendations Recommendations were developed to address and mitigate potential impacts on the freshwater ecology of the resources in traversed by or in close proximity of the proposed infrastructure.

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APPENDIX E – Results of Field Investigation

PRESENT ECOLOGICAL STATE (PES) AND ECOLOGICAL IMPORTANCE AND SENSITIVITY (EIS) RESULTS

Table E1: Presentation of the results of the PES assessment (WET-Health) applied to the CVB wetland.

Hydrology Geomorphology Vegetation HGM Extent Ha Overall Score Unit (%) Impact Change Impact Change Impact Change Score Score Score Score Score Score 1 36 100 4.0 -1 3.6 -1 5.7 -1 4.4 PES Category D ↓ C ↓ D ↓ D

Table E2: Presentation of the results of the PES assessment (WET-Health) applied to the HSS wetland.

Hydrology Geomorphology Vegetation Extent Overall HGM Unit Ha (%) Impact Change Impact Change Impact Change Score Score Score Score Score Score Score 1 1 100 2.0 -1 1.2 -1 3.6 -1 2.2 PES Category C ↓ B ↓ C ↓ C

Table E3: Presentation of the results of the Ecoservices assessment applied to the CVB and HSS wetlands.

Ecosystem service CVB Wetland HSS Wetland Flood attenuation 1.8 1.3 Streamflow regulation 2.0 1.6 Sediment trapping 1.4 1.4 Phosphate assimilation 2.0 1.4 Nitrate assimilation 2.0 1.3 Toxicant assimilation 2.1 1.4 Erosion control 1.9 1.8 Carbon Storage 1.0 1.0 Biodiversity maintenance 1.4 1.6 Water Supply 2.0 1.2 Harvestable resources 1.2 0.8 Cultivated foods 1.0 1.0 Cultural value 0.5 0.5 Tourism and recreation 0.6 0.3 Education and research 0.8 0.8 SUM 21.7 17.1 Average score 1.4 1.1

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Table E4: Presentation of the results of the EIS assessment applied to the CVB and HSS wetlands.

FRESHWATER FEATURE: CVB Wetland HSS Wetland Ecological Importance and Sensitivity Score (0-4) A (average) Biodiversity support 0.33 0.67 Presence of Red Data species 0 0 Populations of unique species 0 0 Migration/breeding/feeding sites 1 2 B (average) Landscape scale 1.40 0.80 Protection status of the wetland 1 1 Protection status of the vegetation type 3 3 Regional context of the ecological integrity 1 0 Size and rarity of the wetland type/s present 1 0 Diversity of habitat types 1 0 C (average) Sensitivity of the wetland 1.67 1.00 Sensitivity to changes in floods 2 1 Sensitivity to changes in low flows/dry season 2 0 Sensitivity to changes in water quality 1 2 ECOLOGICAL IMPORTANCE & SENSITIVITY (max of A,B or C) C D Hydro-Functional Importance Score (0-4)

Flood attenuation 2 1

Streamflow regulation 2 1 Sediment trapping 1 1

Phosphate assimilation 2 1

Nitrate assimilation 2 1 Toxicant assimilation 2 1

WaterQuality

Enhancement Erosion control 2 2

Regulating & supporting benefits Regulating supporting & Carbon storage 1 1 HYDRO-FUNCTIONAL IMPORTANCE (average score) 2 1 Direct Human Benefits Score (0-4)

Water for human use 2 1 Harvestable resources 1 1

benefits

Subsistence Cultivated foods 1 1

Cultural heritage 1 1 Tourism and recreation 0 0

Cultural benefits Education and research 1 1 DIRECT HUMAN BENEFITS (average score) 1.00 0.83

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APPENDIX F – Risk Assessment and Mitigation Measures

General construction management and good housekeeping practices Latent and general impacts which may affect the freshwater ecology and biodiversity, will include any activities which take place in close proximity to the proposed ERPM expansion that may impact on the receiving environment. Mitigation measures for these impacts are highlighted below and are relevant to the freshwater system identified in this report:

Proposed ERPM expansion footprint  All development footprint areas should remain as small as possible and should not encroach into the freshwater areas unless absolutely essential and part of the proposed ERPM expansion. It must be ensured that the freshwater habitat is off-limits to construction vehicles and non-essential personnel;  The boundaries of footprint areas, including contractor laydown areas, are to be clearly defined and it should be ensured that all activities remain within defined footprint areas. Edge effects will need to be extremely carefully controlled;  Planning of temporary roads and access routes should avoid freshwater areas and be restricted to existing roads where possible;  Appropriate sanitary facilities must be provided for the life of the construction phase and all waste removed to an appropriate waste facility;  All hazardous chemicals as well as stockpiles should be stored on bunded surfaces and have facilities constructed to control runoff from these areas;  It must be ensured that all hazardous storage containers and storage areas comply with the relevant SABS standards to prevent leakage;  No fires should be permitted in or near the construction area; and  Ensuring that an adequate number of waste and “spill” bins are provided will also prevent litter and ensure the proper disposal of waste and spills.

Vehicle access  All vehicles and equipment must be regularly inspected for leaks. Re-fuelling must take place outside of the stipulated setback area, on a sealed surface area to prevent ingress of hydrocarbons into the topsoil;  In the event of a vehicle breakdown, maintenance of vehicles must take place with care and the recollection of spillage should be practiced near the surface area to prevent ingress of hydrocarbons into topsoil and subsequent habitat loss; and  All spills should they occur, should be immediately cleaned up and treated accordingly.

Vegetation  Proliferation of alien and invasive species is expected within any disturbed areas. Alien invasive species are opportunistic, and where disturbances do occur, they will propagate; therefore, these species should be eradicated and controlled to prevent their spread beyond the project footprint. Alien plant seed dispersal within the top layers of the soil within footprint areas, that will have an impact on future rehabilitation, has to be controlled;  Removal of the alien and weed species encountered within the study area and particularly any identified within the watercourse must take place in order to comply with existing legislation (amendments to the regulations under the Conservation of Agricultural Resources Act, 1983 (Act No. 43 of 1983) and Section 28 of the National Environmental Management Act, 1998 (Act No. 107 of 1998). Removal of species should take place throughout the construction, operational, and maintenance phases; and  Species specific and area specific eradication recommendations:  Care should be taken with the choice of herbicide to ensure that no additional impact and loss of indigenous plant species occurs due to the herbicide used;  Footprint areas should be kept as small as possible when removing alien plant species; and  No vehicles should be allowed to drive through designated sensitive wetland areas during the eradication of alien and weed species.

60 SAS 219104 June 2019

Soils  Sheet runoff from impermeable surfaces such as access roads and the walkways within close proximity to the watercourse should be slowed down by the strategic placement of berms;  As far as possible, all construction activities should occur in the low flow season, during the drier winter months;  As much vegetation growth as possible (of indigenous floral species) should be encouraged to protect soils;  No stockpiling of topsoil is to take place within close proximity to the watercourse, and all stockpiles must be protected with a suitable geotextile to prevent sedimentation of the w watercourse;  All soils compacted as a result of construction activities as well as ongoing operational activities falling outside of project footprint areas should be ripped and profiled; and  A monitoring plan for the development and the immediate zone of influence should be implemented to prevent erosion and incision.

Rehabilitation  Construction rubble must be collected and disposed of at a suitable landfill site; and  All alien vegetation in the footprint area as well as immediate vicinity of the proposed ERPM expansion should be removed. Alien vegetation control should take place for a minimum period of two growing seasons after rehabilitation is completed.

61 SAS 219104 June 2019

Table F1: Results of the risk assessment applied to wetland associated with the proposed development. Reviewed by: Stephen van Staden SACNASP Number 400134/05 Risk Assessment Matrix in terms of GN509 of 2016 Signature

Quality)

No. Activity Aspect Impact

Biota

Phase

Severity

Duration

Detection

Likelihood

Vegetation)

Risk Rating

Significance

Legal Issues

Spatial scale

Flow Regime

Consequence

(Water

Confidence level

Physico & Chemical

Habitat (Geomorph+

Frequency of impact

Frequency of activity

Site preparation prior to *Runoff with high sediment loads construction entering the wetlands as a result of activities related exposed soil from cleared areas, to the proposed *Vehicular movement and smothering the wetland vegetation and new Windmill access to the site; thus altering the habitat of the Shaft and the *Removal of terrestrial wetlands, leading to areas within the rehabilitation of vegetation and associated wetlands more suited to terrestrial the existing disturbances (rubble and vegetation; Witpoortjie Vent 1 litter) to soil; and *Compaction of soil due to the 2 1 2 2 1.75 1 2 4.75 3 1 5 2 11 52.3 L 85 Shaft, including *Possible unplanned and movement of construction machinery proposed uncontrolled movement of leading to alterations of runoff patterns surface construction machinery into the wetlands; infrastructure, through the CVB and HSS *Proliferation of alien vegetation as a and the wetland. result of disturbances; and

Construction Phase placement of *Vegetation degradation, and the contractor subsequent loss of habitat for wetland laydown areas species. and storage facilities. Construction of *Loss of wetland habitat and ecological *Movement of construction surface structure as a result of edge effects machinery within the 2 infrastructure associated with the ERPM expansion; 2 1 2 1 1.5 1 2 4.5 3 2 5 2 12 54 L 100m GN704 Zone of associated with *Impacts to the ecoservice provision of Regulation (HSS wetland); the Windmill the wetland;

62 SAS 219104 June 2019

Quality)

No. Activity Aspect Impact

Biota

Phase

Severity

Duration

Detection

Likelihood

Vegetation)

Risk Rating

Significance

Legal Issues

Spatial scale

Flow Regime

Consequence

(Water

Confidence level

Physico & Chemical

Habitat (Geomorph+

Frequency of impact

Frequency of activity

Shaft, such as *Ground-breaking and *Potential impacts on the hydrology buildings, earthworks relating to and sedimentation of the wetland, structures and foundations; leading to alteration of the flood internal roads. *Mixing and casting of regime; concrete for construction *Potential impacts on the water quality purposes; of runoff which may potentially enter *Stockpiling of the downgradient wetland and construction materials; contamination of soils due to concrete *Creation of a topsoil being cast; and stockpile and a Waste *Proliferation of alien and invasive Rock Dump (WRD); plant species within the wetlands. *Increased likelihood of dust generation due to exposed soils; and *Changes to stormwater runoff in the landscape as a result of construction activities and increased impermeable surfaces. Construction of *Movement of construction surface machinery within the infrastructure 100m GN704 Zone of associated with Regulation (CVB wetland); the Witpoortjie *Stockpiling of Vent Shaft, construction materials; 2 1 2 1 1.5 1 2 4.5 2 1 5 2 10 45 L 85 including *Increased likelihood of refurbishment of dust generation due to the existing exposed soils; and ventilation shaft, *Changes to stormwater surface runoff in the landscape as ventilation fans, a result of construction

63 SAS 219104 June 2019

Quality)

No. Activity Aspect Impact

Biota

Phase

Severity

Duration

Detection

Likelihood

Vegetation)

Risk Rating

Significance

Legal Issues

Spatial scale

Flow Regime

Consequence

(Water

Confidence level

Physico & Chemical

Habitat (Geomorph+

Frequency of impact

Frequency of activity

an access road activities and increased and a generator impermeable surfaces. and compressor. Loss of catchment yield resulting from stormwater containment, leading to: *Increased flood peaks as a result of 64ormalization and concentration of *Ground-breaking surface runoff in clean water diversion associated with the Development of structures; excavation of trenches; clean and dirty *Potential for erosion, leading to 3 *Removal of topsoil; and 3 1 2 1 1.75 2 3 6.75 4 2 5 2 13 87.8 M 85 water separation sedimentation of the wetlands; *Excavation activities systems. *Reduction in volume of water entering leading to the stockpiling the wetlands, leading to loss of of soil. recharge of the wetlands; and *Altered vegetation community structure and diversity due to moisture stress. *Potential subsidence of surrounding environment if pillars are insufficient to support the ground; Sinking of the *Excavation, drilling and *Potential creation of a cone of Windmill Shafts, blasting in order to sink depression, which may drain water and associated the shafts, leading to from surrounding wetland habitats, removal of 4 stockpiling of rock and thus resulting in desiccation of the 1 1 1 1 1 1 2 4 1 2 5 3 11 44 L 85 waste material topsoil; and wetlands; and other *Operation of construction *Water entering the shafts as a result excavated equipment on site. of ingress may necessitate dewatering materials. of the shafts, which may result in the discharge of dirty water into the surrounding wetland environment;

64 SAS 219104 June 2019

Quality)

No. Activity Aspect Impact

Biota

Phase

Severity

Duration

Detection

Likelihood

Vegetation)

Risk Rating

Significance

Legal Issues

Spatial scale

Flow Regime

Consequence

(Water

Confidence level

Physico & Chemical

Habitat (Geomorph+

Frequency of impact

Frequency of activity

*Potential spillage of oils/hydrocarbons from construction vehicles. *Nitrates from blasting leaching from the WRD, leading to eutrophication of the receiving environment and resulting in loss of potable water within *Below-ground blasting the catchment; and and storage of waste rock 2 3 2 2 2.25 1 3 6.25 5 3 5 3 16 100 M 85 *Increased risk of pollution of surface within the WRD. water and groundwater, which may affect the wetland areas, leading to impaired water quality and salinisation of soils within the wetlands.

*The potential failure of the PCD Operation of the infrastructure may result in leakages Windmill and and possible contamination of surface 5 Operation of the PCD Witpoortjie and groundwater, increased flow into associated with the 3 3 2 2 2.5 1 3 6.5 5 3 5 3 16 104 M 85 Shafts. the HSS wetland, and lowered water Windmill Shaft. quality (increase in salts and specific Operational Phase contaminants of concern and reduced pH) within the wetland. *The operation of the shafts may result *Potential creation of a in the formation of a cone of cone of depression; depression, pulling water towards the *Dewatering of the shafts; shafts over time; and *Impacts to the hydrological processes 3 3 3 2 2.75 1 3 6.75 5 3 5 3 16 108 M 85 *Potential decant from the of the wetlands due to removal of shafts to the receiving interflow soils; freshwater environment. *Changes in wetland hydroperiod and vegetation structure;

65 SAS 219104 June 2019

Quality)

No. Activity Aspect Impact

Biota

Phase

Severity

Duration

Detection

Likelihood

Vegetation)

Risk Rating

Significance

Legal Issues

Spatial scale

Flow Regime

Consequence

(Water

Confidence level

Physico & Chemical

Habitat (Geomorph+

Frequency of impact

Frequency of activity

*As a result of dewatering, contaminated water may enter the receiving environment leading to altered water quality; and *Alteration (increase) of flow regimes, reduction in water quality (increase in salts and specific contaminants of concern and reduced pH) and subsequent loss of biodiversity of the wetlands due to decant of contaminated water. Loss of catchment yield due to stormwater containment is expected to occur, which could lead to the following impacts: *Increased flood peaks into the wetlands as a result of formalisation *Containment/diversion of and concentration of surface runoff; runoff into the clean and *Potential for erosion of terrestrial dirty water system; Operation of the areas as a result of the formation of *Discharge of clean water clean and dirty preferential flow paths, leading to 6 into the surrounding 2 1 1 1 1.25 1 2 4.25 3 2 5 2 12 51 L 85 water separation sedimentation of the wetlands; wetland systems; and systems. *Reduction in volume of water entering *Potential of the wetlands, leading to loss of malfunctioning of the dirty recharge (and thus potential water system. desiccation) of the wetland systems; *Erosion and sedimentation of the wetlands at the outlet of the clean water trench; and *Altered vegetation communities due to moisture stress.

66 SAS 219104 June 2019

Quality)

No. Activity Aspect Impact

Biota

Phase

Severity

Duration

Detection

Likelihood

Vegetation)

Risk Rating

Significance

Legal Issues

Spatial scale

Flow Regime

Consequence

(Water

Confidence level

Physico & Chemical

Habitat (Geomorph+

Frequency of impact

Frequency of activity

Rehabilitation of *Temporarily altered flow regime, the wetlands *Re-vegetation of the leading to possible loss of recharge to and 100m wetland and 100m downgradient areas, impacting on 7 GN704 Zones of GDARD setback area and 2 1 2 1 1.5 1 2 4.5 1 2 5 2 10 45 L 85 downgradient biota; and Regulation removal of construction *Possible sedimentation of associated with material and waste. downgradient areas. the shafts. *Sealing and backfilling of *Compaction of soils due to vehicular the shafts; movement; *Rehabilitation of *Compacted soils underneath the Rehabilitation of disturbed areas by surface infrastructure which have been surface contouring and removed; infrastructure revegetating them to *Latent impacts of vegetation losses; 8 footprint areas, blend into the natural 3 2 3 2 2.5 1 2 5.5 1 2 5 2 10 55 L 85 *Increased runoff volumes and with specific landscape which should formation of preferential surface flow focus on the be free draining; and paths as a result of compacted soils, shafts. *Removal of stormwater leading to alteration of hydrological management Closure Phase recharge paths; and infrastructure to ensure a *Increased sedimentation and erosion. free draining landscape. *Contamination of water within the receiving freshwater environment, and subsequent reduction in water quality Decant of contaminated (increase in salts and specific Post-closure water from the contaminants of concern and reduced 9 management rehabilitated shaft area pH); 1 2 1 2 1.5 2 2 5.5 1 2 5 2 10 55 L 85 activities. into the receiving *Subsequent negative impacts on freshwater environment. biota and vegetation; *Altered flow regimes (increased hydroperiod); and *Habitat degradation.

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APPENDIX G – Specialist information

DETAILS, EXPERTISE AND CURRICULUM VITAE OF SPECIALISTS

1. (a) (i) Details of the specialist who prepared the report

Stephen van Staden MSc (Environmental Management) (University of Johannesburg)

Lauren Robson MSc (Zoology: Aquatic Health) (University of Johannesburg)

1. (a). (ii) The expertise of that specialist to compile a specialist report including a curriculum vitae

Company of Specialist: Scientific Aquatic Services Name / Contact person: Stephen van Staden Postal address: 29 Arterial Road West, Oriel, Bedfordview Postal code: 1401 Cell: 083 415 2356 Telephone: 011 616 7893 Fax: 011 615 6240/ 086 724 3132 E-mail: [email protected] Qualifications MSc (Environmental Management) (University of Johannesburg) BSc (Hons) Zoology (Aquatic Ecology) (University of Johannesburg) BSc (Zoology, Geography and Environmental Management) (University of Johannesburg) Registration / Associations Registered Professional Natural Scientist at South African Council for Natural Scientific Professions (SACNASP) Accredited River Health Practitioner by the South African River Health Program (RHP) Member of the South African Soil Surveyors Association (SASSO) Member of the Gauteng Wetland Forum

68 SAS 219104 June 2019

SCIENTIFIC AQUATIC SERVICES (SAS) – SPECIALIST CONSULTANT INFORMATION CURRICULUM VITAE OF STEPHEN VAN STADEN

PERSONAL DETAILS

Position in Company Managing member, Ecologist with focus on Freshwater Ecology Date of Birth 13 July 1979 Nationality South African Languages English, Afrikaans Joined SAS 2003 (year of establishment) Other Business Trustee of the Serenity Property Trust and emerald Management Trust

MEMBERSHIP IN PROFESSIONAL SOCIETIES

Registered Professional Scientist at South African Council for Natural Scientific Professions (SACNASP); Accredited River Health practitioner by the South African River Health Program (RHP); Member of the South African Soil Surveyors Association (SASSO); Member of the Gauteng Wetland Forum; Member of International Association of Impact Assessors (IAIA) South Africa; Member pf the Land Rehabilitation Society of South Africa (LaRSSA)

EDUCATION Qualifications MSc (Environmental Management) (University of Johannesburg) 2003 BSc (Hons) Zoology (Aquatic Ecology) (University of Johannesburg) 2001 BSc (Zoology, Geography and Environmental Management) (University of Johannesburg) 2000

Tools for wetland Assessment short course Rhodes University 2016

COUNTRIES OF WORK EXPERIENCE

South Africa – All Provinces Southern Africa – Lesotho, Botswana, Mozambique, Zimbabwe Zambia Eastern Africa – Tanzania Mauritius West Africa – Ghana, Liberia, Angola, Guinea Bissau, Nigeria, Sierra Leone Central Africa – Democratic Republic of the Congo

PROJECT EXPERIENCE (Over 2500 projects executed with varying degrees of involvement) 1. M 1 Mining Coal, Chrome, PGM’s, Mineral Sands, Gold, Phosphate, river sand, clay, fluorspar 2 Linear developments 3 Energy Transmission, telecommunication, pipelines, roads 4 Minerals beneficiation 5 Renewable energy (wind and solar) 6 Commercial development 7 Residential development 8 Agriculture 9 Industrial/chemical

69 SAS 219104 June 2019

REFERENCES  Terry Calmeyer (Former Chairperson of IAIA SA) Director: ILISO Consulting Environmental Management (Pty) Ltd Tel: +27 (0) 11 465 2163 Email: [email protected]

 Alex Pheiffer African Environmental Management Operations Manager SLR Consulting Tel: +27 11 467 0945 Email: [email protected]

 Marietjie Eksteen Managing Director: Jacana Environmental Tel: 015 291 4015

Yours faithfully

STEPHEN VAN STADEN

70 SAS 219104 June 2019

SCIENTIFIC AQUATIC SERVICES (SAS) – SPECIALIST CONSULTANT INFORMATION CURRICULUM VITAE OF LAUREN ROBSON

PERSONAL DETAILS

Position in Company Junior Field Ecologist

Date of Birth 20 January 1992

Nationality South African

Languages English

Joined SAS 2018

MEMBERSHIP IN PROFESSIONAL SOCIETIES

Registered Candidate Natural Scientist with the South African Council for Natural Scientific Professions

Member of the Gauteng Wetland Forum EDUCATION

Qualifications

MSc Zoology (University of Johannesburg) 2017

BSc (Hons) Zoology (University of Johannesburg) 2014

BSc Life and Environmental Sciences (University of Johannesburg) 2013

COUNTRIES OF WORK EXPERIENCE

South Africa – Gauteng, Mpumalanga, Western Cape

SELECTED PROJECT EXAMPLES

Freshwater Assessments  Freshwater Resource Ecological Assessment as part of the environmental assessment and authorisation process for the proposed further development of Erf 35531 and formalisation of the Kuils River adjacent to Erf 35531, Stikland, Western Cape.  Peer Review of the Basic Assessment with specific focus on Freshwater Resource Impacts and Impact Assessment for the Jewellery Manufacturing Precinct near the OR Tambo Airport, Gauteng to determine adequacy for decision making on the Amendment Application.  Freshwater Resource Verification of the environmental assessment and authorisation process for the proposed mixed-use development on a portion of Portion 62 of the Farm Witportjie 117 IR.  Freshwater Resource Ecological Assessment as part of the Environmental Assessment and Authorisation Process for the Proposed Upgrade of Culverts along Protea Road and Waarburgh Road, Western Cape.  Freshwater Ecological Assessment as part of the Water Use License process for the Daybreak Chickens Abattoir in Delmas, Mpumalanga Province.

71 SAS 219104 June 2019

 Freshwater Ecological Assessment for the proposed Densification of the Residential Development on Portion 230 of the Farm Driefontein 87-ir also known as Germiston Extension 46, Germiston, Gauteng Province.  Freshwater Resource Assessment as part of the Environmental Authorisation and Water Use Licence process for the Proposed Development on Portion 22 and 202 of the Farm Knopjeslaagte as well as Holding 23 of Timsrand AH, Gauteng Province.  Freshwater Resource Verification as part of the Basic Assessment Process for the Proposed Development of a Mixed-Use Township of the Remaining Extent of Portion 54 of the Farm Rietfontein 189 IQ, Gauteng Province.  Freshwater Resource Assessment as part of the Environmental Authorisation and Water Use Licence Application process for the Proposed Rondebult Outfall Sewer, Germiston, Gauteng Province.

72 SAS 219104 June 2019

1. (b) a declaration that the specialist is independent in a form as may be specified by the competent authority I, Stephen van Staden, declare that -  I act as the independent specialist in this application;  I will perform the work relating to the application in an objective manner, even if this results in views and findings that are not favourable to the applicant;  I declare that there are no circumstances that may compromise my objectivity in performing such work;  I have expertise in conducting the specialist report relevant to this application, including knowledge of the relevant legislation and any guidelines that have relevance to the proposed activity;  I will comply with the applicable legislation;  I have not, and will not engage in, conflicting interests in the undertaking of the activity;  I undertake to disclose to the applicant and the competent authority all material information in my possession that reasonably has or may have the potential of influencing - any decision to be taken with respect to the application by the competent authority; and - the objectivity of any report, plan or document to be prepared by myself for submission to the competent authority;  All the particulars furnished by me in this form are true and correct

------

Signature of the Specialist

WATERCOURSE REHABILITATION AND MANAGEMENT PLAN FOR THE PROPOSED ERPM EXPANSION AREA 2 MINE, BRAKPAN SOUTH, GAUTENG PROVINCE

Prepared for

Prime Resources Environmental Consultants

August 2019

Prepared by: Scientific Aquatic Services Report author: J. Liebenberg Report reviewer: K. Marais (Pr. Sci. Nat) S. van Staden (Pr. Sci. Nat) Report Reference: SAS 219104 Date: August 2019

Scientific Aquatic Services CC CC Reg No 2003/078943/23 Vat Reg. No. 4020235273 PO Box 751779 Gardenview 2047 Tel: 011 616 7893 Fax: 086 724 3132 E-mail: [email protected] SAS219104 August 2019

TABLE OF CONTENTS

TABLE OF CONTENTS ...... ii LIST OF FIGURES ...... iii LIST OF TABLES ...... iv GLOSSARY OF TERMS ...... v LIST OF ACRONYMS ...... v 1. INTRODUCTION ...... 1 1.1 Background ...... 1 1.2 Structure of the Rehabilitation plan and report ...... 4 1.3 Watercourse Rehabilitation and Management Plan Framework ...... 5 Principles of the Watercourse Rehabilitation and Management Plan ...... 5 Objectives of the Surface Water Rehabilitation and Management Plan ...... 7 2. PROJECT DESCRIPTION ...... 9 2.1 Windmill Vent Shaft ...... 9 2.2 Witpoortjie Vent Shaft ...... 10 2.3 Assumptions and Limitations ...... 10 3. DESCRIPTION OF WATERCOURSES ...... 11 4. LEGAL FRAMEWORK FOR THE WATERCOURSE REHABILITATION AND MANAGEMENT PLAN ...... 14 5. DESCRIPTION OF IMPACTS ...... 16 5.1 Historic and Current Impacts ...... 16 5.2 Potential Impacts and Results of the Risk Assessment ...... 16 CVB Wetland ...... 16 HSS wetland...... 17 Results of the Risk Assessment ...... 17 6. WATERCOURSE REHABILITATION AND MANAGEMENT PLAN ...... 21 6.1 Roles and Responsibilities ...... 21 6.2 Site Specific Rehabilitation, Implementation and Management Plan ...... 22 Procedure 1: Planning ...... 24 Procedure 2: Alien and Invasive Plant Species Management ...... 26 Procedure 3: Site- Specific Watercourse Rehabilitation ...... 30 6.2.3.1 Task 1: Decommissioning of mining infrastructure and rehabilitation of mining activities ...... 31 6.2.3.2 Task 2: Site Preparation for revegetation and landscaping ...... 31 6.2.3.3 Task 3: Revegetation and Landscaping ...... 33 Procedure 4: Aftercare and monitoring ...... 34 7. CONCLUSION ...... 39 8. REFERENCES ...... 40 ANNEXURE A – RECEIVING ENVIRONMENT BACKGROUND ...... 41 ANNEXURE B – LEGAL REQUIREMENTS ...... 42

ii SAS219104 August 2019

LIST OF FIGURES

Figure 1: Digital satellite image depicting the location of the Witpoortjie Vent Shaft, Windmill Vent Shaft and investigation area in relation to surrounding areas...... 3 Figure 2: Digital satellite image of the delineated watercourses, the Windmill Vent Shaft and Witpoortjie Vent Shaft in relation to the surrounding environment...... 11 Figure 3: Radar plot illustrating the ecological and socio-cultural service provision of the CVB wetland...... 12 Figure 4: Photograph of the CVB wetland associated with the development of the Witpoortjie Vent Shaft...... 12 Figure 5: Representative photograph of alien invasive plant species Cortaderia selloana (Pampas Grass) observed within the CVB wetland habitat...... 12 Figure 6: Representative photograph of trench excavated along north western boundary of the CVB wetland...... 12 Figure 7: Graph illustrating the ecological and socio-cultural service provision of the HSS wetland ...... 13 Figure 8: Photograph of the HSS wetland associated with the development of the Windmill Vent Shaft ...... 13 Figure 9: Photograph of the informal road in contributing to the sedimentation of the HSS wetland during flood events...... 13 Figure 10: Digital satellite image of the HSS wetland, the proposed Windmill Vent Shaft, Investigation Area and the 500m ZoR (GN 509) in relation to the surrounding area...... 19 Figure 11: Digital satellite image of the CVB wetland, the proposed Witpoortjie Vent Shaft, 500m Investigation Area and the 100m ZoR in relation to the surrounding area...... 20 Figure 12: Grouped tasks to aid with the implementation of rehabilitation guidelines and methods...... 30 Figure 13: Digital satellite image depicting monitoring point 1 in relation to the HSS wetland and the Windmill Vent Shaft...... 37 Figure 14: Digital satellite image depicting monitoring point 2 in relation to the CVB wetland and the Windmill Vent Shaft...... 38

iii SAS219104 August 2019

LIST OF TABLES

Table 1: Summary of the freshwater assessment of the CVB wetland associated with the Witpoortjie Vent Shaft (SAS, 2019)...... 12 Table 2: Summary of the freshwater assessment of the HSS wetland associated with the Windmill Vent Shaft (SAS, 2019)...... 13 Table 3: Summary of various parties involved in the implementation of this WRMP...... 21 Table 4: Planning requirements to be considered prior to the commencement of rehabilitation activities...... 24 Table 5: Planning control measures to be adhered to and implemented before undertaken rehabilitation activities...... 25 Table 6: A description of AIPs identified during the field investigation (SAS, 2019)...... 27 Table 7: AIP Monitoring, Control and Eradication Plan requirements...... 28 Table 8: Rehabilitation guidelines and methods: sealing and rehabilitation of vent shafts...... 31 Table 9: Rehabilitation guidelines and methods: buildings, roads, material and other infrastructure...... 31 Table 10: Techniques and guidelines for site preparation...... 32 Table 11: Mechanisms for erosion and sedimentation control...... 32 Table 12: Revegetation and landscaping guidelines...... 33 Table 13: Monitoring actions for the CVB wetland and HSS wetland...... 35

iv SAS219104 August 2019

GLOSSARY OF TERMS

Alien invasive vegetation: Plants that do not occur naturally within the area but have been introduced either intentionally or unintentionally. Vegetation species that originate from outside of the borders of the biome -usually international in origin. Biodiversity: The number and variety of living organisms on earth, the millions of plants, animans and micro-organisms, the genes they contain, the evolutionary history and potential they encompass and the ecosystems, ecological processes and landscape of which they are integral parts. Buffer: A strip of land surrounding a wetland or riparian area in which activities are controlled or restricted, in order to reduce the impact of adjacent land uses on the wetland or riparian area. Hydrology: The study of the occurrence, distribution and movement of water over, on and under the land surface. Indigenous vegetation: Vegetation occurring naturally within a defined area. Watercourse: In terms of the definition contained within the National Water Act, a watercourse means:  A river or spring;  A natural channel which water flows regularly or intermittently;  A wetland, dam or lake into which, or from which, water flows; and  Any collection of water which the Minister may, by notice in the Gazette, declare to be a watercourse;  and a reference to a watercourse includes, where relevant, its bed and banks

LIST OF ACRONYMS

BGIS Biodiversity Geographic Information Systems DWAF Department of Water Affairs and Forestry DWS Department of Water and Sanitation EAP Environmental Assessment Practitioner EIS Ecological Importance and Sensitivity EIA Environmental Impact Assessment EMP Environmental Management Program FEPA Freshwater Ecosystem Priority Areas NEMA National Environmental Management Act PES Present Ecological State SANBI South African National Biodiversity Institute SAS Scientific Aquatic Services subWMA Sub-Water Management Area WMA Water Management Areas WRC Water Research Commission WULA Water Use License Application

v SAS219104 August 2019

1. INTRODUCTION

1.1 Background

Scientific Aquatic Services (SAS) was appointed to compile a Watercourse Rehabilitation and Management Plan (WRMP) for the proposed East Rand Proprietary Mines (ERPM) Expansion Area 2 mine, Gauteng Province, including the Witpoortjie Vent and Windmill shaft (Figure 1). Please refer to Section 2 for more details on the project.

This WRMP was compiled to provide mitigation measures to manage and rehabilitate potential impacts that could affect the Hillslope Seep (HSS) wetland and the Channelled Valley Bottom (CVB) wetland during the proposed expansion and mining activities.

This WRMP follows a system that seeks to achieve a required end state which supports the resource quality objectives for the wetlands and describes how activities that have, or could have a negative impact on the system will be controlled and monitored. This WRMP also identifies the responsible parties and relevant timeframes (where applicable) which will be tasked with implementing these measures. The key aims of the WRMP include:

 Maintenance of the Present Ecological State (PES) of the CVB wetland and HSS wetland associated with the development of the Witpoortjie Vent Shaft and Windmill Vent Shaft, and where possible improve the ecological conditions of the system through rehabilitation of historic anthropogenic activities that have altered the ecological functioning of these systems (refer to Section 2 and 5);

 Minimisation of impacts on surface water and groundwater quality;

 Reinstatement of ecological services and topographical sequences;

 Alien invasive plant species control, protection and the reinstatement of indigenous vegetation;

 Erosion control and siltation management, including topsoil management and bank stabilisation; and

 Prudent monitoring to ensure timeous detection of, and response to damage caused by mining activities and the development of infrastructure.

This WMMP advocates the use of several environmental management tools and mitigatory measures appropriate to the overall planning process of the construction, operational and

1 SAS219104 August 2019

rehabilitation phases of the proposed mining expansion activities and should be implemented by the proponent as soon as it has been approved by all the relevant authorities.

2 SAS219104 August 2019

Figure 1: Digital satellite image depicting the location of the Witpoortjie Vent Shaft, Windmill Vent Shaft and investigation area in relation to surrounding areas.

3 SAS219104 August 2019

1.2 Structure of the Rehabilitation plan and report

This report investigates the need for rehabilitation and maintenance activities for the proposed mining activities. The plan has been structured in the following way:

Chapter 1: Introduction Provides an introduction, the structure of this report, the assumptions and limitations, as well as the relevant legislation.

Chapter 2: Project Description Provides a brief summary of the Witpoortjie Vent and Windmill shaft.

Chapter 3: Description of Watercourses This section includes a summary of the watercourse site assessment findings undertaken by SAS in 2019.

Chapter 4: Legal Framework This section provides a breakdown of the legal framework relevant to the proposed development activities as well as the compilation of this WRMP.

Chapter 5: Impact Assessment Outcomes This section presents a summary of the impact assessment outcomes (as part of the National Environmental Management Act, 1998 (Act No. 107 of 1998) and National Water Act, 1998 (Act No. 36 of 1998) as per the assessment of SAS (2018).

Chapter 6: Watercourse Rehabilitation and Management Plan This section comprises site specific details pertaining to the mitigation and rehabilitation measures that must be implemented. A list of the roles and responsibilities of all individuals involved in the implementation of this WRMP is provided. This section provides the required monitoring actions during rehabilitation and post-construction of the proposed mining activities and infrastructure.

Chapter 7: Conclusion This section summarises the key findings and recommendations based on the recommended rehabilitation and management actions listed and the overall requirements in order to ensure the management of watercourse impacts and to provide the best possible reinstatement and rehabilitation methods for the disturbed areas associated with the watercourses.

4 SAS219104 August 2019

1.3 Watercourse Rehabilitation and Management Plan Framework

Principles of the Watercourse Rehabilitation and Management Plan

To assist in achieving the objectives of the WRMP, a set of principles were applied which contributed to formulating action plans and specific management measures.

Loss of biodiversity puts aspects of the economy, well-being and quality of life at risk, and reduces socio-economic options for future generations. This is of particular concern for the poor in rural areas who have limited assets and are more dependent on common property resources for their livelihoods. The importance of maintaining biodiversity and intact ecosystems for ensuring the on-going provision of ecosystem services, and the consequences of ecosystem change for human well-being, were detailed in a global assessment entitled the Millennium Ecosystem Assessment (MEA, 2005), which established a scientific basis for the need for action to enhance management and conservation of biodiversity.

Sustainable development is enshrined in South Africa’s Constitution and laws. The need to sustain biodiversity is directly or indirectly referred to in a number of Acts, not least the National Environmental Management: Biodiversity Act, 2004 (Act No. 10 of 2004) and is fundamental to the notion of sustainable development. In addition, international guidelines and commitments, as well as national policies and strategies are important in creating a shared vision for sustainable development in South Africa.

Impacts on biodiversity can mainly take place in four ways:  Direct impacts: are impacts directly related to the proposed development activities including project aspects such as site clearing and diversion/abstraction of water.  Indirect impacts: are impacts associated with the zone of influence associated with the proposed development activities, such as the surrounding terrestrial areas and downstream areas on the watercourses.  Induced impacts: impacts that directly attributable to the proposed development activities but are expected to occur due to the activities of the proposed development activities. Factors included here are existing surrounding mining activities and hardened surface within the catchment.  Cumulative impacts: can be defined as the sum of the impact of the proposed development activities as well as the impacts from past, existing and reasonably foreseeable future projects that would affect the same biodiversity resources. Examples include numerous mining developments within the same drainage catchment.

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Given the limited resources available for biodiversity management and conservation, as well as the need for development, efforts to conserve biodiversity need to be strategic, focused and supportive of sustainable development. This is a fundamental principle underpinning South Africa’s approach to the management and conservation of its biodiversity and has resulted in the identification of spatial biodiversity priorities or biodiversity priority areas.

‘Mitigation’ is a broad term that covers all components of the ‘mitigation hierarchy’ defined hereunder. It involves selecting and implementing measures – amongst others – to conserve biodiversity and to protect the users of biodiversity and other affected stakeholders from potentially adverse impacts as a result of anthropogenic activities. The aim is to prevent adverse impacts from occurring or, where this is unavoidable, to limit their significance to an acceptable level.

The mitigation hierarchy, as advocated by DEA et al. (2013) in general consists of the following in order of which impacts should be mitigated: 1. Avoid/prevent impacts: can be done through utilising alternative sites, technology and scale of projects to prevent impacts. In some cases, if impacts are expected to be too high, the “no project” option should also be considered, especially where it is expected that recommended mitigations measures will not be adequate to limit environmental damage and eco-service provision to suitable levels; 2. Minimise impacts: can be done through the utilisation of alternatives that will ensure that impacts on biodiversity and ecosystem services provision are reduced. Impact minimisation is considered an essential part of any development project; 3. Rehabilitate impacts: applicable to areas where impact avoidance and minimisation are unavoidable. As such, impacted areas must be returned to conditions which are ecologically similar to the pre-project condition or an agreed post project land use, for example arable land. Rehabilitation cannot, however, be considered as the primary mitigation toll as even with significant resources and effort of rehabilitation usually does not lead to adequate replication of the diversity and complexity of the natural system. Rehabilitation often only restores ecological function to some degree to avoid ongoing negative impacts and to minimise aesthetic damage to the setting of a project. Practical rehabilitation should consist of the following phases in best practice:  Structural rehabilitation which includes physical rehabilitation of areas by means of earthworks, potential stabilisation of areas as well as any other activities required to develop a long term sustainable ecological structure;  Functional rehabilitation focuses on ensuring that the ecological functionality of the ecological resources associated with the proposed development activities and

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its footprint supports the intended land uses. In this regard, special mention is made of the need to ensure the continued functioning and integrity of the watercourses throughout and after the rehabilitation phase.  Biodiversity reinstatement focuses on ensuring that a reasonable level of biodiversity is re-instated to a level that supports the local land uses. In this regard special mention is made of re-instating vegetation to levels which will allow the natural climax vegetation community or community suitable for supporting the intended land use.  Species reinstatement focuses on the re-introduction of any ecologically important species which may be important for socio-cultural reasons, ecosystem functioning reasons and for conservation reasons. Species reinstatement need only occur if deemed necessary. 4. Offset impacts: The significance of residual impacts should be identified on a regional as well as national scale when considering biodiversity conservation initiatives. If the residual impacts lead to irreversible loss of irreplaceable biodiversity, the residual impacts should be considered to be of a very high significance and offset initiatives are not considered an appropriate way to deal with the magnitude and/or significance of the biodiversity loss. In the case of residual impacts determined to have medium to high significance, an offset initiative may be investigated. If the residual biodiversity impacts are considered of low significance no biodiversity offset is required.

A summary of how the above relates specifically to the proposed development activities in terms of measures which must be applied in order to ensure the minimisation of negative impacts and maximisation of positive impacts as a result of the proposed development activities is provided below:

 Avoiding impacts by not performing environmentally detrimental actions;  Minimising impacts by limiting aspects of an action, optimising processes, structural elements and other design features; and  Rectifying impacts through rehabilitation, restoration, etc. of the affected environment.

Objectives of the Surface Water Rehabilitation and Management Plan

The objectives of this WRMP are to:  Meet the requirements of relevant local and regional authorities;  Identify a range of mitigation measures which could reduce and mitigate the potential impacts on the receiving environment to minimal or acceptable levels;

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 Manage activities to maintain and/ or improve the ecological integrity of the CVB wetland and HSS wetland;  Maximise the ecological functioning and service provision of the CVB wetland and HSS wetland;  Increase the perennial vegetation cover on disturbed and erosion prone areas to reduce the erosive potential of runoff and to trap sediment;  To control and manage Alien and Invasive Plant species (AIPs) and re-introduce indigenous floral species;  To provide an improved and more suitable habitat for faunal species;  Detail specific actions deemed necessary to assist in mitigating the potential environmental impacts on the CVB wetland and HSS wetland;  Ensure as far as is practicable that the measures contained in the report are implemented; and  Propose mechanisms for monitoring compliance with the WRMP and reporting thereon.

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2. PROJECT DESCRIPTION

The ERPM Expansion Area 2 mine includes the development of the Windmill Vent Shaft and Witpoortjie Vent Shaft to undertake mining of the in situ gold resource by means of a sequential underground mining methods.

Shaft sinking and site establishment are proposed to take six (6) years to complete, while the life of mine during the operation and production phase will be 47 years. The decommissioning and rehabilitation of the mine are estimated to take between 2-3 years to complete.

2.1 Windmill Vent Shaft

The surface development area for the Windmill Vent Shaft is approximately 20 Ha in extent. The infrastructure associated with the Windmill Vent Shaft will be developed upgradient from the HSS wetland. Surface infrastructure associated with the development of the Windmill Vent Shaft (within 500 m from the HSS wetland) includes:

1. Berm:  Topsoil will be used to create a berm upstream of the infrastructure area and will be vegetated to screen the residential areas from noise and visual impacts. 2. Buildings:

 Security office, change house, administrative buildings, workshops and stores.

3. Power supply:

 Powerlines and substations are proposed to connect to existing power supply sources.

4. Water Storage Tanks.

5. Fuel storage facility within a bunded area.

6. Road network.

 The existing access roads will be utilised where possible, however a small new road network will be constructed.

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2.2 Witpoortjie Vent Shaft

The Witpoortjie Vent Shaft surface development area is approximately 7 Ha in extent. The infrastructure associated with the Witpoortjie Shaft will be developed approximately 40 m from the CVB wetland and within the 100 m Zone of Regulation (ZoR) (GN R 704). Surface infrastructure associated with the development of the Witpoortjie Vent Shaft and the CVB wetland include the following:

1. Ventilation shaft:

 A 4.8m diameter ventilation shaft is proposed. This shaft is an existing shaft that will be refurbished;

2. Surface ventilation fans;

3. Generator and compressor; and

4. Access roads.

2.3 Assumptions and Limitations

The site layout plan for the Witpoortjie Vent Shaft was not finalised at the time of the compilation of the WRMP. It is recommended that all infrastructure be situated outside the 100m ZoR (GN R 704) to limit impacts on the CVB wetland.

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3. DESCRIPTION OF WATERCOURSES

Background information on the freshwater ecological aspects pertaining to the ERPM Expansion Area 2 mine is presented in Appendix A.

Two (2) watercourses– 1) a CVB wetland; and 2) a HSS wetland were identified within the zone of regulation1 (SAS, 2019). The digital satellite image depicting the delineated watercourse is illustrated in Figure 2.

Figure 2: Digital satellite image of the delineated watercourses, the Windmill Vent Shaft and Witpoortjie Vent Shaft in relation to the surrounding environment.

Table 1 – Table 2 provide a summary of the freshwater assessment of the two (2) identified wetlands (SAS, 2019).

1 In accordance with GN509 of 2016, a regulated area of a watercourse for section 21c and 21i of the National Water Act, 1998 (Act No. 36 of 1998) is defined as:  the outer edge of the 1 in 100-year flood line and/or delineated riparian habitat, whichever is the greatest distance, measured from the middle of the watercourse of a river, spring, natural channel, lake or dam;  in the absence of a determined 1 in 100-year flood line or riparian area the area within 100 m from the edge of a watercourse where the edge of the watercourse is the first identifiable annual bank fill flood bench; or  a 500 m radius from the delineated boundary (extent) of any wetland or pan.

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Table 1: Summary of the freshwater assessment of the CVB wetland associated with the Witpoortjie Vent Shaft (SAS, 2019).

Summary of results: Freshwater Assessment Hillslope Seep Wetland

Figure 4: Photograph of the CVB wetland associated with Figure 3: Radar plot illustrating the ecological and socio- the development of the Witpoortjie Vent Shaft. cultural service provision of the CVB wetland. Category: D (Largely Hydrology PES modified) The CVB wetland is primarily hydrologically driven by overland flow from the greater catchment. The hydrological regime of the wetland Ecoservice provision Intermediate has been largely modified, predominantly as a result of modifications EIS discussion Moderate to the active channel through the construction of artificial instream Category: D (Largely impoundments, as well as increased water inputs from altered runoff REC Category modified) patterns in the greater catchment as a result of the extensive mining activities in the area, some of which traverse the wetland. Additional modifiers to the hydrology of the system include the construction of informal and municipal road and pipeline crossings which have altered flow patterns. Additionally, a trench has been excavated along the north western boundary of the wetland which has resulted in erosion due to the concentrated flow of water (Figure 7).

Water quality The following in situ water quality parameters were measured during the site assessment: pH – 7.48; electrical conductivity – 207mS/m;

and temperature – 12.6°C. According to the Resource Water Quality Objectives (RWQO) of South Africa (DWA, 2011), the pH falls within

the ideal range limit. The electrical conductivity, however, falls within the unacceptable range limit. It is anticipated that the water quality of the wetland is thus impacted upon by the extensive mining practices, and industrial and residential development in the greater catchment. Figure 5: Representative photograph of alien invasive plant species Cortaderia selloana (Pampas Topography: Geomorphology and sediment balance Grass) observed within the CVB wetland habitat. The historic construction of artificial impoundments within the active channel of the wetland, as well as infilling and excavation due to mining activities, have had a significant impact on the WATERCOURSE DRIVERS geomorphological processes of the wetland. Increased water inputs, and thus increased sediment inputs, arising from the road infrastructure that traverse the system has likely resulted in greater sediment loads within the wetland.

Habitat and biota The wetland vegetation community is considered to be modified due to proliferation of alien and invasive plant species within the permanent, seasonal and temporary zones of the wetland (Figure 6). Despite these modifications to the vegetation community, the wetland is well vegetated with various indigenous species such as Phragmites australis, which plays an important ecological role for wetlands as it offers shelter and nesting material for birds and other faunal species. According to the Gauteng C-Plan (2011), the CVB wetland is situated Figure 6: Representative photograph of trench within a Critical Biodiversity Area (CBA) considered important for excavated along north western boundary of the CVB “Orange” listed plant habitat, “Red” listed bird habitat and for primary wetland. vegetation.

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Table 2: Summary of the freshwater assessment of the HSS wetland associated with the Windmill Vent Shaft (SAS, 2019).

Summary of results: Freshwater Assessment Hillslope Seep Wetland

Figure 7: Graph illustrating the ecological and socio- Figure 8: Photograph of the HSS wetland associated with cultural service provision of the HSS wetland the development of the Windmill Vent Shaft Category: C (Moderately Hydrology PES modified) It is likely that the wetland is primarily hydrologically driven by hydropedological hillslope processes. Runoff from the surrounding Ecoservice provision Moderately low area, mainly dominated by open areas which were historically EIS discussion Moderate cultivated, enters the wetland. Additionally, it is anticpated that the Category: C (Moderately wetland may receive some runoff from the mining activities situated REC Category modified) upgradient of and in close proximity to (approximately 600m) the wetland, thus altering the hydrological processes of the wetland.

Water quality No surface water was present during the time of assessment and thus, water quality parameters were not measured on site. It is, however, anticipated that the water quality of the wetland may likely impacted upon by contaminated runoff in the form of sediment from the surrounding open land, as well as potential contaminants from the existing upgradient mining area.

Topography: Geomorphology and sediment balance The historic cultivation of the Windmill Vent Shaft area for agriculture has had a significant impact on the geomorphology of the wetland. Increased water inputs from the surrounding open land, and thus increased sediment inputs, have likely resulted in greater sediment loads within the wetland.

WATERCOURSE DRIVERS

Habitat and biota The wetland vegetation community is considered to be modified since alien invasive plant species were present within the wetland. Despite these modifications to the vegetation community, the wetland is well vegetated and is still considered to provide habitat for faunal and floral species. According to the Gauteng C-Plan (2011), the HSS wetland falls within an Ecological Support Area (ESA), which are natural, near- natural, degraded or heavily modified areas required to be maintained in an ecologically functional state to support CBAs and/or Protected Figure 9: Photograph of the informal road in Areas (PA). contributing to the sedimentation of the HSS wetland during flood events.

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4. LEGAL FRAMEWORK FOR THE WATERCOURSE REHABILITATION AND MANAGEMENT PLAN

The following legislative documents were considered and the aspects which are pertinent to watercourse management including the rehabilitation of disturbed areas, were utilised.

 The Constitution of the Republic of South Africa, 1996 (Act No. 108 of 1996);  The National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA);  The Mineral and Petroleum Resources Development Act, 2002 (Act 28 of 2002) (MPRDA);  The National Environmental Management: Biodiversity Act, 2004 (Act No. 10 of 2004) (NEMBA);  The National Environmental Management: Biodiversity Act, 2014 (Alien and Invasive Species Regulations, 2014);  The National Water Act, 1998 (Act No. 36 of 1998) (NWA);  Government Notice 509 as published in the Government Gazette 40229 of 2016 as it relates to the National Water Act, 1998 (Act No. 36 of 1998); and  Government Notice 704 as promulgated in Government Gazette 20119 of 1999 as it relates to the National Water Act, 1998 (Act No. 36 of 1998).

Section 21 of the National Water Act, 1998 (Act No. 36 of 1998) lists the following activities as water uses:  Section 21 (c): impeding or diverting the flow of water in a watercourse; and  Section 21(i): altering the bed, banks, course or characteristics of a watercourse.

The rehabilitation process is set to minimise the impacts of the proposed development activities on the identified watercourses. These activities trigger a Section 21(c) and (i) water use as stipulated by the National Water Act, 1998 (Act No. 36 of 1998) as well as activities 12 and 19 of the Environmental Impact Assessment Regulations Listing Notice 1 of 2014 (as amended) (GN327) as it relates to the National Environmental Management Act, 1998 (Act No. 107 of 1998).

The conditions for Section 21(c) and (i) activities, in terms of Government Notice 509 of 2016 require that a WRMP be developed and must address the following: 1. Identify a WRMP domain, preferably from a whole -catchment perspective;

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2. Identify an accountable, representative body that should take unbiased custodianship of the WRMP and drive its implementation; 3. Identify key stakeholders; 4. Identify major drivers of watercourse disturbance and instability - human and natural, and their primary and secondary effects; 5. Complete a risk assessment as per the Department of Water and Sanitation (DWS) Risk Assessment Matrix for identified impacts and their mitigation activities; 6. Significance of perceived impacts on the drivers and receptors of the watercourses; 7. Solicit input from stakeholders on their priorities and objectives; 8. Define best practice measures for rehabilitation and maintenance implementation; 9. Design a plan for ecological monitoring which is specifically linked to the stated objectives; and 10. Develop an implementation programme and review mechanism.

The report should contain supporting technical information used to ensure low risk to resource quality such as: a) Impact assessment and mitigation report completed by an independent consultant as required by the National Environmental Management Act, 1998 (Act No. 107 of 1998) and the National Water Act, 1998 (Act No. 36 of 1998); b) All the relevant specialist reports supporting the proposed mitigation measures; i. Specialist reports must address the level of modification /risk posed to resource quality i.e.: flow regime, water quality, geomorphological processes, habitat and biota of the watercourses and contain Present Ecological state (PES) and Ecological Importance and Sensitivity (EIS) data for relevant watercourses. c) Environmental Management Plan (EMP) giving effect to all actions required to mitigate impacts (What, When, Who, Where and How); d) Best practices applicable to these activities, where applicable; e) Generic designs and method statements, where applicable; f) Norms and standards, where available; g) Monitoring programme that must include "present day" conditions to be used as base line values; h) Monitoring, auditing and reporting programme (reports must be sent on request to the region or Catchment Management Agency (CMA)); and i) Internalised controls and auditing, where applicable.

Please refer to Annexure B for additional legislative requirements.

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5. DESCRIPTION OF IMPACTS

5.1 Historic and Current Impacts

Long term habitat degradation was evident within the CVB wetland and HSS wetland as a result of historic anthropogenic and current activities discussed in Table 1 and 2.

5.2 Potential Impacts and Results of the Risk Assessment

The potential impacts and risk assessment results associated with the Windmill Vent Shaft and Witpoortjie Vent Shaft were taken from a report entitled: “Freshwater Resource Ecological Assessment as part of the Environmental Authorisation and Water Use Licence Application process for the proposed ERPM Expansion Area 2 Mine, Brakpan South, Gauteng Province” (SAS, 2019).

Digital satellite images are depicted in Figure 10 – Figure 11 illustrating the proposed ERPM expansion area, the 100 m ZoR (GN R704) and delineated wetlands. The following key potential impacts associated with the construction, operational and decommissioning of the Windmill Vent Shaft and Witpoortjie Vent Shaft were identified:

CVB Wetland The following potential impacts to the CVB wetland were identified related to the rehabilitation of the Witpoortjie Vent Shaft:

 Runoff with high sediment loads entering the wetlands as a result of exposed soil from cleared areas, smothering the wetland vegetation and thus altering the wetland habitat and flood regime;  Compaction of soil due to the movement of construction machinery leading to alterations of wetland hydrological processes;  Vegetation degradation as a result of subsequent loss of habitat for indigenous wetland species;  Alien invasive species proliferation;  Increased flood peaks as a result of formalisation and concentration of surface runoff in clean water diversion structures leading to erosion and incision and altered characteristics of the wetlands;  Changes to geomorphological processes leading to erosion and sedimentation;  Reduction in volume of water entering the wetland, leading to loss of recharge of the wetlands;

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 Potential creation of a cone of depression, which may drain water from surrounding wetland habitats, thus resulting in desiccation of the wetlands;  Water entering the shafts as a result of ingress may necessitate dewatering of the shafts, resulting in the discharge of dirty water into the surrounding wetland environment;  Impacts on water quality with specific mention of turbidity, salinisation, eutrophication and addition of toxicants; and  Cumulative impacts on wetland ecology as a result of sedimentation and loss of recharge to the downgradient wetland areas.

HSS wetland The following potential impacts to the HSS wetland were identified related to the proposed Windmill Shaft:  Runoff with high sediment loads entering the wetlands as a result of exposed soil from cleared areas, smothering the wetland vegetation and thus altering the wetland habitat and flood regime;  Compaction of soil due to the movement of construction machinery leading to alterations of wetland hydrological processes;  Vegetation degradation as a result of alien invasive species proliferation due to the disturbed soil profile;  Changes to geomorphological processes leading to erosion and sedimentation;  Potential creation of a cone of depression, which may drain water from surrounding wetland habitats, thus resulting in desiccation of the wetlands;  Water entering the shafts as a result of ingress may necessitate dewatering of the shafts, which may result in the discharge of dirty water into the surrounding wetland environment;  Impacts on water quality with specific mention of turbidity, salinisation, eutrophication and addition of toxicants; and  Cumulative impacts on wetland ecology as a result of sedimentation and loss of recharge to the downgradient wetland areas.

Results of the Risk Assessment

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anticipated to pose a low risk to the wetlands. However, the outcome of the Risk Assessment indicated that certain activities associated with the proposed ERPM expansion, such as the development of the shafts and clean and dirty water separation systems, will pose a moderate risk to the receiving freshwater environment during the construction phase.

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Figure 10: Digital satellite image of the HSS wetland, the proposed Windmill Vent Shaft, Investigation Area and the 500m ZoR (GN 509) in relation to the surrounding area.

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Figure 11: Digital satellite image of the CVB wetland, the proposed Witpoortjie Vent Shaft, 500m Investigation Area and the 100m ZoR in relation to the surrounding area.

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6. WATERCOURSE REHABILITATION AND MANAGEMENT PLAN

The National Water Act, 1998 (Act No. 36 of1998), imposes the responsibility of “duty of care” on landowners and other responsible parties to rehabilitate “damaged” and “lost” watercourses. Section 6 comprises details pertaining to the rehabilitation measures that must be implemented.

A list of the roles and responsibilities of the individuals involved in the implementation of this WRMP is provided. This section also provides the required actions and control measures to be implemented during planning, rehabilitation and post-rehabilitation phases.

6.1 Roles and Responsibilities

Table 3 provides a summary of the various parties that are involved with the implementation of this WRMP as well as their responsibilities.

Table 3: Summary of various parties involved in the implementation of this WRMP.

Party Responsibility  The Proponent will be responsible for the appointment of a suitably qualified Environmental Manager for the construction phase of the project;  A management body (I.e. Mine Manager) must be appointed to ensure compliance with the WRMP; Proponent  The Proponent will be responsible for ensuring all Contractors receive a copy of this document and understand its contents;  The Proponent is responsible to ensure there is sufficient funding for the required rehabilitation and management actions as set out in this WRMP; and  The Proponent can also be the Mine Manager should they not wish to appoint a separate manager.  The Mine Manager must ensure a clear communication line between all parties working on the project, to ensure all environmental concerns and measures as stipulated within this WRMP are implemented/adhered to;  The Mine Manager should have direct communication with the Proponent and Environmental Manager;  The Mine Manager should call a meeting with all responsible parties should there be conflict/ Mine Manager remediation requirements to ensure a suitable solution is found and implemented;  The Mine Manager must ensure that there is sufficient funding and resources for an Environmental Manager to adequately perform their role; and  The Mine Manager must ensure that the WRMP is implemented and that suitable penalties are in place for non-conformance to the WRMP by Contractors (as indicated by the Environmental Manager).  Issue all specifications/ instructions/ drawings to the Contractor;  Must immediately inform the Mine Manager and Environmental Manager if any changes to the project are envisaged; Engineering  Must immediately inform the Mine Manager and Environmental Manager if any aspects of the Manager WRMP and/or Record of Decision (RoD) for the relevant authorities cannot be complied with; and  Must remain in communication with the Environmental Manager and the Mine Manager to ensure that any design changes required are issued to the Contractor. Environmental  The Environmental Manager is the person responsible for the monitoring of the implementation of Manager the WRMP during the implementation of the activities and for reporting on the degree of

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Party Responsibility compliance. The Environmental Manager should ideally be appointed at the start of construction activities and be responsible for ensuring that all rehabilitation activities are implemented. The Environmental Manager is mandated to do the following: o Ensure that all Contractors/ subcontractors/ employees/ construction workers are fully aware of their environmental responsibilities. This should take the form of an initial environmental awareness-training program in which requirements of this document will be explained; o Monitor site activities on a regular basis to ensure that there is minimal environmental impact due to construction activities. A monitoring report should be submitted to the Contractor, the Civil Engineer (should there be any design changes required) and the Mine Manager; o Ensure that a ‘hotline’ exists for reporting incidents and resolving any problems rapidly; o The Environmental Manager must regularly audit the operation and establish whether the measures in the WRMP are applied, where after the Environmental Manager reports to the lead Mine Manager; o All reports compiled by the Environmental Manager must be submitted to the relevant compliance office within the DWS and any other legal authorities; o The Environmental Manager has the authority to stop works if in his/her opinion there is/may be a serious threat to or impact on the environment caused directly by the construction operations; and o Conduct a final environmental audit and a review of management and rehabilitation measures.  Should the appointed Environmental Manager not have any freshwater ecological experience, a suitably qualified Freshwater Ecologist should be appointed to assist the Environmental Manager as and when needed.  The Contractor/s in this case refers to any contractor/s on site, including the mining staff / contractor/s and sub-contractors on any item of infrastructure being erected or demolished; or contractors appointed to mine on behalf of the proponent;  Such contractor/s will take full responsibility for each of his/her employees and any penalties imposed;  The Contractor must immediately inform the Mine Manager and Environmental Manager if any Contractor changes to the project are envisaged and if any aspects of this WRMP or the RoD cannot be complied with;  All design change instructions must come from the Mine Manager and/or Engineering Manager.  It is the responsibility of the Contractor/s to ensure that the measures stipulated within this WRMP are adhered to; and.  Should the Contractor require clarity on any aspect of the WRMP the Contractor must contact the Environmental Manager for advice.

6.2 Site Specific Rehabilitation, Implementation and Management Plan

Two (2) focus areas for rehabilitation have been identified within the ERPM Expansion Area 2 mine: 1. All areas within the proposed activity footprint (Section 2); and 2. Any other areas outside the activity footprint that may have been accidentally disturbed during the construction and mining activities.

This Implementation plan is based on four (4) procedures which include:

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Procedure 1 • Initial planning before undertaking the proposed mining and Planning rehabilitation activities.

All plans and authorisations must be in place prior to commencement of the proposed mining and rehabilitation activities. This includes but it not limited to: a) Ensure all the required authorisations and permits were obtained for rehabilitation activities.; b) Appointment of a Contractor and Environmental Manager as well as any technical and/or specialist consultants need to be retained; c) Planning for on-site requirements; d) Inform all mining staff and the rehabilitation team of the contents and importance of the Rehabilitation and Management Plan; and e) Timeframes and budgetary allowances.

Procedure 2 • Best time is during spring and summer (September – April) during AIPs management the growing season

Before any rehabilitation activities can commence, the rehabilitation areas must be cleared of AIPs.

Procedure 3 • Tasks include: Decommisioning of mining infrastrucutre and Site specific watercourse rehabiliation rehabiltiation of mining activities, site preparation for revegetation and landscaping and revegetation and landscaping.

The rehabilitation of disturbed areas associated with the above-mentioned focus areas.

Procedure 4 Aftercare and monitoring • Post closure aftercare and monitoring

Prudent monitoring of infrastructure and the rehabilitated areas associated with the CVB wetland and HSS wetland as well as the watercourse itself is of utmost importance. A list of monitoring and auditing requirements has been provided to maximise the success of the implementation of the control measures.

The above mentioned procedures have been expanded upon in greater detail in the sections that follow.

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Procedure 1: Planning

Economically feasible and successful rehabilitation are dependent upon cogent conceptual planning. One of the aims of the planning process, is to limit edge effects and residual impacts of the proposed ERPM Expansion Area 2 mine. Table 4 provides requirements to be considered before any rehabilitation activities commence.

Table 4: Planning requirements to be considered prior to the commencement of rehabilitation activities.

Activity 1: Planning 1.1 Obtaining all relevant authorisations and permits Before rehabilitation activities can commence all necessary permits and authorisations will be required, including but not limited to:  Environmental Authorisation (as applicable); and  Water Use Authorisation. Note: If any plants or seeds will be harvested from the surrounding area for revegetation purposes, a permit may be required from the Gauteng Department of Agriculture and Rural Development (GDARD) prior to plant harvesting.

1.2. Appointment of a Contractor and all required specialists During the planning phase certain aspects need to be considered in order to effectively implement this plan. This includes:  Appointment of a suitably qualified Contractor(s) to undertake the required work;  Appointment of an Environmental Manager to audit and monitor the rehabilitation activities as well as to undertake the required post rehabilitation monitoring;  Appoint any specialist consultants required for guidance, management and monitoring that may need to be retained; and  The Environmental Manager is to compile a monthly audit report indicating all observations, actions and any remediation measures that were implemented and the reports are to be submitted to the competent authorises. Note: Should the Contractor not have the appropriate expertise for implementation of this plan then it is the responsibility of the Contractor to retain a suitably qualified freshwater ecologist to oversee the implementation.

1.3 Budgetary Allowance A rehabilitation budget needs to be prepared prior to the commencement of rehabilitation activities.

1.4 Timing Rehabilitation of disturbed watercourses should commence as soon as possible and should optimally be concurrent as work progress.

1.5. General requirements The planning control measures (Table 5) must be adhered to and implemented as part of the planning phase.

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Table 5: Planning control measures to be adhered to and implemented before undertaken rehabilitation activities.

GENERAL REQUIREMENTS Responsible Persons Proponent Mine Manager Engineering Environmental Contractor Manager Manager General Management  The CVB wetland and HSS wetland should be demarcated as a “No-Go” area (areas not affected by the development of the shaft infrastructure);  The areas must not be entered, unless it is to undertake the necessary rehabilitation activities;  Signage should be displayed at points at each wetland informing contractors the importance and need for wetland conservation and that entry is prohibited;  Footprint areas must be kept to a minimum. Where possible, all infrastructure associated with the Witpoortjie Vent Shaft should be located outside the 100 m ZoR (GN R704). Erosion and Sedimentation Control  Undertake vegetation clearing in a phased manner to reduce the exposure time of bare soils at any time to limit erosion and siltation of the wetlands;  Providing sediment filtering or sediment traps, in advance and in conjunction with rehabilitation activities, to prevent contaminated water leaving the site;  Limit areas of erodible material exposed to those areas being actively worked; and  A photographic survey must be undertaken of any eroded areas within the footprint of the Witpoortjie Vent Shaft and Windmill Vent Shaft and must be repaired or monitored as required. Topsoil Management  Undertake topsoil stripping with one (1) backhoe scoop or 20-30 cm of the upper soil of topsoil layer;  Mixture of the lower and upper layers of the excavated topsoil should be kept to a minimum, so as for later usage as part of rehabilitation activities;  Undertake topsoil stripping in dry conditions to avoid excessive compaction;  Store stripped topsoil in heaps no higher than 2m;  Keep handling of topsoil to a minimum;  Keep topsoil strictly separate from subsoil and other material stockpiles;  All exposed soils must be protected for the duration of the construction phase with a suitable geotextile (e.g. hessian sheeting) to prevent AIP establishment; and  Clearly demarcate topsoil stockpiles with a hessian barrier as a “No-Go” area. Soil Management  All excess material removed as part of the mining activities must be used for backfilling and soil profiling;  At no point may this material be arbitrarily disposed of on site or within a watercourse;  Excavated overburden should be kept free from any sources which may result in contamination and it should be ensured that the minimum surface area is taken up by waste rock dumps;  Product stockpiles, waste rock dumps and any excavated soil should be stockpiled outside of the delineated wetlands and 100 m ZoR as defined by Regulation 704;  Topsoil intended for rehabilitation stockpile heights should be limited to three or four metres to prevent loss of structural integrity of the soil;  Silt fences must be placed around product stockpiles to intercept runoff, reduce flow velocity and prevent sediment entering the watercourse;  Silt fences to be placed as far as possible from the toe of the stockpile, but at least 1 m from the toe to ensure trapping of sediments and management of edge effects;  The rows of the silt fences should be bowed at the last 2m of each section to prevent erosion and loss of silt on the end of the fence line;  Silt fences need to be inspected weekly and before a forecast of a rainfall event, and all damage must be repaired immediately; and  Silt deposits must be removed after each rainfall event and the cleared silt must not be placed down slope of the silt fence.

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Pollutant and Waste Management  No discharge of effluents or polluted water is permitted into a watercourse or the area surrounding the proposed infrastructure area and the mine must ensure strict compliance with Regulation GN704 at all times. In this regard specific mention is made of the need to develop water management controls prior to development of the remainder of the surface infrastructure components; and  If soil contamination occurs (due to a spill), the soil should be removed from the site and disposed of and treated appropriately. Hazardous Chemical Substances  Adequate storage facilities for the storage of oils, paints, grease, fuel, chemical and hazardous materials to be utilised must be provided to prevent contamination of soil and groundwater;  Storage areas must be demarcated and fenced, not be located within proximity to the watercourse and must be placed on impermeable surfaces such as concrete bund to prevent contamination;  All fuel storage drums must be designed in accordance with the relevant oil industry standards, SABS Code and other relevant requirements; and  All waste must be removed from the site and disposed of at a licensed landfill site. Concrete Mixing  Ready mix concrete rather than concrete batching should be the preferred alternative;  Should concrete need to be mixed, all wet and dry material should be stored outside the 100 m ZoR (GN704) and should be covered and contained to prevent contact with rainfall or runoff;  Concrete mixing/ batching must be undertaken on an impermeable surface to prevent soil and groundwater pollution. The high alkalinity associated with cement, which can dramatically affect and contaminate both soil and groundwater. The following recommendations must be adhered to:  A washout area should be designated outside of the delineated boundary of the wetland and 100 m ZoR and wash water should be treated on-site or discharged to a suitable sanitation system;  Cement bags must be disposed of in the demarcated hazardous waste receptacles and the used bags must be disposed at a designated hazardous waste disposal facility. Spilt or excess concrete must be disposed of at a suitable landfill site. Chain of custody documentation must be kept available at site. Mitigate impacts associated with a cone of depression.  A geohydrological investigation must be undertaken for the area to determine the potential impacts that dewatering may have on the surrounding wetland features. This is of importance especially if the wetland features are groundwater sourced and/or for decanting water into the watercourses;  Upstream dewatering boreholes should be considered in order to minimise the creation of dirty water within the underground mine voids, and this clean water should be used to recharge the watercourse downstream of the study area;  Measures to contain and reuse as much water as possible within the mine process water system should be undertaken;  Very strict control of water consumption and detailed monitoring must take place, and all water usage must continuously be optimised; and  All recommendations made by the specialist geohydrologist must be followed. Prevention of potential decant from the shafts to the wetlands  The guidance of the geohydrological studies must be followed to manage the risk and impact associated with the decant of groundwater which may potentially contaminate the wetlands;  The cap and/ or seal for the closure of the vent shafts must be designed to resist water pressure and / or surface overload; and  The cap and seal must be designed and approved professional engineer.

Procedure 2: Alien and Invasive Plant Species Management

AIPs have a number of detrimental effects on biodiversity, from nutrient enrichment of watercourses, increased erosion, outcompeting indigenous floral vegetation and limiting habitat diversity and for availability for faunal species.

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AIP were identified at the study area. A: Arundo donax L. (Giant reed, Spanish Reed- Category 1b); B: Cortaderia selloana (Pampas Grass- Category 1b); C: Tagetes minuta (Tall Khaki Weed – not listed). A description of the identified AIPs is provided in Table 6.

The National Environmental Management Biodiversity Act, 2004 (Act No. 10 of 2004) (NEMBA) Section 73 requires every person to exercise a Duty of Care relating to invasive species within their property, and as such the landowner is responsible for AIP control. Table 7 provides requirements for AIP monitoring, control and eradication.

Table 6: A description of AIPs identified during the field investigation (SAS, 2019).

Photograph Description and Problem Description: Arundo donax is a tall and vigorous aquatic reed growing 2- 6m high spreading from horizontal rootstocks. Pale green to bluish green leaves and leaf sheaths that are persistent on the stems. Cream or brown, compact, erect, spear-shaped silky inflorescences appear at the tip all year round.

The problem and need for control: Arundo donax is regarded as an invasive in many parts of the world, particularly problematic on watercourse banks. In densely infested areas Arundo donax has replaced native plants along rivers, thereby interfering with water flow and displacing watercourse habitat. Colonies of Arundo donax covering hundreds of hectares have been recorded. Arundo donax is highly flammable and can change fire regimes in invaded areas, thereby transforming riparian and wetland communities of native plants into solid stands of this species. Arundo donax has been nominated as among 100 of the "World's Worst" invaders by the IUCN Invasive Species Specialist Group and it has been listed as a noxious alien invasive plant in South Africa (prohibited plants that A must be controlled). They serve no economic purpose and possess characteristics that are harmful to humans, animals or the environment. Description: Cortaderia selloana is a vigorous, tussock grass up to 3,5m in diameter, with flowering stalks up to 4m high. Greyish- or bluish-green leaves with rough margins. Silvery-white to pink or mauve, feathery inflorescences appear from February to April. This grass invades riverbanks and seasonally wetland habitats.

The problem and need for control: Cortaderia selloana threatens the land of conservation value. It has the ability to reach distant open spaces quickly and to blanket them with very rapid growth. Native plant communities can be quickly overcome by the invasion of Cortaderia selloana. Cortaderia selloana invades disturbed areas such as cleared bush margins, burned areas and firebreaks where it competes with and smothers other vegetation, and provides habitat for rats and mice. The build-up of dry material from B Cortaderia selloana such as dead leaves, leaf bases and flowering stalks creates a significant fire hazard.

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Description: Tagetes minuta is an erect, woody, annual, herbaceous weed, up to 2 m tall. Stems are unbranched or branching repeatedly in the upper parts, grooved or ridged. Stems are green at first, but changes to brownish or yellowish after flowering.

The problem and need for control: Tagetes minuta is a fast-growing annual weed which competes with crops and interferes with their management or harvest. Tagetes minuta contain strong scented secondary compounds that might have unpredicted effects to ecosystems.

Table 7: AIP Monitoring, Control and Eradication Plan requirements.

An AIP Monitoring, Control and Eradication Plan must be developed for the property to ensure compliance with NEMBA. The following eight (8) steps should be considered.

Step 1: Survey Step 2: Step 8: Identify Monitor species

Step 7: Step 3: Impleme Prepare nt map Controls

Step 6: Step 4: Schedul Prioritise e control areas Step 5: Prepare Budget

Requirements: Content of the AIP Control Plan Description Extent and distribution of the invasive species on the property 1. Details of the property, name, address and 1. Reflect AIP infestation as a percentage (%) cover per area. Prepare province; a map of area showing the property boundaries; 2. A map indicating the location of the 2. Divide the property into manageable units (management units), property with administrative boundaries of reflected as polygons on the property map. Use natural boundaries local or district municipality and province; (rivers) or infrastructure (roads, fences) to distinguish between the 3. Types of landuse; management units; 4. Property size in hectares (ha); 3. Assign an alpha-numeric identification number using the first three letters of the property name followed by a three digit number, 5. Contact details and name of the starting at 001; landowner(s); 4. Survey each management unit, list and describe the species present 6. Purpose of the control plan; according to their size (i.e. seedlings, young, mature). Also indicate 7. Timeframe: the timeframe for what proportion (percentage %) of the management unit is covered implementation should be realistic by the invasive plants, capture the information as follow: depending on the property size, infestation a. Management Unit and hectares levels, species present and available funding. (Timeframe can range between 3 b. Extent of overall invasion (%) and 10 years); and c. Comments and remarks; and

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8. The desired result (e.g. remove invasive d. Priority (High: clear within 6 - 12 months, Medium 12 - 24 plants and restore grassland habitat) months; Low 24 + months). should be determined. Objectives and actions 9. A list of all AIPs on the property detected 1. Set objectives to demine the desired state to reach compliance. during the survey (The list to include 2. Provide actions to reach the relevant objectives. The following are Species name, common name and examples of objectives: NEMBA Category). a. Objective 1: Control AIP Infestation - Bring the AIP infestation

on the property under control by 2025 b. Objective 2: Prevention - put measures in place to prevent the introduction of new NEMBA listed IAS onto the property, and from spreading from the property to neighbouring properties. c. Objective 3: Early Detection & Rapid Response (EDRR) and eradication - To detect emerging IAS through regular surveys and remove them before they become established, produce seeds or offspring and start spreading.

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Procedure 3: Site- Specific Watercourse Rehabilitation

The outcome of the Risk Assessment (SAS, 2019) indicated that certain activities associated with the proposed ERPM Expansion Area 2 mine were likely to pose a “low to medium” risk of disturbance to the HSS wetland and CVB wetland.

A site-specific WRMP has been developed to rehabilitate disturbance within the focus areas (Section 6.2) and with the primary aim to improve the ecological state and functioning of the HSS wetland and CVB wetland. The success of the rehabilitation efforts is highly dependent upon cogent conceptual planning and design activities undertaken at the early stage of the project (Section 6.2.1).

Practical guidelines and methods were included in the WRMP to achieve a desired end result through rehabilitation interventions, once mining activities have ceased.

The rehabilitation guidelines and methods were grouped into tasks (Figure 12) to further aid with the implementation thereof.

Task 1 Task 2 Decommisioning of mining Task 3 Site Preparation for infrastrucutre and Revegetation and revegetation and rehabilitation of mining andscaping landscaping activities.

Figure 12: Grouped tasks to aid with the implementation of rehabilitation guidelines and methods.

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6.2.3.1 Task 1: Decommissioning of mining infrastructure and rehabilitation of mining activities

The rehabilitation guidelines and methods for the decommissioning of mining infrastructure and rehabilitation of mining activities are illustrated in Table 8 - 9.

Table 8: Rehabilitation guidelines and methods: sealing and rehabilitation of vent shafts.

SEALING AND REHABILITATION OF VENT SHAFTS Responsible Persons Proponent Mine Manager Engineering Environmental Contractor Manager Manager Removal of infrastructure associated with vent shaft  All material and infrastructure associated with the vent shaft must be taken to a site identified for reuse (if possible);  All material and infrastructure not in a reusable condition, must be taken to a suitable disposal facility to ensure any land or water contamination is prevented; and  The material must be taken to a suitable landfill facility to ensure that all surfaces in the area will not contribute to the contaminant land of any overland water flow. Decommissioning, sealing and capping of vent shaft.  Decommission, sealing and capping of the vent shaft must be strictly according to the engineering specifications of a Professional Engineer; and  The sealing and capping of the vent shaft must be signed off/ approved by the Professional Engineer upon completion.

Table 9: Rehabilitation guidelines and methods: buildings, roads, material and other infrastructure.

BUILDINGS, ROADS, MATERIAL AND OTHER INFRASTRUCTURE Responsible Persons Proponent Mine Manager Engineering Environmental Contractor Manager Manager Removal of buildings, roads, and other infrastructure and material  All materials, infrastructure, rubble, stockpiles and other mine residues must be removed after mining activities were completed and must be taken to a suitable disposal facility to ensure all surfaces in the area will not contribute to the contaminant land of any overland water flow; and  Soil must be tested for contamination, and if contamination is discovered the soil must be removed and disposed at an appropriate disposal facility.

6.2.3.2 Task 2: Site Preparation for revegetation and landscaping

Prior to commencing with any re-vegetation and/ or landscaping activities, it is important that disturbed areas are adequately prepared to increase rehabilitation success. Techniques and guidelines for site preparation are provided in Table 10 – Table 11.

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Table 10: Techniques and guidelines for site preparation.

TECHNIQUES FOR SITE PREPARATION Responsible Persons Proponent Engineering Manager Environmental Manager Contractor Erosion and Sedimentation Management: Reshape, refill and stabilise disturbed and eroded areas.  All areas disturbed focus areas (Section 6.2) must be rehabilitated to provide stability. Mechanisms for stability and erosion control are provided in Table 11;  Natural substrate material should be used for this work and no foreign material should be brought in due to the risk of introducing alien and/or invasive plant matter or leachate;  Disturbed and infilled areas should be shaped to ensure the area is gently sloping, free draining and that no preferential flow paths during rainfall events are created;  It is of particular importance that any steep slopes created are flattened out so that the area grades more gently with the surrounding topography;  Before topsoil is replaced, the soil must be ripped to a depth of 30 cm to reduce the oil density and to allow for the establishment of vegetation during revegetation;  An effective method is the use a chisel plough to mechanically rip both the topsoil and subsoil layers prior to revegetation;  A track hoe with a ripper tooth can be used at slopes greater than 3:1 to de-compact soil to the proper depth;  After soil has been ripped, replace topsoil evenly (200 mm). A suitable harrow should be used to create a fine tilth (<10 mm) for seedbed preparation;  In steep areas ensure that energy dissipation takes place to ensure that water leaving the site does so without reaching critical levels which would lead to erosion; and  Ensure that runoff does not lead to excessive sedimentation by Provide erosion control measures such as, sandbags, SoilSaver® and silt fences prior to commencement of revegetation (Table 11).

Table 11: Mechanisms for erosion and sedimentation control.

MECHANISMS FOR EROSION AND SEDIMENTATION CONTROL Rock mattresses Rock-filled mattresses can be used to line gullies and erosive areas. (Witheridge. 2017) (Figure A).

SoilSaver® - Soil retention blankets Soil retention blankets (SoilSaver®) are used to interact with young seedlings by providing a stable surface through which seedlings can take root and grow to provide a vegetative ground cover.

Soil retention blankets made from natural fibres such as jute, coir and hemp are in the form of a mesh that allows the seedlings to be planted through it.

They are biodegradable and their stabilising influence diminishes as the ability of the rooted vegetation to take over the protective role increases.

The biodegradable natural materials should only be used where slopes are stable in terms of mass stability and sufficiently shallow to ensure that Figure A: Example of rock mattress the re-establishing vegetation will be secure in the long term. (Solutions, 2019)

Where slopes are stable in terms of mass stability but too steep to guarantee the long-term security of soil and vegetation cover synthetic soil retention blankets can contribute to the longer term protection of the soil surface and vegetation layer. Soil retention blankets are three-dimensional random open-knit structures with a thickness of up to 20mm (Figure B).

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MECHANISMS FOR EROSION AND SEDIMENTATION CONTROL They are rolled out and pegged down onto the slope and then seeded and filled with topsoil, which is held in the mat. The mat remains under the vegetation providing continuing reinforcement in the root zone (Food and Agricultural Orgnaisation, 2001).

Figure B: Schematic drawing and photographic illustration of a soil retention blanket (Cirtex Civil, 2019).

Gabion Baskets Gabion baskets consist of wire mesh containers that are filled with locally available rocks. When stacked together, they can provide some stability to slopes (Figure C). Typical applications include the following:  Protection from falling rocks on steep slopes  Retaining walls to support terraces, and  Protection of fields, roads and infrastructure adjacent to flood- prone areas. Figure C: Example of gabions (Currie, 2018)

6.2.3.3 Task 3: Revegetation and Landscaping

Revegetation needs to commence as soon as possible after the soil was prepared to prevent AIS proliferation, erosion and sedimentation of the CVB wetland and HSS wetland. The guidelines for revegetation and landscaping of the focus areas (Section 6.2) are illustrated in Table 12.

Table 12: Revegetation and landscaping guidelines.

REVEGETATION AND LANDSCAPING GUIDELINES Responsible Persons Proponent Environmental Manager Contractor  Revegetation should ideally occur during spring and summer;  A Grassland Reclamation Mixture such as that from MayFord, an eco-matched veld seed mix can be used for revegetation purposes;  A qualified botanist or specialist supplier e.g. Sakata Seed Southern Africa’s Seeds (Pty) Ltd / MayFord2 should be consulted for the seeding and aftercare requirements;  Cordon off areas under rehabilitation as “no-go” areas to prevent access or disturbance of the revegetated areas and to allow regeneration of vegetation; and

2 MayFord Website: https://mayford.co.za/veld-grass/ Sekata Seed Southern Africa Contact details Tel: 011 548 2800 Email: [email protected]

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REVEGETATION AND LANDSCAPING GUIDELINES Responsible Persons Proponent Environmental Manager Contractor  Careful planning of all levels must take place to ensure the revegetated areas allow for a free draining landscape that allows water to drain towards the watercourses in a natural manner with specific mention of the following: - Ensure that runoff occurs in a natural diffuse manner with no unnatural concentration of flow; and - Ensure that no areas of unnatural ponding occur due to a lack of runoff potential.  The successful establishment of a vegetation cover will improve the wetland habitat, providing a preferred habitat with adequate vegetation density for the avifaunal SCC and amphibian species dispersal.

Procedure 4: Aftercare and monitoring

Prudent aftercare and monitoring of rehabilitated focus areas are of utmost importance, as this will ensure a continual flow of data, enabling all parties involved to accurately assess and manage the progress of the rehabilitation interventions and any arising issues. To ensure the accurate gathering of data, the following techniques and guidelines should be followed:  Site walk through surveys should be applied as the preferred method of monitoring (at specified frequencies) with specific focus on: o Erosion monitoring (for the duration of the raining season); o Sedimentation (for the duration of the raining season); o Alien and invasive vegetation proliferation (at the start and end of the growing season); o Spills events (regularly at the direction of the relevant engineer); o Failure and damage of infrastructure; o Surface water monitoring; and o Waste and litter problems.  Stability and appropriateness of stormwater controls;  All data gathered should be measurable (qualitative and quantitative);  Monitoring actions should be repeatable;  Data should be auditable; and  Reports should present and interpret the data obtained.

Table 13 illustrates data capturing for the monitoring plan.

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Table 13: Monitoring actions for the CVB wetland and HSS wetland.

Aspect Monitoring Location Frequency of sampling Frequency of Reporting Water quality CVB Wetland & HSS wetland Water must be tested monthly for the following Report must be compiled on a monthly basis for the monitoring Refer to figure 13 and 14. parameters for the duration of the construction phase: duration of the construction and rehabilitation phase Edge effect monitoring along the areas  pH; for all data collected. The report must include closest to the shaft must be undertaken.  Electrical Conductivity; mitigation and management actions that are  Turbidity and/or clarity; recommended and that are undertaken.  Total Dissolved Oxygen;  Temperature; and  Total dissolved solids. Wetland Vegetation CVB Wetland & HSS wetland Monitoring of wetland and terrestrial vegetation zones 1. A six monthly monitoring report to be compiled during rehabilitation and operation. during the rehabilitation phase and annually for at least 3 years post rehabilitation. The report should include as a minimum:

a. List of observed species within the wetland and terrestrial zones; b. Photos of species and densities throughout the construction and rehabilitation phases; c. Wetland PES; and d. Changes in wetland structure and extent. AIP control 1. Screening of the entire rehabilitation 1. Before the initial AIP clearing a baseline 1. Before and after AIP clearing report should be area(s); assessment should be undertaken to indicate compiled; 2. Logging locations of any newly coppiced densities and species; 2. Quarterly report during the first year post AIP species to be treated/removed. 2. After the initial AIP clearing densities should be clearing; and re-recorded, including all methods and 3. Annually during each growing season, for at least chemicals used; 3 years post rehabilitation – report should include 3. Quarterly assessment during the first year post information from before and after mobilisation of rehabilitation. Densities and locations of newly follow-up clearing teams. coppiced AIPs to be recorded; and 4. Annually during the growing season for the second and third year, post rehabilitation to ensure long-term maintenance measures are effective. Erosion 1. All rehabilitated areas; and 1. Weekly during rehabilitation activities; and Monthly monitoring report during the construction 2. All areas disturbed by construction and 2. After every major rainstorm and / flood for the and the rehabilitation phase. Bi-annually mining activities. first wet season post rehabilitation. monitoring undertaken during the operational phase.

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Aspect Monitoring Location Frequency of sampling Frequency of Reporting Revegetation 1. All rehabilitated areas; and 1. Monthly for 6 months after re-instatement of 1. Monthly for 6 months after the re-instatement; and 2. All areas disturbed by construction and vegetation; and 2. Annually during each growing season, for at least mining activities. 2. Annually during the growing season for at least 3 years post rehabilitation. three (3) years post rehabilitation to ensure plant survival and to ensure that no AIPs are outcompeting indigenous species. Infrastructure 1. All infrastructure associated with the Immediately after construction and then subsequent Annual Reporting for the life of the mine. integrity: Windmill and Witpoortjie Vent Shaft: seasonal inspections, specifically after flood events This will focus on the 2. The detailed design phase of the project for the life of the project to detect failure thereof and presence of the will provide specific details of the to take proactive management measures to remove, following forms of interventions (construction notes and replace or repair the structures. structural vulnerability actual dimensions) that will be required for associated with the monitoring. An inventory of the issues to be rehabilitated monitored will be compiled by the engineer landscape: upon completion of the detailed designs 1. Sign off to confirm if and these must be incorporated in the interventions are monitoring programme of the rehabilitation constructed according project. to specifications. 2. Post rehabilitation, the following inspection and reporting will be required: a. Shaft complex rehabilitation; b. Bank collapse; c. Scouring/erosion upstream and downstream d. Side cutting structures; e. Exposed soils, and f. Premature decay of the structural material.

*Note: This monitoring plan must be implemented by a competent person and submit the findings to the responsible authority for evaluation

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Figure 13: Digital satellite image depicting monitoring point 1 in relation to the HSS wetland and the Windmill Vent Shaft.

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Figure 14: Digital satellite image depicting monitoring point 2 in relation to the CVB wetland and the Windmill Vent Shaft.

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7. CONCLUSION

SAS was appointed to compile a WRMP for the proposed East Rand Proprietary Mines (ERPM) Expansion Area 2 mine, Gauteng Province.

This WRMP was compiled to provide mitigation measures to manage and rehabilitate potential impacts that could affect the HSS wetland and the CVB wetland during the expansion mining activities.

This WRMP advocates the use of several environmental management tools and mitigatory measures appropriate to the rehabilitation of disturbed areas associated with the study area and should be implemented by the proponent, appropriate, throughout the life of the project, including the aftercare and maintenance phase. This WRMP must be updated every second year to include relevant mitigation measures for any additional impacts or infrastructure changes that may occur post compilation of this report.

With the implementation of the developed WRMP the potential impacts on the CVB wetland and HSS wetland associated with the development of the Witpoortjie Vent Shaft and Windmill Vent Shaft can be managed by rehabilitating the disturbed areas resulting in a significantly reduced risk and impact to the watercourses of the region.

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8. REFERENCES

Bantilan-Smith, M., Bruland, G., MacKenzie, R., Henry, A., and C. Ryder. 2009. A Comparison of the Vegetation and Soils of Natural, Restored, and Created Coastal Lowland Wetlands in Hawaii Wetlands, 29 (3): 1023-1035. DOI: 10.1672/08-127.1

Cirtex Civil. 2019. Biocoir-Coconut Matting. Available at: https://cirtexcivil.co.nz.

Currie, A. 2018, January. Gabions coexist with the landscape. IMESA, January, pp. 22.

Food and Agricultural Organisation of the United States. 2001. Small dams and weirs in earth and gabion materials. Report AGL/MISC/32/2001 prepared by Land and Water Development Division, Rome, Italy.

GISD. 2011. Global Invasive Species database online data sheet. Arundo donax. www.issg.org/database. Accessed July 2019.

National Environmental Management Act (NEMA) 107 of 1998.

National Environmental Management: Biodiversity Act (Act 10 of 2004) and the associated Alien and Invasive Species Regulations (GN R598 of 2014).

National Water Act (Act No 38 of 1998).

Scientific Aquatic Services. 2019. Freshwater Ecological Assessment as Part of the Environmental Authorisation and Water Use Licence Application Process for the proposed EPRM Expansion Area 2 Mine, Brakpan South, Gauteng Province. Prepared for Prime Resources Environmental Consultants, June 2019. Specialist report, unpublished.

Solutions. 2019. Erosion Control. Available at: http://soilutions.net/.

Witheridge. 2017. Erosion & Sediment Control Field Guide for Pipeline Projects – Part 1. Catchments and Creeks Pty Ltd., Brisbane, Queensland.

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ANNEXURE A – RECEIVING ENVIRONMENT BACKGROUND

The table A1 provides background information on the freshwater ecological aspects pertaining to the ERPM Expansion Area 2 mine.

Table A1: Background information on the freshwater ecological aspects pertaining to the ERPM Expansion 2 mine.  The study area falls within quaternary catchment C22C;  The study area falls within the Vaal Management Area (WMA);  The sub-Water Management Area (sub-WMA) is the Downstream Vaal Dam subWMA;  The study area falls within the Highveld Ecoregion;  No National Freshwater Ecosystem Priority Area (NFEPA) rivers are located at the Windmill Vent or Witpoortjie Vent Shafts or associated 500m investigation areas. The Rietspruit River is located approximately 1.1 km east of the Windmill Vent Shaft;  According to the NFEPA database no wetlands are associated with the Windmill Vent Shaft; however, one (1) natural seep wetland and one (1) artificial seep wetland are indicated within 500 m of the Witpoortjie Vent Shaft. Both seep wetlands have been considered by the NFEPA database as heavily to critically modified;  The ERPM Expansion Area 2 mine falls within a sub quaternary catchment not currently considered important in terms of fish or freshwater conservation; and  According to the NFEPA database, both shafts fall within the critically endangered Mesic Highveld Grassland Group 2 wetland vegetation type. The north western portion of the Windmill Vent Shaft fall within the Dry Highveld Grassland Group 5, classified as least threatened.

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ANNEXURE B – LEGAL REQUIREMENTS

The table A1 below presents each legislative document and the aspects, which are pertinent to water resource management, including the rehabilitation of disturbed areas to a level that will promote improved water quality and aquatic ecology.

Table A1: Legislative Requirements pertinent to water resource management and rehabilitation. The National Environmental Management Act, 1998 (Act No. 107 of 1998) and the associated Regulations as amended in 2017, refer specifically to biodiversity management in the following Clause: (4)(a) Sustainable development requires the consideration of all relevant factors including, (i) that the disturbance of ecosystems and loss of biological diversity are avoided, or, where they cannot be altogether avoided, are minimised and remedied.

This Maintenance and Management Plan has been developed in fulfilment of the requirements as defined in the Environmental Impact Assessments EIA Regulations, 2014 (as amended) (No. R. 327) where a "maintenance management plan" is defined as a management plan maintenance purposes defined or adopted by the competent The National Environmental authority. The following EIA Regulation triggers the need for this MMP: Management Act, 1998 (Act No. 107 of 1998) Activity 19, Listing Notice 1: The infilling or depositing of any material of more than 10 cubic meters into, or the dredging, excavation, removal or moving of soil, sand, shell grit, pebbles or rock of more than 10 cubic metres from a watercourse; but excluding where such infilling, depositing, dredging, excavation, removal or moving- (a) will occur behind a development setback; (b) is for maintenance purposes undertaken in accordance with a maintenance management plan; (c) falls within the ambit of activity 21 in this Notice, in which case that activity applies; (N.B. Points (d) and (e) does not apply as these activities fall within the coastal zone). The objectives of this act are (within the framework of the National Environmental Management Act) to provide for:  the management and conservation of biological diversity within the Republic of South Africa and of the components of such diversity;  the use of indigenous biological resources in a sustainable manner;  the fair and equitable sharing among stakeholders of benefits arising from bio prospecting involving indigenous biological resources;  to give effect to ‘ratified international agreements’ relating to biodiversity which are binding to the Republic;  to provide for co-operative governance in biodiversity management and conservation; and  to provide for a South African National Biodiversity Institute to assist in The National Environmental achieving the objectives of this Act. Management: Biodiversity

Act, 2004 (Act No. 10 of 2004) This act alludes to the fact that management of biodiversity must take place to ensure that the biodiversity of surrounding areas is not negatively impacted upon, by any activity being undertaken, in order to ensure the fair and equitable sharing among stakeholders of benefits arising from indigenous biological resources. Furthermore, a person may not carry out a restricted activity involving either: a) a specimen of a listed threatened or protected species; b) specimen of an alien species; or c) a specimen of a listed invasive species without a permit.

Permits for the above may only be issued after an assessment of risks and potential impacts on biodiversity is carried out. Before issuing a permit, the issuing authority may in writing require the applicant to furnish it, at the applicant’s expense, with such

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independent risk assessment or expert evidence as the issuing authority may determine. The Minister may also prohibit the carrying out of any activity, which may negatively impact on the survival of a listed threatened or protected species or prohibit the carrying out of such activity without a permit. Provision is made for appeals against the decision to issue/refuse/cancel a permit or conditions thereof.

National Environmental Management: Biodiversity Act, 2004 (Act No. 10 of 2004) (NEMBA) (Alien and Invasive Species Regulations, 2014): NEMBA is administered by the Department of Environmental Affairs and aims to provide for the management and conservation of South Africa’s biodiversity within the framework of the NEMA. In terms of alien and invasive species. This act in terms of alien and invasive species aim to:  Prevent the unauthorized introduction and spread of alien and invasive species to ecosystems and habitats where they do not naturally occur,  Manage and control alien and invasive species, to prevent or minimize harm to the environment and biodiversity; and  Eradicate alien species and invasive species from ecosystems and habitats where they may harm such ecosystems or habitats.

Alien species are defined, in terms of the National Environmental Management: Biodiversity Act, 2004 (Act No. 10 of 2004) as: (a) a species that is not an indigenous species; or (b) an indigenous species translocated or intended to be translocated to a place outside its natural distribution range in nature, but not an indigenous species that has extended its natural distribution range by natural means of migration or dispersal without human intervention.

Categories according to NEMBA (Alien and Invasive Species Regulations, 2014):  Category 1a: Invasive species that require compulsory control.  Category 1b: Invasive species that require control by means of an invasive species management programme.  Category 2: Commercially used plants that may be grown in demarcated areas, provided that there is a permit and that steps are taken to prevent their spread.  Category 3: Ornamentally used plants that may no longer be planted.

See Annexure C for further details pertaining to Alien and Invasive Vegetation control.

Amendments to regulations under the Conservation of Agricultural Resources Act, 1983 (Act No. 43 of 1983) ensures that landowners are legally responsible for the control of The Conservation of invasive alien plants on their properties. The CARA legislation divides alien plants into Agricultural Resources Act, weeds and invader plants, with weeds regarded as alien plants with no known useful 1983 (Act No. 43 of 1983) economic purpose, while invader plants may serve useful purposes as ornamentals, as sources of timber and may provide many other benefits, despite their aggressive nature.

The purpose of the National Water Act, 1998 (Act 36 of 1998) (NWA) is to ensure that the nation’s water resources are protected, used, developed, conserved, managed and controlled.

The NWA, 1998 also provides for water use licenses which an operation will have to apply for, before commencing with any Section 21 water use activity. Various conditions The National Water Act, 1998 may be attached to these licenses and a breach thereof will result in criminal and civil (Act No. 36 of 1998) liability. The conditions attached to water use licenses will function alongside the additional protective measures, duty of care and statutory liability provisions provided by the NWA and other legislation to regulate a whole array of water issues. Accordingly, and in terms of the Guide to the National Water Act, “water use” refers to doing something that has an impact on the water resource, for example:  The amount of water in the resource;  The quality of water in the resource; and

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 The environment surrounding the resource.

Section 4 governs the entitlement to use water and states that water may only be used if it is a Schedule 1 use, a continuance of an existing lawful use (ELU), or authorised in terms of a general authorisation (GA) or license. A water use may therefore not be implemented unless it is properly authorised through one of these types of authorisations. The National Water Act, 1998 (Act No. 36 of 1998) recognises that the entire ecosystem and not just the water itself in any given water resource constitutes the resource and as such needs to be conserved. No activity may therefore take place within a watercourse unless it is authorised by the Department of Water and Sanitation (DWS). Any area within a wetland or riparian zone is therefore excluded from development unless authorisation is obtained from the DWS in terms of Section 21 (c) & (i). A watercourse is defined as: a) A river or spring; b) A natural channel in which water flows regularly or intermittently; c) A wetland, lake or dam into which, or from which water flows; and d) Any collection of water which the minister may, by notice in the Gazette, declare a watercourse. In accordance with Regulation GN509 of 2016, a regulated area of a watercourse for section 21c and 21i of the NWA, 1998 is defined as: a) The outer edge of the 1 in 100 year flood line and/or delineated riparian habitat, whichever is the greatest distance, measured from the middle of the watercourse of a river, spring, natural channel, lake or dam; b) In the absence of a determined 1 in 100 year flood line or riparian area the area within 100 m from the edge of a watercourse where the edge of the watercourse is the first identifiable annual bank fill flood bench; or c) A 500 m radius from the delineated boundary (extent) of any wetland or pan.

This notice replaces GN1199 and may be exercised as follows: i) Exercise the water use activities in terms of Section 21(c) and (i) of the Act as Government Notice 509 as set out in the table below, subject to the conditions of this authorisation; published in the Government ii) Use water in terms of section 21(c) or (i) of the Act if it has a low risk class as Gazette 40229 of 2016 as it determines through the Risk Matrix; relates to the National Water iii) Do maintenance with their existing lawful water use in terms of section 21(c) or Act, 1998 (Act No. 36 of 1998) (i) of the Act that has a LOW risk class as determined through the Risk Matrix; iv) Conduct river and storm water management activities as contained in a river management plan; v) Conduct rehabilitation of wetlands or rivers where such rehabilitation activities have a LOW risk class as determined through the Risk Matrix; and vi) Conduct emergency work arising from an emergency situation or incident associated with the persons’ existing lawful water use, provided that all work is executed and reported in the manner prescribed in the Emergency protocol.

A General Authorisation (GA) issued as per this notice will require the proponent to adhere with specific conditions, rehabilitation criteria and monitoring and reporting programme. Furthermore, the water user must ensure that there is a sufficient budget to complete, rehabilitate and maintain the water use as set out in this GA. The obtaining of a New Order Mining Right (NOMR) is governed by the MPRDA. The MPRDA requires the applicant to apply to the DMR for a NOMR which triggers a process of compliance with the various applicable sections of the MPRDA. The NOMR process requires environmental authorisation in terms of the MPRDA Regulations and Mineral and Petroleum specifically requires the preparation of a Scoping Report, an Environmental Impact Resources Development Act, Assessment (EIA) and Environmental Management Programme (EMP), and a Public 2002 (Act No. 28 of 2002) Participation Process (PPP). The primary environmental objective of the MPRDA is to (MPRDA) give effect to the ‘environmental right’10 contained in the South African Constitution. The MPRDA further requires the Minister to ensure the sustainable development of South Africa’s mineral resources, within the framework of national environmental policies, norms and standards, while promoting economic and social development.

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With regard to the environment, Section 37(1) of the MPRDA provides that the environmental management principles listed in Section 2 of the National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA) must guide the interpretation, administration and implementation of the environmental requirements of the MPRDA, and makes those principles applicable to all prospecting and mining operations.

Furthermore, Section 37(2) of the MPRDA states that “any prospecting or mining operation must be conducted in accordance with generally accepted principles of sustainable development by integrating social, economic and environmental factors into the planning and implementation of prospecting and mining projects in order to ensure that exploitation of mineral resources serves present and future generations”. These regulations, forming part of the National Water Act, were put in place in order to prevent the pollution of water resources and protect water resources in areas where mining activity is taking place from impacts generally associated with mining.

It is recommended that the project complies with Government Notice 704 as promulgated in Government Gazette 20119 of 1999 as it relates to the National Water Act, 1998 (Act No. 36 of 1998) which contains regulations on use of water for mining Government Notice 704 as and related activities aimed at the protection of water resources. GN 704 states that: promulgated in Government No person in control of a mine or activity may: Gazette 20119 of 1999 as it (a) locate or place any residue deposit, dam, reservoir, together with any relates to the National Water associated structure or any other facility within the 1:100 year floodline or within Act, 1998 (Act No. 36 of 1998) a horizontal distance of 100 metres (m) from any watercourse or estuary, borehole or well, excluding boreholes or wells drilled specifically to monitor the pollution of groundwater, or on waterlogged ground, or on ground likely to become waterlogged, undermined, unstable or cracked;

According to the above, the activity footprint must fall outside of the 1:100 year floodline of the drainage feature or 100m from the edge of the feature, whichever distance is the greatest, unless authorised by DWS.

APPENDIX 18 HYDROPEDOLOGICAL REPORT

HYDROPEDOLOGICAL ASSESSMENT AS PART OF THE WATER USE LICENSE APPLICATION PROCESS FOR THE PROPOSED ERPM EXPANSION AREA 2 MINE, BRAKPAN SOUTH, GAUTENG PROVINCE

Prepared for

Prime Resources Environmental Consultants

July 2019

Prepared by: Scientific Aquatic Services Report author: B. Mzila Report reviewer: S. van Staden (Pr.Sci.Nat) Report Reference: SAS 219105 Date: July 2019

Scientific Aquatic Services CC CC Reg No 2003/078943/23 Vat Reg. No. 4020235273 PO Box 751779 Gardenview 2047 Tel: 011 616 7893 Fax: 086 724 3132 E-mail: [email protected] SAS 219105 July 2019

DOCUMENT GUIDE

NEMA Regulations (2017) - Appendix 6 Relevant section in report (1) A specialist report prepared in terms of these Regulations must contain - (a) details of - (i) the specialist who prepared the report; and Appendix A (ii) the expertise of that specialist to compile a specialist report, including a curriculum vitae; Appendix A (b) a declaration that the specialist is independent in a form as may be specified by the Appendix A competent authority; (c) an indication of the scope of, and the purpose for which, the report was prepared; Section 1 (cA) an indication of the quality and age of base data used for the specialist report; Section 2 (cB) a description of existing impacts on site, cumulative impacts of the proposed Section 5 and 6 development and levels of acceptable change; (d) the duration, date and season of the site investigation and the relevance of the season Section 2 to the outcome of the assessment; (e) a description of the methodology adopted in preparing the report or carrying out the Section 2 specialised process inclusive of equipment and modelling used; (f) details of an assessment of the specific identified sensitivity of the site related to the Section 4 and 5 proposed activity or activities and its associated structures and infrastructure, inclusive of a site plan identifying alternative; (g) an identification of any areas to be avoided, including buffers; Section 5 (h) a map superimposing the activity, including the associated structures and infrastructure Section 5 on the environmental sensitivities of the site, including areas to be avoided, including buffers; (i) a description of any assumptions made and any uncertainties or gaps in knowledge; Section 1.3 (j) a description of the findings and potential implications of such findings on the impact of Section 5 and 6 the proposed activity, including identified alternatives, on the environment or activities; (k) any mitigation measures for inclusion in the EMPr; Section 6 (l) any conditions for inclusion in the environmental authorisation; Section 5, 6 and 7 (m) any monitoring requirements for inclusion in the EMPr or environmental authorisation; Section 6

(n) a reasoned opinion - (i) as to whether the proposed activity, activities or portions thereof should be authorised; Section 7 (iA) regarding the acceptability of the proposed activity or activities; and Section 6 and 7 (ii) if the opinion is that the proposed activity, activities or portions thereof should be Section 6 and 7 authorised, any avoidance, management and mitigation measures that should be included in the EMPr, and where applicable, the closure plan; (o) a description of any consultation process that was undertaken during the course of N/A preparing the specialist report (p) a summary and copies, if any, comments received during any consultation process and, N/A where applicable all responses thereto; and (q) any other information requested by the competent authority. No other information requested

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EXECUTIVE SUMMARY

Scientific Aquatic Services (SAS) was appointed by Prime Resources (Pty) Ltd to conduct a hydropedological assessment as part of the Water Use Licence Application process for the proposed East Rand Proprietary Mines (ERPM) Expansion Area 2 Mine, Gauteng Province. The project entails construction of access and vent shafts hereafter collectively referred to as the ‘ERPM expansion’, unless referring to each individual shaft area specifically.

ERPM intends to convert into a mining right and plans to consolidate the underground resources. In order to do so, this would require the development of the Windmill Shaft (a twin shaft including both access and vent shafts) and the Witpoortjie Vent Shaft (an existing ventilation shaft to be refurbished) to allow access to the underground operations.

According to the wetland assessment conducted by Scientific Aquatic Services (SAS, 2019), two watercourses were identified within the investigation areas: ➢ A Channelled Valley Bottom (CVB) wetland, was identified within the investigation area of the Witpoortjie Vent Shaft; and ➢ A Hillslope Seep (HSS) wetland within the investigation area of the Windmill Shaft.

According to SAS (2019), the wetlands have been impacted upon by extensive historical and current mining activities within the greater catchment. The CVB associated with Witpoortjie Vent Shaft has been impacted upon by the existence of impoundments as well as encroachment of mining activities to some degree which have altered the natural extent of the wetland and the hydrological regime in some parts of the wetland.

The HSS wetland has been impacted upon by informal farm roads which traverse the wetland and historical and current agricultural activities within the greater catchment. Table A summarises the findings of the wetland study. Table A: Summary of results of the characterisation of the identified watercourse within the ERPM Expansion. Watercourse PES Ecoservices EIS REC and RMO REC: D (Largely modified) CVB wetland D (Largely modified) Intermediate Moderate RMO: Maintain REC: C (Moderately modified) HSS wetland C (Moderately modified) Moderately low Low/marginal RMO: Maintain

Based on the findings of this study, the Witpoortjie Vent shaft area is dominated by soil types regarded as responsive shallow. As mentioned in Section 5.2.1, these soils are characterised by limited storage capacity which results in the generation of overland flow after rain events. These soils lead to a rapid runoff response time during intense rainfall events attributed to their shallow nature which inhibits infiltration. The contribution of these soils to wetland recharge is significant during a rainfall event and minimal during drier seasons.

The windmill shaft area is dominated by responsive shallow soils (which have been discussed above) as well as recharge soils which are characterised by absence of any morphological indication of saturation and are typically associated with deep freely drained soils. The dominant hydropedological pathway for these soils is vertical through and out the profile into the underlying bedrock, thus recharging groundwater.

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No impact is foreseen for the Hillslope seep located within the investigation area since the development is located outside of the catchment of this wetland, and the valley bottom wetlands will be negligibly impacted. From a hydropedological point of view, the impact significance of the proposed development is moderately low during construction and low during the operational phase. This is largely due to: ➢ The occurrence of soils which have a limited contribution to wetland recharge; ➢ The nature of the project as well as the limited extent of the footprint of the proposed development; and ➢ The catchment size of the associated wetland system in relation to the project footprint.

The hydropedological contribution of the wetland systems was calculated using simple hydrological principles in efforts to quantify the hydropedological percentage loss due to the proposed project both on a local and catchment scale. The results are presented below.

Table B: Calculated percentage loss of wetland recharge a catchment scale Catchment Scale Change in Class Attributable to hydropedological loss Wetland % Loss on a Wetland Hydropedological System catchment Impact Water Balance Consideration Change Category scale Category No hydropedological losses are foreseen for the wetlands associated with the All proposed development due to the 0.00 No Impact No change Wetlands occurrence of soil not regarded important for wetland recharge as far as subsurface processes are concerned

Overall, a change in the functionality (i.e. PES and EIS) of the wetlands is deemed unlikely Recommendations have been developed in the points below: ➢ Avoid wetlands and interflow soils (soil/bedrock) soils as far as practically possible; and ➢ All development footprint areas to remain as small as possible and disturbance of soil to be limited to what is absolutely essential.

The significance of the impact can be further reduced to very low significance, if the above mitigatory measures are implemented. This project is considered acceptable from a hydropedological point of view.

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TABLE OF CONTENTS

DOCUMENT GUIDE ...... ii EXECUTIVE SUMMARY ...... iii LIST OF FIGURES ...... vi LIST OF TABLES ...... vii GLOSSARY OF TERMS ...... viii ACRONYMS ...... ix 1 INTRODUCTION ...... 1

2 ASSESSMENT METHODOLOGY...... 6

3 HYDROPEDOLOGICAL BEHAVIOUR OF SOIL TYPES ...... 10

4 ECOLOGICAL SIGNIFICANCE ...... 12 5 RESULTS AND DISCUSSION ...... 15

5.2.1 Responsive (Shallow) Soils ...... 18 5.2.2 Recharge (Deep) Soils ...... 18 5.2.3 Interflow (Soil/Bedrock) soils ...... 19 5.2.4 Responsive (Saturated) Soils ...... 20

5.3.1 Buffer Determination Using Hydropedological Principles ...... 33 6 CONCLUSIONS AND RECOMMENDATIONS ...... 36 7 REFERENCES ...... 39 APPENDIX A: DETAILS, EXPERTISE AND CURRICULUM VITAE OF SPECIALISTS .... 40

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LIST OF FIGURES

Figure 1: Locality map depicting the proposed diversion drain within the ERPM Expansion and surrounding areas ...... 3 Figure 2: 1:50 000 topographic map depicting the proposed diversion drain within the ERPM Expansion and surrounding areas ...... 4 Figure 3: Soil texture classification chart (Food and Agriculture Organization (FAO), 1980...... 8 Figure 4: A diagram depicting soil wetness based on soil textural class ...... 8 Figure 5: A diagram depicting the percentage volume of water in the soil by soil texture .... 9 Figure 6: A typical conceptual presentation of hydrological flow paths on different hydropedological soil types- hillslope hydropedological behaviour...... 11 Figure 7: The delineated HSS wetland associated with the Windmill Shaft...... 13 Figure 8: The delineated CVB wetland associated with the Witporrtjie Vent Shaft...... 14 Figure 9: Map depicting spatial distribution of soils within the Vent Shaft Area ...... 16 Figure 10: Map depicting spatial distribution of soils within the Windmill Shaft Area ...... 17 Figure 11: A depiction of responsive shallow soils ...... 18 Figure 12: View of the identified Hutton soil form with deep, free draining characteristics ... 19 Figure 13: A depiction of an interflow soil in the soil/bedrock interface ...... 19 Figure 14: A depiction of responsive (saturated) soils associated with the valley bottom wetlands within the ERPM Expansion ...... 20 Figure 15: Map depicting hydrological soil types and delineated watercourses associated with the Witportjie Vent Shaft Area ...... 22 Figure 16: Map depicting hydrological soil types and delineated watercourses associated with the Windmill Shaft Area ...... 23 Figure 17: Map depicting verified hydropedological flow paths associated with the Vent Shaft Area ...... 24 Figure 18: Map depicting verified hydropedological flow paths associated with the Windmill Shaft Area ...... 25 Figure 19: Depiction of the landscape setting associated with the proposed Witportjie vent shaft ...... 26 Figure 20: Depiction of the landscape setting associated with the proposed windmill shaft showing shallow responsive and recharge soils...... 27 Figure 21: Depiction of the location of the conceptual cross section associated with vent shaft area ...... 29 Figure 22: Depiction of the location of the conceptual cross sections ...... 30 Figure 23: Conceptual hydrological flow paths for Vent shaft cross section predevelopment ...... 31 Figure 24: Conceptual hydrological flow paths Vent shaft cross section post development ...... 31 Figure 25: Conceptual hydrological flow paths for Windmill shaft cross section predevelopment ...... 32 Figure 26: Conceptual hydrological flow paths for Windmill shaft cross section post development ...... 32 Figure 27: Applicable scientific buffer associated with the Vent Shaft Area ...... 35

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LIST OF TABLES

Table 1: Average permeability for different soil textures in cm/hour Food and Agriculture Organization (FAO), 1980...... 6 Table 2: Soil permeability classes for agriculture and conservation (Food and Agriculture Organization (FAO), 1980...... 7 Table 3 : DWS range of hydraulic conductivities in different soil types (DWS Groundwater Dictionary, 2011) ...... 7 Table 4: Hydrological soil types of the studied hillslopes (Le Roux, et al., 2015)...... 11 Table 5: Summary of results of the characterisation of the identified watercourse within the ERPM Expansion...... 12 Table 6: Hydrological grouping of soils occurring within the ERPM Expansion according to Van Toll and Le Roux (2016)...... 20 Table 7: List of soil forms within the ERPM Expansion and their contribution to wetland recharge...... 21 Table 8: Impact categories for describing the impact significance of the proposed mining activities on the wetlands and associated hydropedological drivers ...... 33 Table 9: Calculated percentage loss of wetland recharge on both local and catchment scale ...... 33

vii SAS 219105 July 2019

GLOSSARY OF TERMS

Alluvial soil: A deposit of sand, mud, etc. formed by flowing water, or the sedimentary matter deposited thus within recent times, especially in the valleys of large rivers. Aquifer An aquifer is an underground layer of water-bearing permeable rock, rock fractures or unconsolidated materials e.g. gravel, sand, or silt, that contains and transmits groundwater Base flow: Long-term flow in a river that continues after storm flow has passed. Catena A sequence of soils of similar age, derived from similar parent material, and occurring under similar macroclimatic condition, but having different characteristics due to variation in relief and drainage. Catchment: The area where water is collected by the natural landscape, where all rain and run-off water ultimately flows into a river, wetland, lake, and ocean or contributes to the groundwater system. Chroma: The relative purity of the spectral colour which decreases with increasing greyness. Evapotranspiration The process by which water is transferred from the land to the atmosphere by evaporation from the soil and other surfaces and by transpiration from plants Fluvial: Resulting from water movement. Gleying: A soil process resulting from prolonged soil saturation which is manifested by the presence of neutral grey, bluish or greenish colours in the soil matrix. Groundwater: Subsurface water in the saturated zone below the water table. Hydromorphic soil: A soil that in its undrained condition is saturated or flooded long enough to develop anaerobic conditions favouring the growth and regeneration of hydrophytic vegetation (vegetation adapted to living in anaerobic soils). Hydro period Duration of saturation or inundation of a wetland system. Hydrology: The study of the occurrence, distribution and movement of water over, on and under the land surface. Hydromorphy: A process of gleying and mottling resulting from the intermittent or permanent presence of excess water in the soil profile. Intermittent flow: Flows only for short periods. Mottles: Soils with variegated colour patterns are described as being mottled, with the “background colour” referred to as the matrix and the spots or blotches of colour referred to as mottles. Pedology The branch of soil science that treats soils as natural phenomena, including their morphological, physical, chemical, mineralogical and biological properties, their genesis, their classification and their geographical distribution. Perched water The upper limit of a zone of saturation that is perched on an unsaturated zone by table: an impermeable layer, hence separating it from the main body of groundwater Runoff Surface runoff is defined as the water that finds its way into a surface stream channel without infiltration into the soil and may include overland flow, interflow and base flow. Swelling clay: Clay minerals such as the smectites that exhibit interlayer swelling when wetted, or clayey soils which, on account of the presence of swelling clay minerals, swell when wetted and shrink with cracking when dried. Vadose zone The unsaturated zone between the ground surface and the water table (groundwater level) within a soil profile Watercourse: In terms of the definition contained within the National Water Act, a watercourse means: • A river or spring; • A natural channel which water flows regularly or intermittently; • A wetland, dam or lake into which, or from which, water flows; and • Any collection of water which the Minister may, by notice in the Gazette, declare to be a watercourse; • and a reference to a watercourse includes, where relevant, its bed and banks

viii SAS 219105 July 2019

ACRONYMS

°C Degrees Celsius. DWA Department of Water Affairs DWAF Department of Water Affairs and Forestry DWS Department of Water and Sanitation EAP Environmental Assessment Practitioner EIA Environmental Impact Assessment ET Evapotranspiration FAO Food and Agriculture Organization GIS Geographic Information System GPS Global Positioning System HGM Hydrogeomorphic m Meter MAP Mean Annual Precipitation MPRDA Minerals and Petroleum Resources Development Act, Act 28 of 2002 NEMA National Environmental Management Act NWA National Water Act PSD Particle Size Distribution SACNASP South African Council for Natural Scientific Professions SAS Scientific Aquatic Services subWMA Sub-Water Management Area WMA Water Management Areas WULA Water Use Licence Application

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1 INTRODUCTION

The ERPM expansion is situated within the suburb of Brakpan, with the Windmill Shaft situated approximately 1.5km south of the M43 motorway and the Witpoortjie Vent Shaft situated approximately 1.1km east of the R23 (Heidelberg Road). The Witpoortjie Vent Shaft is located approximately 6.3km east of the Windmill Shaft (Figure 1 and 2).

Project Description

The proposed activities will likely entail excavation and construction activities, which may remove hydropedologically important soils and intercept the subsurface flows in the vadose zone feeding the wetlands as well as affect vadose zone recharge mechanisms. Thus, it was deemed necessary to investigate the recharge mechanism of the wetland systems within and in close proximity to the ERPM Expansion to ensure that development planning takes cognisance of the hydropedologically important areas and hence enable informed decision making and construction design and sustainable development.

A hydropedological survey and sampling activities were conducted in May 2019 to assess the hydropedological characteristics of the landscape and associated soils within the ERPM Expansion. A soil sampling exercise was undertaken at selected representative points, considering the various soil types, in order to deduce the wetland recharge mechanisms and

1 SAS 219105 July 2019

identify the anticipated hydropedological impacts of the proposed development on the wetland resources that will be affected by the proposed activity.

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Figure 1: Locality map depicting the proposed diversion drain within the ERPM Expansion and surrounding areas

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Figure 2: 1:50 000 topographic map depicting the proposed diversion drain within the ERPM Expansion and surrounding areas

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Objectives

The purpose of this assessment is to investigate the hydropedological properties of the soils in the vicinity of the wetland system within the ERPM Expansion, in order to infer the potential recharge mechanisms and destination of the transferred water present in the surrounding soils that may be affected during the life of the proposed development. It was also an objective to assess the impact of the proposed development activity on the wetland systems in terms of the hydropedological drivers. Recommendations on mitigation were then considered and presented.

Assumptions and Limitations

Hydropedological science and research is rapidly evolving and there are currently no standard methods to assess and/or model the recharge capacity of soils, as a result, the findings of this assessment are therefore a mix of qualitative and quantitative results and based on the specialist’s training, opinion and experience with the hydrological properties of the identified soil types.

Sampling by definition means that not all areas are assessed, and therefore some aspects of soil and hydropedological characteristics may have been overlooked in this assessment. However, it is the opinion of the professional study team that this assessment was carried out with sufficient sampling and in sufficient detail to enable the proponent, the Environmental Assessment Practitioner (EAP) and the regulating authorities to make an informed decision regarding the proposed activity.

A hydropedological classification of soils outside of the ERPM Expansion were also verified in order to understand the hillslope processes. Hydropedological soil types outside of the ERPM Expansion were however not mapped as part of this study, however, were considered in development the conceptual model of the hydropedological flow paths of the landscape.

The effects climate change dynamics were not considered as part this assessment; however, it is acknowledged that this might exacerbate the anticipated reduction in water inputs and the resultant hydrological function of the remaining wetlands beyond the extent of the proposed development.

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2 ASSESSMENT METHODOLOGY

A field assessment was undertaken in May 2019 to investigate the hydropedological properties of the soils in the vicinity of the investigated wetlands, to infer the recharge potential of the surrounding soils as best possible, based on their intrinsic pedological characteristics. Subsurface soil observations were made by means of a standard hand auger and investigation methods. Field assessment data included description of physical soil properties including the following parameters, in order to characterise the various recharge mechanisms of the investigated wetlands: ➢ Diagnostic soil horizon sequence; and ➢ Landscape position in relation to the investigated wetlands (recorded on GPS); ➢ Depth to saturation (water table), if encountered;

Field assessment data was subsequently used to carry out the following assessments and investigation: ➢ Verify the spatial extent of the identified soil forms using a GIS software programme; ➢ Identify the potential impacts of the proposed development on the unsaturated flow processes, and implications to the functionality of the wetland systems; ➢ Compile a brief report on the conceptual hydropedological regime of the assessed wetlands based on the soil types within the ERPM Expansion under current conditions; and ➢ Recommend suitable mitigation and management measures to alleviate the identified impacts on the wetland hydropedological conditions.

Table 1: Average permeability for different soil textures in cm/hour Food and Agriculture Organization (FAO), 1980. Soil Texture Permeability (cm/hour) Sand 5 Sandy loam 2.5 Loam 1.3 Clay loam 0.8 Silty clay 0.25 Clay 0.05

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Table 2: Soil permeability classes for agriculture and conservation (Food and Agriculture Organization (FAO), 1980. Permeability rates* Soil permeability classes cm/hour cm/day Very slow Less than 0.13 Less than 3 Slow 0.13 - 0.3 3 - 12 Moderately slow 0.5 - 2.0 12 - 48 Moderate 2.0 - 6.3 48 - 151 Moderately rapid 6.3 - 12.7 151 - 305 Rapid 12.7 - 25 305 - 600 Very rapid > 25 > 600 *Saturated samples under a constant water head of 1.27 cm Table 3 : DWS range of hydraulic conductivities in different soil types (DWS Groundwater Dictionary, 2011)

Soil Type Saturated Hydraulic Conductivity, Ks (cm/s) Gravel 3x10-2 – 3 Coarse Sand 9x10-5 – 6x10-1 Medium Sand 9x10-5 – 5x10-2 Fine Sand 2x10-5 – 2x10-2 Loamy Sand 4.1x10-3 Sandy Loam 1.2x10-3 Loam 2.9x10-4 Silt, Loess 1x10-7 – 2x10-3 Silt Loam 1.2x10-4 Till 1x10-10 – 2x10-4 Clay 1x10-9 – 4.7x10-7 Sandy Clay Loam 3.6x10-4 Silty Clay Loam 1.9x10-5 Clay Loam 7.2x10-5 Sandy Clay 3.3x10-5 Silty Clay 5.6x10-6 Unweathered marine clay 8x10-11 – 2x10-7

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Figure 3: Soil texture classification chart (Food and Agriculture Organization (FAO), 1980.

Figure 4: A diagram depicting soil wetness based on soil textural class

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Figure 5: A diagram depicting the percentage volume of water in the soil by soil texture

Wetland Impact Calculation Approach

To accurately calculate the percentage loss for each wetland system associated with the MRA, simple hydrological principles were applied. This approach considered various parameters such as:

➢ Rainfall; ➢ Hydropedological soil types ➢ Catchment area for each wetland system; ➢ Mean Annual Runoff; ➢ Runoff coefficients (Mahmoud and Alazba, 2015) (Refer to Appendix B); • Slope percentage; • Soil texture; • Land use;

For each wetland system, a catchment area was delineated. In catchments which extended upgradient beyond the area where hydropedological data was gathered, the inflow into the study areas was calculated using standard hydrological calculations of annual discharge. This value was used, where applicable, as an initial or catchment input volume to which the site specific hydropedological recharge values as well as other hydrological inputs were added. The contribution of the vadose zone or hydropedological input, taking into account its contribution to interflow, overland flow, expressed in percentage as well as estimated volumes of hydropedological recharge loss.

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3 HYDROPEDOLOGICAL BEHAVIOUR OF SOIL TYPES

Hydropedological behaviour of different soils can vary significantly, depending on the soil drainage patterns. The discussion below is largely based on the concept presented in Figure 4 and Table 4 below.

Responsive shallow soils ‘respond’ quickly to rain events and typically generate overland flow. These soils can be shallow and overlie relatively impermeable bedrock, with limited storage capacity which is quickly exceeded following a rain event.

High chroma soils (i.e. red and yellow brown) are typically well drained, well aerated, deep, and vertical flow is the dominant hydrological pathway. These soils are referred to as recharge soils, as they are likely to recharge groundwater, or lower lying positions in the regolith, via the bedrock due to the dominance of vertical flow.

Lighter coloured soils or leached soils are usually associated with lateral movement of water which leaches soil minerals from the soil through the process of eluviation. Lateral flow occurs due to differences in the hydraulic conductivity of soil horizons or due to the presence of an impermeable subsurface layer. These soils are termed interflow soils. Lateral flow occurs at the A/B horizon interface and/or bedrock interfaces due to the reduced permeability, which therefore prevents vertical movement.

Grey colours in soils are mainly caused by prolonged saturation (hydroperiod), attributed to poor soil drainage due to high clay content or some other impediment. These soils drive freshwater resources on a more localised scale and the recharge path is generally completed over shorter periods (days to months depending on the transmissivity of the soils). Surface runoff occurs rapidly and leads to recharge of soils on a localised level after rainfall events. Figure 6 presents a conceptual diagram of the recharge mechanism of different soil types within the landscape and their influence on freshwater resources.

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Figure 6: A typical conceptual presentation of hydrological flow paths on different hydropedological soil types- hillslope hydropedological behaviour.

Hydrological Soil Types

The table below presents descriptions of the hydropedological soil types and how they contribute to wetland recharge.

Table 4: Hydrological soil types of the studied hillslopes (Le Roux, et al., 2015). Hydrological Description Symbol Soil Types Soils without any morphological indication of saturation. Vertical flow through and out the profile into the underlying bedrock is the dominant flow direction. These Recharge soils can either be shallow on fractured rock with limited contribution to evapotranspiration or deep, freely drained soils with significant contribution to ground water regime. Duplex soils where the textural discontinuity facilitates accumulation of water in the topsoil. Duration of drainable water depends on the rate of Interflow (A/B) evapotranspiration, position in the hillslope (lateral addition/release) and slope (discharge in a predominantly lateral direction). Soils overlying relatively impermeable bedrock. Hydromorphic properties signify Interflow temporal build-up of water on the soil/bedrock interface and slow discharge in a (Soil/Bedrock) predominantly lateral direction. Responsive Shallow soils overlying relatively impermeable bedrock. Limited storage capacity (Shallow) results in the generation of overland flow after rain events. Soils with morphological evidence of long periods of saturation. These soils are Responsive close to saturation during rainy seasons and promote the generation of overland (Saturated) flow due to saturation excess.

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The flow paths from the crest of a slope to the valley bottom is assessed and classified. According to Le Roux, et al. (2015), the classification largely takes into account the flow drivers during a peak rainfall event and the associated flow paths of water through the soil. The hillslope classes are:

➢ Class 1 – Interflow (Soil/Bedrock Interface); ➢ Class 2 – Shallow responsive; ➢ Class 3 – Recharge to groundwater (Not connected); ➢ Class 4 – Recharge to wetland; ➢ Class 5 – Recharge to midslope; and ➢ Class 6 – Quick interflow.

4 ECOLOGICAL SIGNIFICANCE

Table 5: Summary of results of the characterisation of the identified watercourse within the ERPM Expansion. Watercourse PES Ecoservices EIS REC and RMO REC: D (Largely modified) CVB wetland D (Largely modified) Intermediate Moderate RMO: Maintain REC: C (Moderately HSS wetland C (Moderately modified) Moderately low Low/marginal modified) RMO: Maintain

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Figure 7: The delineated HSS wetland associated with the Windmill Shaft.

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Figure 8: The delineated CVB wetland associated with the Witporrtjie Vent Shaft.

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5 RESULTS AND DISCUSSION

Morphological and Hydraulic Properties of Wetland and Hydropedologically Important Soils Associated with the ERPM Expansion:

The catena of the wetland systems wetlands resembled a Lithic and Plinthic topo sequence. Lithic soils of Mispah and Glenrosa are characterised by an Orthic A horizon which grades directly into hard rock or lithocutanic material.

Plinthic soils within the ERPM Expansion can be classified as hard plinthic soil types, where the Orthic A horizon grades directly into a plinthic horizon e.g. Dresden (Dr). Hard plinthic soils can also be moderately deep where the Orthic A horizon grades into a red or yellow brown apedal horizon e.g. Glencoe (Gc).

The presence of a G horizon on Katspruit (Ka) soils indicates greater predispensation to wetness, and these soils are typically saturated with water, at least seasonally. These soils are largely associated with valley bottom wetlands. Figure 9 and 10 depict the locality of the soil within the ERPM Expansion as well as the delineated wetland features.

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Figure 9: Map depicting spatial distribution of soils within the Vent Shaft Area

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Figure 10: Map depicting spatial distribution of soils within the Windmill Shaft Area

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Recharge of the Wetlands

The four primary wetland recharge mechanisms include precipitation (rainfall), surface flow (runoff), subsurface flow (interflow) through the vadose zone of the surrounding soils, and groundwater discharge. Identified soils with the ERPM Expansion have been grouped into hydropedological soil types and are discussed below in order to understand their contribution to wetland recharge.

5.2.1 Responsive (Shallow) Soils

These soils are shallow, loamy sand of poor structure overlying relatively impermeable dark rock horizon. Limited storage capacity results in the generation of overland flow after rain events. These soils lead to a rapid runoff response time during intense rainfall events attributed to their shallow nature which inhibits infiltration. The slope position of the soils is typically the crest and scarp. It must be noted that these are not wetland soils, however they are important for recharge of wetlands during rainfall events by means of overland flow. Thus, only support wetlands during rainy seasons and particularly directly after rainfall events.

Less than 30 cm

Figure 11: A depiction of responsive shallow soils

5.2.2 Recharge (Deep) Soils

Recharge soils are characterised by absence of any morphological indication of saturation and are typically associated with deep freely drained soils. The dominant hydropedological pathway for these soils is vertical through and out the profile into the underlying bedrock. These soils are termed recharge soils, as they are likely to recharge groundwater, or lower lying positions in the regolith via bedrock. Figure 12 depicts Hutton (Hu) soil form, a typical recharge soil identified within the ERPM Expansion.

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Figure 12: View of the identified Hutton soil form with deep, free draining characteristics

5.2.3 Interflow (Soil/Bedrock) soils

These soils are characterised by hydromorphic properties particularly mottling (red, yellow, and grey colors) which signify temporal build of water on the soil/bedrock interface and slow discharge in a predominantly lateral direction. The horizons are indicative that the underlying bedrock is slowly permeable and periodic saturation in the rainy season is likely, which may lead to lateral flow at the soil bedrock interface. The drainage may be restricted by an impermeable rock layer (Le Roux, et al., 2015).

Figure 13: A depiction of an interflow soil in the soil/bedrock interface

The contribution of overland flow and precipitation (rainfall) is considered significant during rainy seasons. Table 5 present the hydrological grouping of soils associated with the ERPM Expansion according to Van Toll and Le Roux (2016). The conceptual wetland recharge based on the water flow paths through the soil medium are presented in Figure 15.

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5.2.4 Responsive (Saturated) Soils

Responsive soils include clayey Katspruit (Ka)) soil form which depict prominent signs of prolonged wetness (Gleying) occurring within the permanent zone of the valley bottom wetlands (refer to Table 4) the morphological characteristics of the soils signify long periods of saturation (Le Roux, et. al., 2015) and are essentially water receptors from the surrounding catchment, since they largely occur in the lowest points in the landscape setting. The high clay content of these soils prolongs the inundation (hydroperiod) of the wetlands by reducing the rate of lateral seepage while vertical movement of water in the soils does not occur. The locality of these soils is depicted in Figure 14.

Figure 14: A depiction of responsive (saturated) soils associated with the valley bottom wetlands within the ERPM Expansion

Table 6 presents the grouping of the hydropedological soil types, whilst Table 7 presents their diagnostics characteristics. Figure 15 and 16 depicts the locality of the identified hydropedological soil types within the ERPM Expansion.

Table 6: Hydrological grouping of soils occurring within the ERPM Expansion according to Van Toll and Le Roux (2016). Recharge Responsive Responsive Interflow (Deep) (Shallow) (Saturated) (Soil/Bedrock) Hutton Mispah Katspruit Glencoe Glenrosa Dresden

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Table 7: List of soil forms within the ERPM Expansion and their contribution to wetland recharge.

Recharge Diagnostic Soil Forms Description Mechanism Horizons Relatively deep, loamy sand of poor structural stability, overlying red/light brown, and unspecified material. Recharge - A: Orthic Vertical flow is dominant. These soils are referred to as (Vertical Hutton - B1: Red Apedal B recharge soils, as they are likely to recharge flow) groundwater, or lower lying positions in the regolith, via the bedrock. The horizons are indicative that the underlying bedrock is - A: Orthic Interflow slowly permeable and periodic saturation in the rainy - B1: Yellow Brown (Soil/Bedro Glencoe (Gc) season is likely, which may lead to lateral flow at the soil Apedal ck) bedrock interface. The drainage may be restricted by a - Hard Plinthic shallow impermeable rock layer.

- A: Orthic The combination of relatively impermeable bedrock and Dresden (Dr) - Hard Plinthic shallow soil depth implies that these Responsive soils have a low storage capacity. They will saturate (shallow) Mispah - A: Orthic quickly following a rain event and (Ms)/Glenros - Hard contribute mostly to overland flow. a (Gn) Rock/Lithocutanic Very poor recharge potential due to severe internal drainage constraints. These soils are saturated with water for most of the year such that poor drainage Responsive Katspruit - A: Orthic conditions have induced the development of the gleyed (Saturated) (Ka) - G: Gleyed (G) horizon. The G-horizon is relatively impermeable, which impedes water movement (percolation) into the groundwater thereby retaining water in the wetlands.

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Figure 15: Map depicting hydrological soil types and delineated watercourses associated with the Witportjie Vent Shaft Area

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Figure 16: Map depicting hydrological soil types and delineated watercourses associated with the Windmill Shaft Area

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Figure 17: Map depicting verified hydropedological flow paths associated with the Vent Shaft Area

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Figure 18: Map depicting verified hydropedological flow paths associated with the Windmill Shaft Area

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Hydro-pedological Implications

Vent Shaft Area

Based on the findings of this study, the Vent shaft area is dominated by soil types regarded as responsive shallow. As mentioned in Section 5.2.1, these soils are characterised by limited storage capacity which results in the generation of overland flow after rain events. These soils lead to a rapid runoff response time during intense rainfall events attributed to their shallow nature which inhibits infiltration. The contribution of these soils to wetland recharge is significant during a rainfall event and minimal during drier seasons.

Figure 19: Depiction of the landscape setting associated with the proposed Witportjie vent shaft

The severity of impact of the proposed development on the associated wetlands is relatively low from a hydropedology point of view due to: ➢ The dominance of responsive shallow soil which are significant during rainy seasons as they contribute to overland flow; ➢ The nature of the project as well as the limited extent of the footprint of the proposed development; and ➢ The hydrological catchment size of the associated wetland system.

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It is the specialist’s opinion that the impact significance will range between moderately low and low if the responsive saturated (wetlands) are avoided at the vent shaft complex.

Windmill Shaft Area

Figure 20: Depiction of the landscape setting associated with the proposed windmill shaft showing shallow responsive and recharge soils.

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significance of the proposed development is moderately low during construction and low during the operational phase. This is largely due to:

➢ The occurrence of soils which have a limited contribution to wetland recharge; ➢ The nature of the project as well as the limited extent of the footprint of the proposed development; and ➢ The catchment size of the associated wetland system in relation to the project footprint.

Overall, a change in the functionality (i.e. PES and EIS) of the wetlands is deemed unlikely. Cross sections were developed to depict the hydropedological soil types and how the proposed development may affect the hillslope processes. Figure 21 and 22 depicts the location of the cross sections developed in the vicinity of each shaft complex, and Figure 23 to 26 below present a cross sections depicting the hillslope processes associated with the wetlands associated with the ERPM Expansion.

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Cross Section

Figure 21: Depiction of the location of the conceptual cross section associated with vent shaft area

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Cross Section

Figure 22: Depiction of the location of the conceptual cross sections

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Figure 23: Conceptual hydrological flow paths for Vent shaft cross section predevelopment

Figure 24: Conceptual hydrological flow paths Vent shaft cross section post development

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Figure 25: Conceptual hydrological flow paths for Windmill shaft cross section predevelopment

Figure 26: Conceptual hydrological flow paths for Windmill shaft cross section post development

Table 8 presents impact categories for describing the impact significance of the proposed mining activities on the wetlands and associated hydropedological drivers. Table 9 presents the calculated percentage loss of wetland recharge on both local and catchment scale.

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Table 8: Impact categories for describing the impact significance of the proposed mining activities on the wetlands and associated hydropedological drivers Severity SSI Change Class Description Reduction No Impact 0 – 2.5 % No change Hydropedological process are predicted to be unmodified and the functionality of the wetland will remain unchanged Low 2.5 – 5 % No Significant change Small effect on the hydropedological process are predicted, however the functionality of the wetland remains unchanged and no change in resource class is expected. Low to 5 – 10 % Limited change with a change A slight change in hydropedological processes is Moderate in PES category possible predicted and a small change in the in the wetland may have taken place but is change to the PES, EIS or wetland functionality and ecoservice provision is limited with no more than one PES class predicted. Moderate 10 – 15 % Significant change with a A moderate change in the hydropedological processes is change in PES Category predicted to occur, the change in PES may exceed one definite and possibly a change category but no change in EIS takes place. No loss of of more than one category important ecoservices is predicted to occur High 15 – 22.5 % Very significant change with a Modifications have reached a very significant level and change in PES of more than the hydropedological processes are predicted to be two categories largely modified with a large change in the PES, EIS of the wetland feature as well as a significant loss in ecoservice provision. Very High 22.5 -60% Serious to Critical change with Modifications have reached a serious level and the a change in PES of more than hydropedological processes have been seriously modified three categories or a with an almost complete loss of wetland integrity, permanent complete loss of functionality and service provision. wetland resource

Table 9: Calculated percentage loss of wetland recharge on both local and catchment scale Catchment Scale Change in Class Attributable to hydropedological loss Wetland % Loss on a Wetland Hydropedological System catchment Impact Water Balance Consideration Change Category scale Category No hydropedological losses are foreseen for the wetlands associated with the All proposed development due to the 0.00 No Impact No change Wetlands occurrence of soil not regarded important for wetland recharge as far as subsurface processes are concerned

5.3.1 Buffer Determination Using Hydropedological Principles

A scientifically derived buffer was developed to ensure that appropriate consideration of the hydropedological drivers in the ERPM Expansion is given in support of the principles of Integrated Environmental Management (IEM) and sustainable development. Refer to Figure 27. The buffer was developed in such a way that interflow soils (immediately adjacent to wetland and outside of the vent shaft area) are protected so that no significant change in the PES of wetlands occurs although limited impact would still occur if this buffer was to be adhered to and that residual impacts on the wetland will be limited from a hydropedological perspective.

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The buffer was only deemed necessary for the Witportjie vent shaft area due to its close proximity to the wetland while no buffer is relevant at the windmill shaft complex as the site is far from any wetlands.

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Figure 27: Applicable scientific buffer associated with the Vent Shaft Area

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6 CONCLUSIONS AND RECOMMENDATIONS

Table A: Summary of results of the characterisation of the identified watercourse within the ERPM Expansion. Watercourse PES Ecoservices EIS REC and RMO REC: D (Largely modified) CVB wetland D (Largely modified) Intermediate Moderate RMO: Maintain REC: C (Moderately modified) HSS wetland C (Moderately modified) Moderately low Low/marginal RMO: Maintain

Based on the findings of this study, the Witpoortjie Vent shaft area is dominated by soil types regarded as responsive shallow. As mentioned in Section 5.2.1, these soils are characterised

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by limited storage capacity which results in the generation of overland flow after rain events. These soils lead to a rapid runoff response time during intense rainfall events attributed to their shallow nature which inhibits infiltration. The contribution of these soils to wetland recharge is significant during a rainfall event and minimal during drier seasons.

Overall, a change in the functionality (i.e. PES and EIS) of the wetlands is deemed unlikely Recommendations have been developed in the points below:

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➢ Avoid wetlands and interflow soils (soil/bedrock) soils as far as practically possible; and ➢ All development footprint areas to remain as small as possible and disturbance of soil to be limited to what is absolutely essential.

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7 REFERENCES

Department of Environmental Affairs, Department of Mineral Resources, Chamber of Mines, South African Mining and Biodiversity Forum, and South African National Biodiversity Institute (DEA, DMR, CoM, SAMBF, SANBI) 2013. Mining and Biodiversity Guideline: Mainstreaming biodiversity into the mining sector. Pretoria, 100 pages. Online available: http://bgis.sanbi.org/Mining/project.asp Department of Water Affairs and Forestry, 2005. A practical field procedure for identification and delineation of wetland and riparian areas. DWAF, Pretoria. Department of Water and Sanitation, 2011. The Ground Water Dictionary: Second Edition, [Accessed: September 2018]. Food and Agriculture Organization (FAO), 1980. Drainage design factors. FAO Irrigation and Drainage Paper No. 38. Rome. GCS Water and Environmental Consultants. 2016. Dorstfontein East Environmental Impact Assessment - Hydrogeological Investigation. Final Draft Version – 1. Kotze, D.C, Marneweck, G.C., Batchelor, A.L., Lindley, D. and Collins, N. 2004. Wetland Assess: A rapid assessment procedure for describing wetland benefits. Mondi Wetland Project. Unpublished report. Le Roux, P. A., Hensley, M., Lorentz, S. A., van Tol, J. J., van Zijl, G. M., Kuenene, B. T., Jacobs, C. C. (2015). HOSASH: (Hydrology of South African Soils and Hillslopes. Water Research Commission. Soil Classification Working Group, 1991. Soil classification. A taxonomic system for South Africa. Mem. agric. nat. Resource. S. Afr. No. 15. Dept. Agric. Dev., Pretoria.

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APPENDIX A: DETAILS, EXPERTISE AND CURRICULUM VITAE OF SPECIALISTS

1. (a) (i) Details of the specialist who prepared the report Stephen van Staden MSc (Environmental Management) (University of Johannesburg) Braveman Mzila BSc (Hons) Hydrology University of KwaZulu-Natal 1. (a). (ii) The expertise of that specialist to compile a specialist report including a curriculum vitae Company of Specialist: Scientific Aquatic Services Name / Contact person: Stephen van Staden Postal address: 29 Arterial Road West, Oriel, Bedfordview Postal code: 2007 Cell: 083 415 2356 Telephone: 011 616 7893 Fax: 011 615 6240/ 086 724 3132 E-mail: [email protected] MSc (Environmental Management) (University of Johannesburg) BSc (Hons) Zoology (Aquatic Ecology) (University of Johannesburg) Qualifications BSc (Zoology, Geography and Environmental Management) (University of Johannesburg) Registered Professional Scientist at South African Council for Natural Scientific Professions (SACNASP) Registration / Associations Accredited River Health practitioner by the South African River Health Program (RHP) Member of the South African Soil Surveyors Association (SASSO) Member of the Gauteng Wetland Forum

1. (b) a declaration that the specialist is independent in a form as may be specified by the competent authority I, Stephen van Staden, declare that - • I act as the independent specialist in this application; • I will perform the work relating to the application in an objective manner, even if this results in views and findings that are not favourable to the applicant; • I declare that there are no circumstances that may compromise my objectivity in performing such work; • I have expertise in conducting the specialist report relevant to this application, including knowledge of the relevant legislation and any guidelines that have relevance to the proposed activity; • I will comply with the applicable legislation; • I have not, and will not engage in, conflicting interests in the undertaking of the activity; • I undertake to disclose to the applicant and the competent authority all material information in my possession that reasonably has or may have the potential of influencing - any decision to be taken with respect to the application by the competent authority; and - the objectivity of any report, plan or document to be prepared by myself for submission to the competent authority; • All the particulars furnished by me in this form are true and correct

------Signature of the Specialist

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SCIENTIFIC AQUATIC SERVICES (SAS) – SPECIALIST CONSULTANT INFORMATION CURRICULUM VITAE OF STEPHEN VAN STADEN

PERSONAL DETAILS

MEMBERSHIP IN PROFESSIONAL SOCIETIES

Registered Professional Scientist at South African Council for Natural Scientific Professions (SACNASP); Accredited River Health practitioner by the South African River Health Program (RHP); Member of the South African Soil Surveyors Association (SASSO); Member of the Gauteng Wetland Forum; Member of International Association of Impact Assessors (IAIA) South Africa; Member of the Land Rehabilitation Society of South Africa (LaRSSA)

COUNTRIES OF WORK EXPERIENCE

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PROJECT EXPERIENCE (Over 2500 projects executed with varying degrees of involvement) 1. M 1 Mining: Coal, Chrome, PGM’s, Mineral Sands, Gold, Phosphate, river sand, clay, fluorspar 2 Linear developments 3 Energy Transmission, telecommunication, pipelines, roads 4 Minerals beneficiation 5 Renewable energy (wind and solar) 6 Commercial development 7 Residential development 8 Agriculture 9 Industrial/chemical

REFERENCES

➢ Terry Calmeyer (Former Chairperson of IAIA SA) Director: ILISO Consulting Environmental Management (Pty) Ltd Tel: +27 (0) 11 465 2163 Email: [email protected]

➢ Alex Pheiffer African Environmental Management Operations Manager SLR Consulting Tel: +27 11 467 0945 Email: [email protected]

➢ Marietjie Eksteen Managing Director: Jacana Environmental Tel: 015 291 4015

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SCIENTIFIC AQUATIC SERVICES (SAS) – SPECIALIST CONSULTANT INFORMATION

CURRICULUM VITAE OF BRAVEMAN MZILA

PERSONAL DETAILS Position in Company Wetland Ecologist and Soil Scientist Date of Birth 03 January 1991 Nationality South African Languages IsiZulu, English Joined SAS 2017

EDUCATION Qualifications BSc (Hons) Environmental Hydrology (University of KwaZulu-Natal) 2013 BSc Hydrology and Soil Science (University of KwaZulu-Natal)) 2012 COUNTRIES OF WORK EXPERIENCE South Africa – Gauteng, KwaZulu-Natal, Eastern Cape SELECTED PROJECT EXAMPLES Freshwater Ecological Assessments • Freshwater ecological assessment as part of the water use authorisation relating to stormwater damage of a tributary of the Sandspruit, Norwood, Gauteng province. • Wetland verification as part of the environmental assessment and authorization process for the proposed development in Crowthorne extension 67, Gauteng province. • Freshwater assessment as part of the section 24g rectification process for unauthorised construction related activities that took place on erf 411, Ruimsig extension 9, Gauteng province • Baseline aquatic and freshwater assessment as part of the environmental assessment and authorisation process for the N11 Ring Road, Mokopane, Limpopo Province • Wetland Resource Scoping Assessment as Part of The Environmental Assessment and Authorisation Process for The Kitwe TSF Reclamation Project, Kitwe, Zambia • Wetland delineation as part of the environmental assessment and authorization process for the proposed development in Boden Road, Benoni, Ekurhuleni Metropolitan Municipality, Gauteng Province. Soil, Land Use and Land Capability Assessments • Soil, Land Use and Land Capability Assessment as part of the environmental assessment and authorisation process for the proposed Witfontein Railway Siding Project Near Bethal, Mpumalanga Province • Soil, Land Use and Land Capability Assessment as part of the environmental assessment and authorisation process for the proposed Hueningkranz Mine, Postmasburg, Northern Cape Province Hydropedological Wetland Impact Assessments • Hydropedological Assessment as Part of The Environmental Assessment and Authorisation Process for the proposed Vandyksdrift Central Dewatering Project • Hydropedological Assessment for the Proposed Evander Gold Elikhulu Tailings Storage Facility (TSF) Expansion, Mpumalanga Province • Hydropedological Assessment as part of the environmental assessment and authorisation process for the proposed Palmietkuilen Mine, Springs, Gauteng Province • Hydropedological Assessment as part of the environmental assessment and authorisation process for the proposed Uitkomst Colliery Mine expansion, Newcastle, KwaZulu-Natal Province Soil Rehabilitation Assessments • Soil rehabilitation plan, a water resource assessment and develop a management plan in support of the water use licence for the Driefontein operations, Carletonville, Gauteng

APPENDIX 19 TRAFFIC REPORT Merchelle’s Collective (Pty) Ltd Reg. No. 2016/481395/07

PO Box 4695 Halfway House 1685, South Africa Building 1, Maxwell Office Park, Magwa Crescent West c/o Allandale Road & Maxwell Drive, Waterfall City, Midrand T : 011 207 2066 F : 086 674 6121 E : [email protected]

ERPM EXTENSION AREA 2 MINE, BRAKPAN SOUTH TRAFFIC BASELINE STUDY AND IMPACT ASSESSMENT – DRAFT REPORT

Document Prepared For:

Prime Resources The Workshop 70-7th Avenue

Parktown North Johannesburg 2193

Contact: Stephan Geyer

T: +27 11 447 4888 W: www.reources.co.za

3-07-2019 GP053

Directors: W. Küsel | L.L. Pike (CEO) | R.A. Rajasakran

3-07-2019 i GP053

DOCUMENT CONTROL SHEET

Project Title: ERPM Brakpan South TIA Project No: GP053 Document Ref. No: GP053 ERPM Brakpan South TIA Report

DOCUMENT APPROVAL

ACTION DESIGNATION NAME DATE SIGNATURE

Traffic Engineer, Rochelle Prepared Merchelle’s Collective Rajasakran 18 July 2019 (Pty Ltd Pr Eng

Reviewed

Approved

RECORD OF REVISIONS

DATE REVISION AUTHOR COMMENTS

Rochelle Rajasakran 3-07-2019 01 Issued to Prime Resources for comment. Pr Eng

Rochelle Rajasakran Comments from Prime Resources received Pr Eng on 08-07-2019. 18-07-2019 02 Comments addressed and report re- submitted on 18-07-2019.

3-07-2019 i GP053

TABLE OF CONTENTS SECTION PAGE 1 INTRODUCTION ...... 1 1.1 BACKGROUND ...... 1

1.2 WARRANTS AND EXTENT OF STUDY ...... 2 2 METHODOLOGY ...... 4 3 EXISTING CONDITIONS ...... 5 3.1 STUDY AREA...... 5

3.2 DATA COLLECTION ...... 6

3.3 EXISTING ROAD NETWORK ...... 6 3.3.1 Connecting Roads ...... 6 3.3.2 Intersections ...... 8

3.4 EXISTING TRAFFIC VOLUMES ...... 11

3.5 CAPACITY EVALUATION ...... 12 3.5.1 Discussion of Base Year Results ...... 12

3.6 RECOMMENDED UPGRADES...... 14 4 FUTURE ROAD NETWORK PLANNING ...... 15 5 TRAFFIC IMPACT ASSESSMENT ...... 17 5.1 TRANSPORTATION OF RAW MATERIALS FROM SITE ...... 17

5.2 SITE ACCESS ...... 17

5.3 CONSTRUCTION PHASE TRAFFIC...... 17 5.3.1 Trip generation and distribution ...... 17

5.4 OPERATIONAL PHASE TRAFFIC ...... 20 5.4.1 Trip generation and distribution ...... 20 5.4.2 Capacity Evaluation ...... 23

5.5 DECOMMISSIONING PHASE TRAFFIC ...... 24 6 ROAD NETWORK UPGRADES REQUIRED ...... 25 7 ASSESSMENT OF IMPACTS ...... 27 7.1 IMPACT RATING ...... 27

7.2 POTENTIAL TRANSPORT IMPACTS ...... 27 7.2.1 Road and intersection capacity and vehicle emissions due to additional traffic loading ...... 27 7.2.2 Pavement and impact of concrete truck loading ...... 28 7.2.3 Dust Generation ...... 28 7.2.4 Noise pollution ...... 28 7.2.5 Impact of haulage vehicles on the road network ...... 28

7.3 IMPACT ASSESSMENT ...... 28 8 CONCLUSIONS AND RECOMMENDATIONS ...... 30

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TABLE OF FIGURES

FIGURE 1-1 LOCALITY MAP SHOWING ERPM EXTENSION AREA 2 SHAFT LOCATIONS AND BRAKPAN SOUTH - WIDER STUDY AREA ...... 1

FIGURE 3-1 DEVELOPMENT SITE AND EXTENT OF STUDY AREA ...... 5

FIGURE 3-2 BARRY MARAIS RD. (AT CAMORA ST./ROAD A I/S) – PAVEMENT IN FAIR CONDITION ...... 6

FIGURE 3-3 DOG-LEG BEND AND OVERHEAD PIPE AT KOOT ST. JUST BEFORE THE EXISTING WITPOORTJE VENT SHAFT ...... 7

FIGURE 3-4 NEW ASPHALT LAYER ON THE R23 ...... 7

FIGURE 3-5 NEW ASPHALT LAYER ON THE R550, JUST AFTER THE DIANA RD. I/S ...... 8

FIGURE 3-6 AWSC INTERSECTION – R550 AND R23 ...... 9

FIGURE 3-7 R550 AND ROAD A INTERSECTION (ALTERNATIVE ACCESS TO WINDMILL SHAFT FROM THE SOUTH) ... 9

FIGURE 3-8 BARRY MARAIS RD. AND ROAD A INTERSECTION – MINIBUS-TAXIS HOLDING DURING THE OFF-PEAK HOUR ...... 10

FIGURE 3-9 BARRY MARAIS RD. AND R21 RONDEBULT RD. SIGNALISED INTERSECTION AND STAGGERED SOUTHERN LEG OF THE JUNCTION ...... 10

FIGURE 3-10 BASE YEAR 2019 AM PEAK HOUR TRAFFIC VOLUMES (06:15 – 07:15) ...... 11

FIGURE 3-11 BASE YEAR 2019 PM PEAK HOUR TRAFFIC VOLUMES (16:15 – 17:15) ...... 11

FIGURE 3-12 QUEUE BUILD-UP ON BARRY MARAIS RD./CAMORA ST. AT 5:05 PM (GOOGLE TRAFFIC) ...... 13

FIGURE 3-13 LOS MOVEMENT SUMMARY FOR BARRY MARAIS RD./CAMORA ST.-ROAD A I/S BASE YEAR 2019, AM AND PM PEAK HOURS ...... 13

FIGURE 3-14 LOS MOVEMENT SUMMARY FOR THE IMPROVED (SIGNALISED) BARRY MARAIS RD. & CAMORA ST./ROAD A I/S ...... 14

FIGURE 4-1 FUTURE K-ROUTE PLANNING AROUND THE DEVELOPMENT SITE ...... 15

FIGURE 4-2 REPOSITIONED WINDMILL SHAFT AND PROPOSED NEW ACCESS ONCE K165.06 IS CONSTRUCTED 16

FIGURE 5-1 EXISTING PIPELINES, ADJACENT ROAD A, FOR THE TRANSPORTATION OF ORE ...... 17

FIGURE 5-2 TRIP GENERATION AND DISTRIBUTION FOR THE AM PEAK HOUR – CONSTRUCTION PHASE ...... 19

FIGURE 5-3 TRIP GENERATION AND DISTRIBUTION FOR THE PM PEAK HOUR – CONSTRUCTION PHASE ...... 19

FIGURE 5-4 MAIN DIRECTION OF TRAVEL FOR PRIVATE VEHICLES ...... 22

FIGURE 5-5 AM PEAK HOUR TRIP GENERATION AND DISTRIBUTION – OPERATIONAL PHASE ...... 23

FIGURE 5-6 PM PEAK HOUR TRIP GENERATION AND DISTRIBUTION – OPERATIONAL PHASE ...... 23

FIGURE 6-1 BARRY MARAIS RD. & CAMORA ST./ROAD A - EXISTING AND PROPOSED LAYOUT ...... 25

FIGURE 6-2 BARRY MARAIS RD. & R21 RONDEBULT RD. - EXISTING AND PROPOSED LAYOUT ...... 26

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LIST OF TABLES

TABLE 3-1BASE YEAR 2019 EXISTING CAPACITY ANALYSIS ...... 12

TABLE 3-2 BASE YEAR 2019 RECOMMENDED UPGRADES TO BARRY MARAIS RD. & CAMORA ST./ROAD A ...... 14

TABLE 5-1 TRIP GENERATION – CONSTRUCTION PHASE ...... 18

TABLE 5-2 CAPACITY RESULTS FOR CONSTRUCTION RELATED TRAFFIC – BARRY MARAIS RD.&CAMORA ST./ROAD A ...... 20

TABLE 5-3 TOTAL STAFF COMPLEMENT DURING THE OPERATIONAL STAGE ...... 20

TABLE 5-4 TOTAL PEAK HOUR TRIPS DURING THE OPERATIONAL PHASE ...... 21

TABLE 5-5 AVERAGE GDP GROWTH ...... 24

TABLE 5-6 RESULTS FOR SITE 3 AND 4, OPENING YEAR 2028 ...... 24

TABLE 7-1 SCALE USED TO DETERMINE OVERALL RANKING OF ENVIRONMENTAL IMPACT ...... 27

TABLE 7-2 IMPACT ASSESSMENT: CONSTRUCTION AND OPERATION PHASE ...... 29

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1 INTRODUCTION

Prime Resources Environmental Consultants were appointed for the Environmental Impact Assessment (EIA) of the Proposed ERPM Extension Area 2 Mine in Brakpan South. The mine is situated within a greenfields site, where underground ore mining will be conducted. The new Windmill Shaft will be constructed and the existing Witpoortje Vent Shaft will be re-commissioned into use. Merchelle’s Collective (Pty) Ltd was appointed by Prime Resources to conduct a Traffic Baseline Study and Impact Assessment for the site.

A locality map is provided in Figure 1-1 below.

BOKSBURG GERMISTON

BRAKPAN

SPRINGS Wider Study Area

BRAKPAN WITPOORTJIE SHAFT

WINDMILL SHAFT

THOKOZA

KATLEHONG

TSAKANE VOSLOORUS

DUDUZA

NIGEL

Figure 1-1 Locality map showing ERPM Extension Area 2 Shaft Locations and Brakpan South - Wider Study Area

1.1 Background The background to the development of the site was provided by Prime Resources as follows:

ERPM Extension Area 1 (Pty) Ltd (“ERPM Ext 1”) is a subsidiary of ERPM (Pty) Ltd (“ERPM”). ERPM Ext 1 holds a prospecting right (GP243PR) which it intends to convert into a Mining Right (submitted with reference number: GP 30/5/1/2/2 10078 MR). Since submission of the EA application, ERPM’s contiguous mining rights - GP151MR and GP150MR – have been sold to ERPM Ext 1.

GP243PR is located to the south and adjacent to GP150MR, approximately 11 km South-East of Boksburg Town and 7 km East of Vosloorus. Affected farm portions include portions of Witpoortje 117 IR, Withok 131 IR, Rooikraal 156 IR and Glen Roy 132 IR.

ERPM Ext 1 plans to consolidate the underground resources of GP243PR (referred to as ERPM Extension Area 2 or ERPM Ext 2), with those of GP150MR and GP151MR, the combined underground resources within these three areas justifies the large capital commitment to develop a long term, large-scale mining operation. The Far East Vertical (FEV) shaft and FEV vent shaft on GP151MR will be refurbished and used to access underground workings of GP151MR and GP150MR. An additional twin shaft (includes both access and vent shaft), termed Windmill Shaft, is proposed to be constructed on Portion 5 of the Farm

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Witpoortje 117 IR to allow access to the underground operations of the Ext 2 area and will include the development of the associated head gear. Ore that is mined below ground will be crushed and mixed with groundwater to form a slurry and will be brought to surface via a hydraulic hoist system and transported via existing pipelines to either the Knights Plant (via the Knight Plant Pipeline) to the north-west of the surface development area or the Ergo Plant (via the Ergo Plant Pipeline) to the north-east of the surface development area. An existing vent shaft on Portion 19 of the Farm Witpoortje 117 IR (Witpoortje Vent Shaft) will also be re-opened and re-equipped for use.

Surface infrastructure associated with the development of Windmill Shaft is to be developed within the proposed surface development area of approximately 20 Ha and for the Witpoortje Vent Shaft within the proposed surface development area of approximately 7 Ha.

The Traffic Impact Assessment Report is a specialist assessment that is input to the Environmental Impact Assessment (EIA) of the development. This report investigates the impact of the development-related traffic on existing traffic conditions on the immediate road network surrounding the development site. The report also evaluates the need for any new road upgrades that are required to alleviate potential impacts in terms of roadway capacity, road safety and road conditions.

1.2 Warrants and Extent of Study In order to identify the level of investigation for the TIA, the following guidelines taken from the Manual for Traffic Impact Studies of the Department of Transport were followed:

 Threshold Value (in terms of trips generated) for Traffic Impact Studies: For this development the operational trips generated will be greater than 50 trips generated in the Peak Hour, therefore a Traffic Impact Study is warranted. The TIA is also required to quantify other negative impacts that the development may have within the transport environment for input to the EIA process.

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 Extent of Analysis: For this Traffic Impact Study, the operations of five critical intersections have been evaluated. This represents a study area which extends approximately 9km to the south and 2.7km to the west of the site.  Assessment Years: The base year for analysis was taken as year 2019. The construction period was taken as 2019-2020 and the opening year of the facility was taken as year 2028.

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2 METHODOLOGY

The TIA is conducted in accordance with the Manual for Traffic Impact Studies of the Department of Transport and with reference to the COTO TIA Guidelines. In addition to this, the methodology makes provision for the assessment of impacts against the criteria that apply to environmental assessments, as provided by Prime Resources.

The quantification of impacts is calculated for each phase of the operation i.e. Construction, Operation, Decommissioning and Rehabilitation (Post-closure).

The methodology for the Traffic Impact Assessment includes the following tasks:

 Conduct a site visit to assess the road network around the study area, including the accesses onto the external road network and key intersections on the national/public road network that could be impacted.

 Confirm the transportation methods of the raw materials to/off site.

 Undertake traffic count surveys in the area and conduct a Base Year capacity assessment of the road network.

 Compile a list of technical information to be obtained from the engineering team, for the construction, operations and decommissioning phases of the mine:

 Details of the traffic/truck volumes expected to operate to/from the mine.  Origin / Destination of the traffic/truck volumes.  Sources of raw material (if any) that will be transported to site  Location of and delivery methods of the final products.  Details of staff movements and transport.  Details regarding abnormally dimensioned machine components required during the construction and operation of the plant (if any).

 Assign the above development related trips to the road network for the Construction Phase and thereafter Opening Year of the mine. Conduct capacity analysis of critical intersections.

 Determine environmental impacts of the development-related traffic, safety hazards and other issues identified from the site visit.

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3 EXISTING CONDITIONS

3.1 Study Area The proposed ERPM Ext 2 underground mine area extends from Barry Marais Rd. eastwards across Heidelberg Rd. and towards the Tsakane informal settlement area. Hard infrastructure that will be constructed comprises the Windmill Shaft, providing access to the mine area and located to the western limits of the project site, just off Barry Marais Rd. The Witpoortje Shaft is an existing vent shaft that will be re-opened to serve the Ext 2 mine area. The vent shaft is located just after the dog leg bend on Koot St., whereafter the road becomes Denne Rd.

The presence of several tailings dams on/or adjacent to the site indicates the high level of both historic and current mining activity in the area. It is anticipated that mine tailings from the proposed ERPM 2 mine will be deposited onto the existing ERGO Tailings Storage Facility (TSF), just south of the project area.

The development site and study area to be considered for the traffic evaluation is illustrated in Figure 3-1

below. N

WITPOORTJE VENT SHAFT 3

4 5 WINDMILL SHAFT

ERGO TSF

Legend 2 1 12-Hour Traffic Count Sites 1

Estimated ERPM Ext 2 MRA

Figure 3-1 Development site and extent of study area

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3.2 Data Collection Traffic surveys were undertaken at five intersections (one of which is a staggered junction), as shown in Figure 3-1 above and described below. A brief description of the relevance of the intersection to the study area is also provided below:

1. R23 Heidelberg Rd and R550 (Springs Road) I/S – critical junction connecting the site to potential labour source in Tsakane.

2. R550 (Springs Road) and unnamed farm access road (Road A) – alternative access to Windmill Shaft from the south.

3. Barry Marais Rd. and Road A/Camora St. – main access to Windmill Shaft.

4. Barry Marais Rd. and R21 Rondebult Rd. - critical junction connecting the site to potential labour source in Vosloorus and access from the north.

5. Road B – Staggered leg of the above junction, providing access from Villa Liza.

The surveys were conducted on a typical weekday, namely Wednesday 15th May 2019, covering a 12-hour period from 06:00 to 18:00. The surveys consisted of classified, turning movement volume counts. The vehicles were classified as light, minibus-taxi, bus and heavy vehicles per direction in 15-minute intervals.

A brief description of each of the intersections is provided below:

3.3 Existing Road Network The site is well-located in terms of road infrastructure, being located adjacent to some of the major mobility north-south and east-west roads in the area. The road network connecting the site to the surrounding towns and suburbs is described below.

3.3.1 Connecting Roads

3.3.1.1 Barry Marais Rd.

Barry Marais Rd. is a Class 2 major arterial. The road connects to the N3 in the south, thereafter becoming Bierman Rd. Bierman Rd. runs in a westward direction providing direct access into Vosloorus and Thokoza. The road connects to the N12 to the north, via Atlas Rd. Interchange. The northern link provides access to the CBD’s of Boksburg and Benoni. The pavement appears to be in fair condition with no major cracking or potholes observed. There are no sidewalks, however streetlights are present. The topography is fairly level, implying no vertical crests and good sight distance. The main access to Windmill Shaft will be off Barry Marais Rd.

Figure 3-2 Barry Marais Rd. (at Camora St./Road A I/S) – Pavement in fair condition

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3.3.1.2 R23 Heidelberg Rd.

The R23 is a Class 2 major arterial that is an important mobility route for the region. The road connects to the N17 just north of the site, and to Heidelberg Town to the south. The road provides access to the Witpoortje Vent Shaft, which is located off the R23 Heidelberg Rd./Koot St. intersection (which becomes Denne Rd.)

The R23 pavement has recently been upgraded, with contractors currently working on services alongside the road.

Figure 3-3 Dog-leg bend and overhead pipe at Koot St. just before the existing Witpoortje Vent Shaft

Figure 3-4 New asphalt layer on the R23

3.3.1.3 R550 (Springs Rd.)

The R550 is a Class 3 minor arterial that provides east-west connectivity. The road connects to Duduza and Tsakane in the east and Vereeniging to the west. The proposed alternate southern access, Road A, to Windmill Shaft is off the R550 (see Intersection No. 2 in Section 3.3.2 below).

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The R550 is also being upgraded with sections of new asphalt to the south of the R550/Diana Rd. Intersection.

Figure 3-5 New asphalt layer on the R550, just after the Diana Rd. I/S

3.3.1.4 Road A – Access road to the Windmill Shaft

Road A is an informal gravel road. The road appears to be in poor condition and little utilised. Overland pipes that will be utilised in the proposed mining operations run along the LHS of the roadway. Road A is the main access road to the Windmill Shaft, which will be located on the RHS of the road. The access road will have to be upgraded to a stabilised gravel road, considering the large workforce (900 people) that will access the shaft during operations.

3.3.2 Intersections

3.3.2.1 Intersection 1: R23 Heidelberg Rd and R550 (Springs Road) I/S

This intersection is a four-legged, All Way Stop Controlled (AWSC) intersection. The R23 has a wide grassed median along this section. All approaches have exclusive right turn lanes and slip controlled left turn lanes. The intersection is surrounded by predominately agricultural holdings and is shown in Figure 3-6 below.

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Figure 3-6 AWSC Intersection – R550 and R23

3.3.2.2 Intersection 2: R550 and Road A

This intersection is a priority-controlled T-Junction. Road A is an informal, gravel road providing access to adjacent agricultural holdings, eventually connecting to Barry Maris Rd. to the north. This intersection forms the alternative, southern access to the Windmill Shaft.

Figure 3-7 R550 and Road A Intersection (alternative access to Windmill Shaft from the south)

3.3.2.3 Intersection 3: Barry Marais Rd. and Camora/Road A (Main access to Windmill Shaft)

This intersection is a four-legged Two-Way Stop Controlled (TWSC) junction. The northern leg (Camora St.) becomes a frontage road providing access into the Windmill Park informal residential area.

The southern leg is a gravel road providing access to agricultural holdings. An informal minibus-taxi rank operates from this leg of the junction, with vehicles holding here during the off-peak hours.

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Figure 3-8 Barry Marais Rd. and Road A Intersection – Minibus-taxis holding during the off-peak hour

3.3.2.4 Intersection 4 & 5: Barry Marais Rd. and R21 Rondebult Rd.

Intersection 4 is a signalised T-Junction with a steep gradient on the R21 approach. The intersection provides direct access to Barry Marais Rd. from towns such as Boksburg and Germiston to the north and Vosloorus, Katlehong and Thokoza to the south. The signal timings during the off-peak hour need to be revised. The green phase on the R21 leg is 60sec long, although there is minimal traffic here. This causes frustration to motorists on Barry Marais Rd. who then tend to skip the red signal.

The staggered southern leg of the junction (Intersection 5) provides access to Windmill Park. The junction has an exclusive right turn lane off Barry Marais Rd., improving safety conditions and preparing motorists for a right turn just before the signalised intersection.

Figure 3-9 Barry Marais Rd. and R21 Rondebult Rd. Signalised Intersection and staggered southern leg of the junction

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3.4 Existing Traffic Volumes The peak hour traffic count volumes are shown in Figure 3-10 and

Figure 3-11. The volumes are classified according to light vehicles and heavy vehicles, with buses included in the heavy vehicle volume.

Figure 3-10 Base Year 2019 AM Peak Hour Traffic Volumes (06:15 – 07:15)

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Figure 3-11 Base Year 2019 PM Peak Hour Traffic Volumes (16:15 – 17:15)

Barry Marais Rd. carries relatively low traffic volumes, given that most of the population in this region depends on public transport. During the morning peak hour, the main direction of flow is northwards towards work opportunities in the CBD’s of Boksburg and Benoni. The afternoon peak reflects commuter traffic returning to the residential areas of Vosloorus and Thokoza. The traffic volumes indicate a minimal percentage of heavy vehicles, being in the region of 2%. The latter indicates the low level of industrialisation and manufacturing land uses in the area.

3.5 Capacity Evaluation The five intersections discussed above, were analysed using a traffic analysis software tool called SIDRA (Signalised and unsignalised Intersection Design and Research Aid). The operating performance was evaluated under existing traffic conditions and lane configuration during the AM and PM peak hours. The AM Peak Hour was taken as 06:15-07:15 and the PM Peak Hour as 16:15-17:15.

The operational performance of each intersection was evaluated in terms of delay experienced on each approach as well as capacity of the junction to process the current traffic flows. The performance measurement is the Level of Service (LOS) defined by the Highway Capacity Manual in which letters A through F are used. LOS A depicts free flow conditions while LOS F denotes a breakdown in traffic flow, resulting in high delays to motorists. These definitions are based on Measures of Effectiveness (MoE) for the type of facility, which in this case is an intersection. Typical MoE’s include speed, travel-time, density and delay for the associated volume of vehicles that use the facility.

The COTO TIA Manual indicates that a LOS D is acceptable for urban roads.

The Volume Demand to Capacity Ratio (v/c) is a measure that compares roadway demand (vehicle volumes) with roadway supply (carrying capacity). For example, V/C 1.00 indicates that the roadway facility is operating at its capacity.

The results for the capacity assessment for the existing situation are shown in

Table 3-1.

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Table 3-1Base Year 2019 Existing Capacity Analysis

Control Peak South Approach East Approach North Approach West Approach Average Intersection LOS Int. No. Description Type Hour Delay LoS V/C Delay LoS V/C Delay LoS V/C Delay LoS V/C Delay LoS V/C R23 Heideberg Rd. & R550 1 AWSC AM 10.9 B 0.368 13.8 B 0.774 9.5 A 0.265 11.7 B 0.31 11.8 B 0.774 Springs Rd. AWSC PM 9.9 A 0.188 12.4 B 0.339 9 A 0.301 9.7 A 0.303 10 B 0.339 2 R550 Springs Rd. & Road A TWSC AM 0.1 A 0.216 10.5 B 0.008 0.1 A 0.164 0.2 A 0.216 TWSC PM 0.1 A 0.156 9.6 A 0.006 0.2 A 0.051 0.2 A 0.156 Barry Marais Rd. & 3 TWSC AM 95.2 F 0.971 8.1 A 0.233 129.9 F 0.972 2.5 A 0.677 11.1 B 0.972 Camora/Road A TWSC PM 22.2 C 0.036 0.4 A 0.418 138.7 F 1.227 1.8 A 0.22 22.5 C 1.227 Barry Marais Rd. & R21 4 Signal AM 38.7 D 0.977 15.6 B 0.758 60.6 E 1.001 40.1 D 1.01 Rondebult Rd. Signal PM 5.8 A 0.379 8.8 A 0.762 35.8 D 0.774 12 B 0.774 Barry Marais Rd. and Road B 5 (staggered southern leg of TWSC AM 289.8 F 1.036 0.1 A 0.454 3.1 A 1.036 above junction) TWSC PM 0.1 A 0.398 85.4 F 0.205 0.1 A 0.579 0.5 A 0.579 3.5.1 Discussion of Base Year Results

The intersections were found to operate as follows:

1) The R23 Heidelberg Rd. & R550 Springs Rd. four-way stop controlled intersection, has a generous geometric design with left turn slip lanes and exclusive right turn lanes on all four approaches. The I/S thus operates well within capacity during both the AM and PM peak hours. From a safety perspective, it is a quite a large intersection, with two major provincial routes intersecting, to be operating under four-way stop control conditions. 2) The R550 & Road A I/S operates satisfactorily during both AM and PM Peak hours, given the relatively low volumes that make use of Road A (>5 veh. during both peak hours). 3) Barry Marais Rd. and Camora St./Road A operates satisfactorily from an overall intersection capacity perspective. However Road A and Camora St. operate at LOS F due to the relative difficulty in obtaining a gap in the high traffic flow on Barry Marais Rd. Road A operates as an informal taxi rank and Camora St. processes a significant traffic flow from Windmill Park (239 vehicles turn right in the PM Peak hour, with the majority being light vehicles and not minibus taxis). The low LOS experienced on the sideroad was corroborated with the average queue build- up observed on Google traffic during the PM Peak hour, as shown in Figure 3-12 below. The movement summary is shown in Figure 3-13 below. A signal warrant needs to be conducted at this intersection. 4) Barry Marais Rd. and R21 Rondebult Rd. I/S operates at an overall LOS D and B in the peak hours. The right turn from Rondebult Rd. is significantly high (394veh in the AM peak hour) which reduces the overall intersection LOS. 5) Barry Marais and Road B operates at a satisfactory LOS A; however, the southern approach operates at a LOS F during both peak hours. The volumes on this approach are negligible (the highest being 14veh that turn right during the PM Peak hour), and the software programme does not account for platooning of traffic due to the upstream signal, and subsequent gaps created in the traffic stream. Ideally, from a safety and capacity perspective, the staggered southern leg should be realigned to the main R21/Rondebult approach.

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Figure 3-12 Queue build-up on Barry Marais Rd./Camora St. at 5:05 PM (Google Traffic)

Figure 3-13 LOS Movement Summary for Barry Marais Rd./Camora St.-Road A I/S Base Year 2019, AM and PM Peak Hours

3.6 Recommended Upgrades The following improvements are required in order to safely and efficiently process the current traffic volumes and movements on the road network:

1) R23 Heidelberg Rd. & R550 Springs Rd.: No improvements are required. 2) R550 & Road A: No improvements are required, however if this road is to be used as an alternative access then it is recommended that the junction is sign posted as it is quite easy to miss, and 50m of paving is laid down with the requisite road markings. 3) Barry Marais Rd. and Camora St./Road A: The addition of a right turn lane to Camora St. was tested in the SIDRA model, however it had no effect on the LOS on this approach. The I/S was subsequently signalised with satisfactory results. The EMM needs to be consulted with regard to the informal taxi rank operating from the Road A approach. If current ranking procedures prove problematic during the construction and operation of the mine, then the rank would have to be relocated (or accommodated in the vicinity of the intersection as safely as possible). 4) Barry Marais Rd. and R21 Rondebult Rd: The right turn on Rondebult Rd. operates at LOS F and E even with optimised signal timings. It is recommended that the EMM consider an additional right turn lane on the Rondebult Rd. approach, and additional receiving, short lane on Barry Marais Rd. It was also observed that the off-peak signal timings are not optimised, with Rondebult Rd.

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receiving 60sec green time during the cycle. Driver frustration on Barry Marais Rd. was observed during each cycle, with motorists skipping the red signal. It is thus recommended that the EMM revise the signal settings. 5) Barry Marais and Road B: It is at the EMM’s discretion to correct the staggered approach to improve both safety conditions and vehicle delay at this junction. This intersection is not considered for further analysis.

Table 3-2 Base Year 2019 Recommended Upgrades to Barry Marais Rd. & Camora St./Road A

Control Peak South Approach East Approach North Approach West Approach Average Intersection LOS Int. No. Description Type Hour Delay LoS V/C Delay LoS V/C Delay LoS V/C Delay LoS V/C Delay LoS V/C Barry Marais Rd. & 3 Signal AM 33.4 C 0.4 4.1 A 0.287 34.4 C 0.303 21.2 C 0.926 19.2 B 0.926 Camora/Road A Signal PM 25 C 0.02 9.8 A 0.717 31.9 C 0.713 8.4 A 0.376 12.9 B 0.717

Figure 3-14 LOS Movement Summary for the improved (signalised) Barry Marais Rd. & Camora St./Road A I/S

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4 FUTURE ROAD NETWORK PLANNING

The Gauteng Provincial Department of Roads and Transport have demarcated road reserves for the future provincial K and PWV routes throughout the Gauteng Province. The road planning in the vicinity of the site and in the Brakpan area is shown in Figure 4-1 and Figure 4-2 below. As can be seen in Figure 4-1, the Windmill Shaft surface infrastructure encroaches on the PWV 16 alignment and the Camora St./Road A becomes K165.06 and is re-aligned as shown below.

Figure 4-1 Future K-Route Planning around the Development Site

The footprint of the Windmill Shaft was subsequently repositioned as shown in Figure 4-2 below. Due to the fact that the timeframe for construction of the K165.06 is unknown at this stage, it is proposed that Camora St./Road A remains the main access to the Windmill Shaft. Once K165.06 is constructed, the access to the shaft is proposed as shown in the yellow dashed line in Figure 4-2.

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Figure 4-2 Repositioned Windmill Shaft and proposed new access once K165.06 is constructed

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5 TRAFFIC IMPACT ASSESSMENT

The additional traffic is expected to impact on the environment in three aspects or phases. There will be traffic generated during the construction phase of the plant and the impact of this traffic is generally of a short duration. The second aspect refers to the traffic generated post construction and this traffic is referred to as operational traffic. Operational traffic is generally long term and lasts as long as the mine continues to be active. The third phase is the decommissioning phase, when the ore-extracting activities of the mine have ceased and mine reclamation is being completed.

5.1 Transportation of raw materials from Site During the operational phase of the plant, ore extracted from the mine will be transported via existing pipelines to either the Knights Plant (via the Knights Plant Pipeline) or to the Ergo Plant (Ergo Plant Pipeline).

Figure 5-1 Existing pipelines, adjacent Road A, for the transportation of ore

The transportation of the raw materials will therefore have no impact to the transportation network.

5.2 Site Access The Windmill Shaft Site will be accessed via road by construction vehicles during the construction phase and by employees during the operational phase. The main access to the site will be via the Barry Marais Rd. & Camora St.-Road A I/S and a secondary access from the south via the R550/Road B I/S.

It is recommended that the access road from Barry Marais Rd. to the Windmill Shaft be stabilised and that the remainder of the roadbed from the Windmill Shaft to the R550 I/S is graded to fix any ditches or potholes.

5.3 Construction Phase Traffic 5.3.1 Trip generation and distribution

This traffic relates directly to the traffic expected during the construction of the facility which is expected to take place over a period of 8 years. The construction phase traffic is expected to dissipate shortly after completion of construction of the shaft.

Table 5-1 provides the estimated new trips that will be generated during the construction phase for the AM and PM Peak hours.

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Table 5-1 Trip generation – Construction Phase

Estimated Construction Traffic AM Peak Hour PM Peak Hour In Out In Out Construction Supervisors and Management - cars 10 0 0 10 Foreman/Surveyors – cars/bakkies 10 0 0 10 Buses - staff 5 5 5 5 Minibuses - staff 5 5 5 5 Mechanical Contractors - bakkies 2 0 0 2 Electrical Contractor: Minibus 1 1 1 1 Electrical Contractor: Cars 5 0 0 5 Electrical Contractor: Truck 3 3 3 3 Concrete Trucks 8 8 8 8 Suppliers Trucks 5 5 5 5 Engineers Staff - Cars 5 0 0 5 Visitors 4 0 0 4 Total 62 26 26 62

For the purposes of distributing the above trips to the road network, the following assumptions are made:

 Staff/construction labour will arrive from the nearby informal residential areas of Windmill Park and Villa Liza (walk trips), Vosloorus via Barry Marrais Rd. and Tsakane/Duduza via the R550 and Road A.

 Artisans and other mechanical and electrical contractors will most probably come from Benoni, Boksburg and Germiston via the R21 Rondebult Rd. and Brakpan via Barry Marais Rd.

 Engineers and contractors are assumed to arrive from Johannesburg via the N3/N17 and the R21 Rondebult Rd.

 Concrete trucks are assumed to arrive from Brakpan (Afrisam) via Elsburg Rd., Keurboom St. and Barry Marais Rd.

 Trucks transporting machinery and steel from Gauteng or Durban would arrive via the N3/Barry Marais Rd. Interchange.

 The delivery of abnormal loads will require an Abnormal Load Route Determination study and is not dealt with further in this study.

The construction related trips were subsequently distributed to the road network as follows:

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Figure 5-2 Trip Generation and Distribution for the AM Peak Hour – Construction Phase

Figure 5-3 Trip Generation and Distribution for the PM Peak Hour – Construction Phase

The COTO TIA Guidelines indicate that a traffic impact assessment is only required when more than 50 trips is added to the critical demand movement at an intersection. Given the low demand the impact to the road network is considered to be negligible and will not deteriorate significantly due to the construction activity.

The access intersection namely the Barry Marais Rd. & Camora St./Road A I/S was however analysed further in SIDRA. The construction related trips were added to the Base Year 2019 volumes at this intersection (it is assumed that construction would begin in late 2019/early 2020 thus no growth was added to the background traffic). It is also assumed that the minibus-taxi rank would continue to operate from this junction.

The intersection is evaluated assuming that the recommended upgrades are in place i.e. the intersection is signalised with additional lane capacity on Barry Marais Rd. eastbound.

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Table 5-2 Capacity Results for Construction Related Traffic – Barry Marais Rd. & Camora St./Road A

Control Peak South Approach East Approach North Approach West Approach Average Intersection LOS Int. No. Description Type Hour Delay LoS V/C Delay LoS V/C Delay LoS V/C Delay LoS V/C Delay LoS V/C Barry Marais Rd. 3 Signal AM 40.6 D 0.58 45.2 D 0.93 41.5 D 0.401 29.8 C 0.965 33.4 C 0.965 & Camora/Road A Signal PM 25.9 C 0.14 11.5 B 0.743 32.6 C 0.747 10.6 B 0.449 14.9 B 0.747 The results indicate that the intersection will operate satisfactorily in both the AM and PM Peak hours. The AM Peak hour will require an additional turning phase to accommodate the right turn movement on Barry Marais Rd.

A total of 32 trucks will be added to the road network. Heavy vehicle loading has a significant impact to the pavement structure, however the number of trucks emanating from the construction activity is negligible.

5.4 Operational Phase Traffic The ERPM Mine is reasonably expected to start operations in Year 2028, once all approvals have taken place and the Windmill Park Shaft has been constructed.

It is expected that all mining activity will be concentrated at the Windmill Park Shaft.

The Witpoortje Vent Shaft, once in operation will only attract minor traffic related to operations and maintenance, typically once a month. The shaft has satisfactory access off the R23/Koot Street I/S. Due to the minor impacts generated by the shaft, the impact of this shaft on traffic operations is excluded from further traffic analysis.

5.4.1 Trip generation and distribution

The following assumptions were made to determine the trip generation at the Windmill Park Shaft, based on the anticipated scale of mining activity:

 It is estimated that the mine will employ some 984 employees, categorised as per Table 5-3 below.  The mine will operate in two shifts namely 06:00 – 18:00 and 18:00 – 06:00.  Top and senior management, including specialists will work core hours between 08:00-16:00 and will thus impact the transport network during the normal peak hour traffic periods.  Shift workers will arrive at say 5:30 for the first shift and leave at say 18:30; will arrive at say 17:30 for the second shift and leave at say 06:30. Thus the trips occurring during the peak hour that would have an impact on the network are the shift workers arriving for the second shift at 17:30 in the afternoon and leaving at 06:30 the next morning.  Most of the unskilled and semi-skilled staff will arrive from Vosloorus, Thokoza, Katlehong, Tsakane, Duduza and will make use of public transport.

Table 5-3 Total Staff Complement during the Operational Stage

Occupational Levels Total per Total per Use own car Use Public 1No. of trips day shift Transport

Work normal 100% 4 Top management 4 office hours

Work normal 100% 6 Senior management 6 office hours

Work normal 100% 20 Professionally 20 qualified and office hours

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experienced specialists and mid- management

Skilled technical and 93 car trips academically qualified 2 workers, junior 40% 2 MBT management, 310 155 60% 1 3Bus supervisors, foremen (50% MBT, and superintendents 50% Bus)

25 car trips Semi-skilled and 80% discretionary 248 124 20% (50% MBT, 4 MBT decision-making 50% Bus) 1 Bus

100% 6 MBT Unskilled and defined 198 2 Busses 396 0% (20% Walk, decision-making 40% MBT, 40 4Walk 40% Bus) trips

Total 984 477 163 trips

1Assumptions: 2MBT carries maximum 15 passengers 3Standard Bus carries maximum 55 passengers 4Walk trips are conservatively estimated

Table 5-4 Total Peak Hour Trips during the Operational Phase

AM Peak Hour PM Peak Hour Occupation Levels In Out In Out Top management 4 4 (from JHB, via N3/N17 and R21 Rondebult Rd.) Senior management 6 6 (from JHB, via N3/N17 and R21 Rondebult Rd.) Professionally qualified and 20 20 experienced specialists and mid- management (50% JHB/Benoni/Boksburg, 50% Brakpan/Eastrand) Skilled technical and academically qualified workers, junior management, 2 MBT 93 car trips 93 car trips 2 MBT supervisors, foremen and superintendents 1 Bus 2 MBT 2 MBT 1 Bus (50% JHB/Benoni/Boksburg, 50% 1 Bus 1 Bus Brakpan/Eastrand) Semi-skilled and discretionary decision- 4 MBT 25 car trips 25 car trips 4 MBT making 1 Bus 4 MBT 4 MBT 1 Bus (50% JHB, Benoni & Boksburg, 50% 1 Bus 1 Bus Brakpan/Eastrand)

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Unskilled and defined decision-making 6 MBT 6 MBT 6 MBT 6 MBT (20% Windmill Park, Villa Liza; 40% 2 Busses 2 Busses 2 Busses 2 Busses Vosloorus/Katlehong/Thokoza & 40% 40 walk trips 40 walk trips Duduza/Tsakane Total 46 133 133 46

The main routes and direction of travel for private vehicles, which have the most impact on the road network is shown in Figure 5-4 below.

Figure 5-4 Main direction of travel for private vehicles

A conservative total of 179trips/hr can be expected to arrive/depart the mine during the morning and afternoon peak hours. The trips are distributed on the local network as shown in Figure 5-5 and Figure 5-6.

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Figure 5-5 AM Peak Hour Trip Generation and Distribution – Operational Phase

Figure 5-6 PM Peak Hour Trip Generation and Distribution – Operational Phase

5.4.2 Capacity Evaluation

An estimated total of 179 vehicle trips will added to the road network during the peak hour. The main impacted intersections were considered to be the Barry Marais Rd.& Camora St./Road A access and the Barry Marais Rd./R21 Rondebult Rd. I/S.

The opening year for the mine was considered as Year 2028. As there are no historic traffic counts in the area, traffic growth was estimated from the GDP trend over the past 10 years. GDP growth on average

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was 2%, as illustrated in Table 5-5 below. Background traffic was subsequently grown at 2% to arrive at 2021 volumes. The SIDRA models were updated with the new 2028 traffic volumes and the operational traffic added to the AM and PM traffic volumes.

Table 5-5 Average GDP Growth

Year GDP Growth 2007 5.4% 2008 3.2% 2009 -1.5% 2010 3.0% 2011 3.3% 2012 2.3% 2013 2.5% 2014 1.8% 2015 1.3% 2016 0.6% 2017 1.3% 2018 0.8% Average GDP 2% Growth The results from the SIDRA modelling is shown in Table 5-6 below. The Barry Marais Rd./R21 Rondebult I/S required capacity upgrades in order to process the flows at an acceptable LOS. These upgrades are discussed further in Chapter 6. A LOS D for the overall intersection performance was targeted as acceptable criteria when making capacity improvements to the intersection.

Table 5-6 Results for Site 3 and 4, Opening Year 2028

Control Peak South Approach East Approach North Approach West Approach Average Intersection LOS Int. No. Description Type Hour Delay LoS V/C Delay LoS V/C Delay LoS V/C Delay LoS V/C Delay LoS V/C Barry Marais Rd. & 3 Signal AM 68.1 E 1.033 36.1 C 0.833 46.6 D 0.505 52.6 D 1.081 51.2 D 1.081 Camora/Road A Signal PM 34.9 C 0.103 7.9 A 0.669 83.5 F 1040 49.1 D 1.001 33.7 C 1.04 Barry Marais Rd. & 4 Signal AM 26.3 C 1.019 48.9 D 1.013 7.8 A 0.765 22.3 C 1.019 R21 Rondebult Rd. Signal PM 13.3 B 0.862 33.3 C 0.839 13.7 B 0.306 13.7 B 0.862

5.5 Decommissioning Phase Traffic The mine is expected to continue ore extraction for the next 37 years. Once this activity comes to an end, the mine will be rehabilitated, decommissioned and closed.

It is expected that all mine tailings will be transported via existing overland pipes to the ERGO TSF located adjacent to the mine property. During rehabilitation, a few trucks can be expected to operate to/from site, related to vegetation watering and monitoring, including maintenance. This activity can be expected to continue for approximately 3 years post-closure.

The removal of buildings and the mine shaft could require approximately a third of the estimated construction trips. The road network has been adequately improved to address these trips.

From a transport perspective, the rehabilitation and decommissioning phase will therefore have very little impact on the road network.

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6 ROAD NETWORK UPGRADES REQUIRED

The vehicle trips generated by the mine during the critical peak hours is 179 trips/hour. The main access road is the Barry Marais Rd.& Camora St./Road A junction. An alternative access at the R550/Road A intersection is also proposed however it is unlikely that many vehicles will make use of this access as the concentration of land use and activity lies to the north, east and western areas of the site. The majority of private vehicle trips are therefore assumed to arrive at the site via Barry Marais Rd. and the R21 Rondebult Rd.

Based on the traffic evaluation, the following network improvements are necessary:

1) The Barry Marais Rd. & Camora St./Road A I/S currently experiences significant delay on the side road approaches. Due to the high traffic flow on Barry Marais Rd., vehicles from the side road have difficulty in entering the traffic stream, and the problem is exacerbated since the majority of vehicles from Camora St. turn right in the PM Peak hour. Various lane improvements were modelled; however, it did not alleviate the delay on the side roads. The intersection was subsequently upgraded to a signalised intersection, with capacity upgrades to Barry Marais Rd. which was previously free flow, in order to process the through volumes on the main road at a comparable LOS. The signal should be on a semi-fixed timing plan with the side roads on a vehicle actuated phase (only when a vehicle is present will the side road phase activate) to account for the low traffic volumes during the off-peak hours. The recommended improvements are as follows: a. New signal installation at the intersection b. Short right turn lane on Camora St. c. Extend existing left turn lane on Barry Marais Rd. northbound to 120m and reconfigure lane movements to also include the through movement 2) The Barry Marais Rd./R21 Rondebult Rd. I/S currently operates just within capacity. Once additional traffic volumes and traffic growth is added to the background traffic, the intersection fails to meet the LOS D criteria. Additional through lanes were subsequently added to Barry Marais Rd. and the signal timings optimised to process the traffic flows at an acceptable LOS. Recommended improvements are as follows: a. Additional short through lane (120m) and short receiving lane (60m) on Barry Marais Rd. northbound b. Additional short right turn lane (60m) on R21 Rondebult Rd. and short receiving lane (60m) on Barry Marais Rd. southbound c. New right turn phase for the right turn movement on Barry Marais southbound approach – new signal heads required

The improvements discussed above are shown in Figure 6-1 and Figure 6-2 below.

Figure 6-1 Barry Marais Rd. & Camora St./Road A - Existing and Proposed Layout

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Figure 6-2 Barry Marais Rd. & R21 Rondebult Rd. - Existing and Proposed Layout

3) Grade and stabilise Road A up to the Windmill Shaft. Grade the rest of Road A to the R550 I/S if this is used as an alternate access point to the site. 4) Road pavement appears to be in a satisfactory condition on Barry Marais Rd. (no potholes or cracking observed upon a cursory inspection).

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7 ASSESSMENT OF IMPACTS

7.1 Impact rating The following risk assessment model will be used for determination of the significance of impacts. SIGNIFICANCE = (MAGNITUDE + DURATION + SCALE) X PROBABILITY

The maximum potential value for significance of an impact is 100 points. Environmental impacts can therefore be rated as high, medium or low significance on the following basis: . High environmental significance 60 – 100 points . Medium environmental significance 30 – 59 points . Low environmental significance 0 – 29 points

Table 7-1 Scale used to determine overall ranking of Environmental Impact

Magnitude (M) Duration (D) 10 – Very high (or unknown) 5 – Permanent 8 – High 4 – Long-term (ceases at the end of operation) 6 – Moderate 3 – Medium-term (5-15 years) 4 – Low 2 – Short-term (0-5 years) 2 - Minor 1 - Immediate Scale (S) Probability (P) 5 – International 5 – Definite (or unknown) 4 – National 4 – High probability 3 – Regional 3 – Medium probability 2 – Local 2 – Low probability 1 – Site 1 – Improbable 0 – None 0 – None

7.2 Potential Transport Impacts The following likely transport impacts related to the construction and operational phases of the development have been identified:

7.2.1 Road and intersection capacity and vehicle emissions due to additional traffic loading

Construction Phase: The development will generate an additional 88 trips/hr along Barry Marais Rd. during the peak hours. The increase in traffic will worsen the current capacity constraints at the access intersection to the Windmill Park Shaft, namely Barry Marais Rd. & Camora St./Road A I/S. It is therefore proposed to signalise this intersection, with minor lane improvements. A signal warrant will have to be carried out and approval sought by the EMM for the installation of a new signal. The cost of a signal is approximately R400 000-00. While this cost is marginal, it does however imply that the EMM have an additional signal to maintain.

Operational Phase: The development will generate an additional 179 trips/hr, predominantly along Barry Marais Rd. An additional loading of approximately 65veh/hr can be expected at the Barry Marais Rd./R21RondebulT I/S. This intersection will require minor lane improvements as well as a right turn phase from Barry Marais Rd.

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The average car produces 6 tons of CO2 per year. The impact of an additional 179 vehicles to the network for the duration of the operations will produce an additional 1 074 tons of CO2.

7.2.2 Pavement and impact of concrete truck loading

The pavement condition along Barry Marais Rd. was observed to be in a satisfactory condition.

A total of 8 concrete trucks per day can be expected to deliver concrete to the site for a short duration. Batching plants are in close proximity (Afrisam located in Brakpan – 13km away) thus the impact to the pavement on the surrounding road network will be minor.

7.2.3 Dust Generation

Road A, the access road to the Windmill Shaft is a gravel road. Due to the presence of a number of settlements in close proximity to the mine, it can be anticipated to generate a significant number of walk trips related to work opportunities at the mine. Vehicles could raise dust while travelling on the gravel road, to the detriment of pedestrians. It is therefore recommended that the road is stabilised up to the Windmill Shaft.

7.2.4 Noise pollution

Construction vehicles generate noise both while on the road (being diesel powered) and during operation on site. The noise levels of most earth moving, and material handling equipment is greater than 85 dB. Noise levels do however drop quickly with distance from the source. The site is fortunately located within a greenfields area, with Windmill Park residential area approximately 1.5km away and Villa Liza approximately 2.3km away. The impact of noise on the environment is therefore considered minor and will require little to no abatement strategies.

7.2.5 Impact of haulage vehicles on the road network

During the operational phase, ore will be extracted and transported via overland pipes. This has significant positive benefits for the environment as the number of haulage vehicles is therefore nil.

7.3 Impact Assessment The rating of each impact before and after mitigation measures have been applied is provided in Table 7- 2 below.

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Table 7-2 Impact Assessment: Construction and Operation Phase

Impact Monitoring Significance Receptor / Impact Mitigation and Management No. Process/Activity Environmental Impact Magnitude (M) Duration (D) Scale (S) Probability (P) Resource Effect Measures Time Monitoring Rating Value Frame for Monitoring

Specific Measures to reduce / 5 4 2 4 High 44 manage impacts:  Monitoring of queue [1] [1] [1] [2] [Low] [6]  Make available public transport lengths at the access such as a bus service to/from the intersection to ensure mine for staff from surrounding improvements are effectual settlements to reduce number of  Congestion car and minibus taxi trips on the  Unsafe driving Negative network and subsequent  Capacity on the conditions on the road Monthly monitoring 7.2.1  Additional vehicle trips 2 road network and Upper value indicated is as per Table 1 above before any mitigation measures are applied. reduction in CO emissions. during construction and generated by activity network Impact 2 2  Lane capacity improvements to quarterly during CO emissions at the new  Additional CO impacted intersections to reduce operations. development emissions delays and overall journey time. Lower value indicated in brackets beneath indicates respective rating after mitigation measures  Signalisation of access contemplated in the table to the right are considered. intersection (Barry Marais Rd./Road A I/S) to reduce delays and improve safety by reducing the number of conflict points.

 Increase in heavy

vehicle volumes  Trucks should not be overloaded  Deterioration in Monthly monitoring during construction Negative 2 2 2 2 Low 12 and wheel/axle loading should be pavement quality  Monitoring of truck loading during construction. 7.2.2 (total of 32 truck trips in accordance to legislation (TMH for compliance  Pavement resulting in unsafe Impact [1] [1] [1] [2] [Low] [6] added to the road 3) Condition driving conditions network, including 8 concrete trucks)

E.g.  Dust inhalation by  Dust Generation  Increase in vehicle Negative 4 4 2 5 High 50 7.2.3 volumes along Road staff walking to work  Stabilised roadbed  Monitoring of dust levels Monthly monitoring Impact [1] [1] [1] [2] [Low] [6] along Road A during construction and A (gravel) operation

 Noise generation  Transportation of  None required – site is within a by heavy vehicles  Noise Pollution to Negative 1 1 1 2 Low 6 supplies by heavy greenfields location, nearest 7.2.4 during the nearby residential vehicles during the settlements are 1.5 – 2.3km construction areas within earshot Impact [1] [1] [1] [2] [Low] [6] construction phase away phase  Transportation of raw

materials by overland Positive 1 1 1 2 Low 6  Impact of haulage pipes thus no impact 7.2.5  None of raw materials to roadway capacity Impact [1] [1] [1] [2] [Low] [6] and pavement condition

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8 CONCLUSIONS AND RECOMMENDATIONS

The following conclusions can be drawn from the study:

1) The proposed ERPM Ext 2 underground mine area extends from Barry Marais Rd. eastwards across Heidelberg Rd. and towards the Tsakane informal settlement area. Hard infrastructure that will be constructed comprises the Windmill Shaft, providing access to the mine area and located to the western limits of the project site, just off Barry Marais Rd. The Witpoortje Shaft is an existing vent shaft that will be re-opened to serve the Ext 2 mine area. 2) The site is well-located in terms of road infrastructure, being located adjacent to some of the major mobility north-south and east-west roads in the area namely Barry Marais Rd., R21 Rondebult Rd., R23 Heidelberg Rd. and R550 Springs Rd. 3) During the operational phase of the plant, ore extracted from the mine will be transported via existing overland pipelines to either the Knights Plant (via the Knights Plant Pipeline) or to the ERGO Plant (ERGO Plant Pipeline). The transportation of the raw materials will therefore have no impact to the road network. 4) Thus, the Windmill Shaft site will only be accessed via road by construction vehicles during the construction phase and by employees during the operational phase. The main access to the site will be via the Barry Marais Rd. & Camora St.-Road A I/S with a secondary access from the south via the R550/Road B I/S. 5) The Gauteng Provincial Department of Roads and Transport have demarcated road reserves for the future provincial K and PWV routes that run across the development site. The Windmill Shaft originally encroached on the PWV 16 alignment. The footprint was subsequently amended to fall outside of the road reserve. The Camora St./Road A becomes K165.06 with a change in the alignment. Due to the fact that the timeframe for construction of the K165.06 is unknown at this stage, it is proposed that Camora St./Road A remains the main access to the Windmill Shaft. Once K165.06 is constructed, the access to the shaft can be re-positioned with little impact to mining operations. 6) During the Construction Phase, the development will generate an additional 88 trips/hr along Barry Marais Rd. during the peak hours. The increase in traffic will worsen the current capacity constraints at the access intersection to the Windmill Park Shaft, namely Barry Marais Rd. & Camora St./Road A I/S. It is therefore proposed to signalise this intersection, with minor lane improvements. A signal warrant will have to be carried out and approval sought by the EMM for the installation of a new signal. The cost of a signal is approximately R400 000-00. While this cost is marginal, it does however imply that the EMM have an additional signal to maintain. 7) During the Operational Phase, the development will generate an additional 179 trips/hr, predominantly along Barry Marais Rd. An additional loading of approximately 65veh/hr can be expected at the Barry Marais Rd./R21RondebulT I/S. This intersection will require minor lane improvements as well as a right turn phase from Barry Marais Rd. 8) An informal taxi rank is operated from the north-east quadrant of Barry Marais Rd. & Camora St./Road A I/S. The rank may have to be formalised and the layout re-configured in order to operate safely once the intersection is signalised.

The following recommendations are made:

1) The following upgrades are recommended at the Barry Marais Rd.& Camora St./Road A access I/S during the Construction Phase: a. New signal installation at the intersection b. Short right turn lane on Camora St. c. Extend existing left turn lane on Barry Marais Rd. northbound to 120m and reconfigure lane movements to also include the through movement 2) The following upgrades are recommended at the Barry Marais Rd./R21 Rondebult Rd. I/S during the Operational Phase:

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a. Additional short through lane (120m) and short receiving lane (60m) on Barry Marais Rd. northbound b. Additional short right turn lane (60m) on R21 Rondebult Rd. and short receiving lane (60m) on Barry Marais Rd. southbound c. New right turn phase for the right turn movement on Barry Marais southbound approach – new signal heads required 3) It is recommended that the access road from Barry Marais Rd. to the Windmill Shaft be stabilised and that the remainder of the roadbed from the Windmill Shaft to the R550 I/S is graded to fix any ditches or potholes. 4) The informal taxi rank may have to be formalised and the layout re-configured in order to operate safely once the intersection is signalised. 5) All other environmental impacts due to traffic generation is minor and it is recommended that the development go ahead from a Traffic Engineering perspective.

APPENDIX 20 IMPACT ASSESSMENT

ERPM EXTENSION AREA 1 (PTY) LTD

IMPACT ASSESSMENT FOR THE PROPOSED ERPM EXTENSION 2 MINE, PROPOSED BY ERPM EXTENSION 1 AREA (PTY) LTD, EKURHULENI SOUTH EAST MAGISTERIAL DISTRICT, GAUTENG PROVINCE

SEPTEMBER 2019

Prepared for: ERPM Extension Area 1 (Pty) Ltd Unit 206 Alto Level House 4 Fir Drive Northcliff 2195

TABLE OF CONTENTS

1. Introduction and Background ...... 1 1.1. Specialist Studies ...... 1 1.2. Impact Assessment ...... 1 1.3. Impact Rating Methodology ...... 1 1.4. Cumulative Impacts ...... 2 2. Description and Assessment of Potential Impacts ...... 3 2.1. Air Quality ...... 3 2.2. Noise and vibrations ...... 6 2.3. Soil and Land Use ...... 9 2.4. Archaeology and Palaeontology ...... 12 2.5. Hydrology ...... 14 2.6. Geohydrology ...... 17 2.7. Socio-economic ...... 20 2.8. Visual Aesthetics ...... 25 2.9. Terrestrial Ecology ...... 28 2.10. Aquatic Ecology and Wetlands ...... 31 2.11. Traffic ...... 34 2.12. Cumulative Impacts ...... 36

Project Name: ERPM Extension 2 Mine ii Report Title: Impact Assessment Project number: 181020 Date: September 2019 1. INTRODUCTION AND BACKGROUND

This report is to be read in conjunction with the Environmental Impact Assessment Report (EIAR) and the Environmental Management Programme (EMPr), as compiled for the proposed ERPM Extension 2 (ERPM Ext 2) Mine.

1.1. Specialist Studies

Specialist service providers within their respective fields were commissioned to undertake studies to investigate the baseline conditions of the receiving environment as well as to assess the potential impact the activities and aspects of the proposed ERPM Ext 2 Mine may have. The following specialist studies were conducted:

Air Quality IMA Trader 20 cc Blasting Blast Management & Consulting Soil and Land Use Prime Resources (Pty) Ltd Heritage Archaetnos Culture & Cultural Resource Consultants Palaeontology Prof Marion Bamford Hydrology African Environmental Development Geohydrology Future Flow Groundwater & Project Management Solutions Noise IMA Trader 20 cc Socio-economic Prime Resources (Pty) Ltd Visual aesthetics Prime Resources (Pty) Ltd Aquatic Ecology and Wetlands Scientific Aquatic Services Terrestrial Ecology Scientific Terrestrial Services Traffic Merchelle’s Collective (Pty) Ltd 1.2. Impact Assessment

The potential environmental impacts are described per environmental receptor for each phase of the development. Where mitigation was recommended these have been included. The tabulated impact assessments are included in Section 2.

1.3. Impact Rating Methodology

Below is an assessment of the nature, extent, duration, probability and significance of the identified environmental and social impacts of the project. The significance of both positive and negative potential impacts was determined through the evaluation of impact consequence and likelihood of occurrence. The following risk assessment model has been used for determination of the significance of impacts.

Consequence Extreme Human health morbidity /mortality. Loss of species Severe Materially reduced faunal populations, loss of livelihoods, individual economic loss Substantial Material reduction in environmental quality – air, soil, water. Loss of habitat, loss of heritage, amenity Moderate Nuisance Slight Negative change – with no other consequences

Probability 1 Highly unlikely 2 Unlikely 3 Possible 4 Probable 5 Definite

Project Name: ERPM Extension 2 Mine 1 Report Title: Impact Assessment Project number: 181020 Date: September 2019 Significance

Extreme Moderate High High Fatally flawed Fatally flawed

Severe Low Moderate High High High

Substantial Low Moderate Moderate Moderate Moderate

Moderate Low Low Low Low Moderate

Consequence Slight Low Low Low Low Low

Highly unlikely Unlikely Possible Probable Definite

Fatally flawed Unacceptable level of risk

High Requires strict conditions and high levels of compliance and enforcement

Moderate Requires conditions and routine inspections

Low Little risk of environmental degradation

Where mitigation was recommended these have been included and the significance of the particular impact then determined following mitigation (these values are indicated within square brackets).

1.4. Cumulative Impacts

This section ends with a qualitative assessment of cumulative impacts, defined as the potential contribution of ERPM Ext 2 to the overall existing impacts in the surrounding area.

Project Name: ERPM Extension 2 Mine 2 Report Title: Impact Assessment Project number: 181020 Date: September 2019 2. DESCRIPTION AND ASSESSMENT OF POTENTIAL IMPACTS

2.1. Air Quality

Both nuisance dust and fine particulate matter will be generated and released into the atmosphere during the construction, operation and closure phases. The main activities which were identified will include:

 Access roads to the SDAs  Increased vehicle trips generated by the mine  Site clearing, including the removal of vegetation and topsoil  Development of the shaft, including blasting and excavations  Management of topsoil, overburden and waste rock stockpiles  Underground activities (including combustion vehicles) emitting gases through the vent shafts  Earthworks during rehabilitation

The potential dust related activities may be mitigated in a variety of ways however, predominant methods include dampening dust generating surfaces and applying dust palliatives. Stockpiles and cleared areas may be protected from wind by establishing vegetation or installing windbreaks as necessary.

Coarse Fraction Dust

Coarse fraction dust is the dust that will settle out of the air relatively quickly. Use of the access roads to the SDAs and other activities such as site and vegetation clearing, topsoil handling and the development of the shafts, including blasting and excavations are expected to result in the generation of nuisance dust, which may be experienced by people living near the project. Dust has a particle size of > 10 microns (PM10) therefore, it is not expected to have a health impact. Fugitive dust is visible and will be nuisance when deposited on objects near the project. If very high rates of dust fallout occur the growth of plants may be affected.

 Nature: Negative  Consequence: Moderate. The extent of the nuisance impact is dependent on wind speed and direction however it is expected that it will remain a local impact. The duration will continue throughout the life of mine, and will cease when the activities cease, assuming that rehabilitation is effective.  Probability: The probability for nuisance dust to be generated is definite.  Significance: The significance is Moderate prior to mitigation. With the implementation of mitigation, the probability can be reduced to possible, reducing the significance to Low.

Particulate matter < 10 microns (PM10 and PM2.5)

Particulate matter (PM) suspended in the atmosphere with particle sizes of less than 10 microns is inhalable and may cause considerable health problems. This PM is generated by the same processes as the Coarse Dust Fraction (mineral dust) but may also be generated from exhaust systems and smoke. PM10 and PM2.5 present as smog and only the larger fraction settles out of the atmosphere. A number of health effects (human and animals) have been associated with inhaling fine particulates. Similarly, these fine particulates may clog the stomata in plants leading to poor plant growth.

 Nature: Negative

Project Name: ERPM Extension 2 Mine 3 Report Title: Impact Assessment Project number: 181020 Date: September 2019  Consequence: Substantial. The extent of the health impact is dependent on wind speed and direction however it is expected that it will remain a local impact. The duration will continue throughout the life of mine, and will cease when the activities cease  Probability: The probability for fine particulates to be generated and impact on human health is possible.  Significance: The significance is Moderate prior to mitigation. With the implementation of mitigation, the consequence can be reduced to Moderate, reducing the significance to Low.

Emission of NO2, SO2 CO2 and BTEX released to the atmosphere during the construction, operation and closure phases. The main activities which were identified will include:

 The use of internal combustion vehicles and equipment;  The use of hazardous chemicals and fuels, including their storage and handling;  Underground activities; and  Increased vehicle trips.

The potential emissions may be mitigated by:

 Choosing low sulphur diesel for vehicles and machines;  Developing a storage and handling plan for the chemicals and fuels to be used, ensuring the legal storage of chemical and fuels, and implementing an emergency response plan for spills and fires, and training users;  Undertaking air quality monitoring at the shaft to determine compliance with the NAAQS at the surface, and equipping shafts with filters if monitoring results reveal that filters are necessary to remove pollutants;  Making use of mass transport to reduce the number of vehicles; and  Choosing efficient vehicles and machinery and keeping them in good operating condition.

Volatile organic carbons (VOCs), SO2 and NO2 emissions

VOCs, NOx and SOx emissions generally originate from the burning of fossil fuels and in the mining sector these can be a result of vehicle exhaust gases (trackless mining equipment) and the generation of electricity. VOCs, NOx and SOx are pollutants which can cause irritation and health issues and be precursors to acid rain. It is expected that these emissions will be released from the underground mine via the Witpoortje vent shaft.

 Nature: Negative  Consequence: Substantial. The extent of the health impact is dependent on wind speed and direction however it is expected that it will remain a local impact. The duration will continue throughout the life of mine, and will cease when the activities cease  Probability: The probability for emissions to be generated and impact on human health is unlikely.  Significance: The significance is Moderate prior to mitigation. With the implementation of mitigation, the consequence can be reduced to Moderate, reducing the significance to Low.

Project Name: ERPM Extension 2 Mine 4 Report Title: Impact Assessment Project number: 181020 Date: September 2019 Post- Significance Mitigation Activity Impact Phase Mitigation Rating Significance Rating  Access roads  Increased vehicle trips generated by the mine  Dampening dust generating surfaces  Site clearing, including the  Applying dust palliatives removal of vegetation and topsoil  Protecting stockpiles and cleared areas from wind by Nuisance dust emissions  Development of the shaft, Moderate establishing vegetation or installing windbreaks as Low towards sensitive receptors including blasting and excavations necessary  Management of topsoil,  Erecting screens around initial blast areas, cover further overburden and waste rock blasts so that dust settles within the shafts. stockpiles  Earthworks during rehabilitation. Construction  Use, storage and handling of Operation Fine particulate matter  Choosing low sulphur diesel for vehicles and machines hazardous chemicals and fuel Decommissioning emissions towards sensitive  Developing a storage and handling plan for the chemicals  Underground activities (including Moderate Low receptors (with potential health and fuels to be used, ensuring the legal storage of combustion vehicles) emitting impacts) chemical and fuels, and implementing an emergency gases through the vent shafts response plan for spills and fires, and training users  Use of internal combustion  Equipping shafts with filters if monitoring results reveal

vehicles and equipment Emission of NO2, SO2 CO2 and that filters are necessary to remove pollutants  Use, storage and handling of BTEX released to the  Making use of mass transport to reduce the number of Moderate Low hazardous chemicals and fuels atmosphere (with potential vehicles  Underground activities health impacts)  Choosing efficient vehicles and machinery and keeping  Increased vehicle trips them in good operating condition.

Project Name: ERPM Extension 2 Mine 5 Report Title: Impact Assessment Project number: 181020 Date: September 2019 2.2. Noise and vibrations

Ground vibration, air blast and fly rock impacts on houses, broiler chickens, powerline, pipelines, roads and water boreholes.

 The potential impacts are applicable in the construction phase as the effects of blasting during operation will be very low.  The potential impact does not have specific mitigation and management measures for vibration and fly rock, but monitoring is required during each blast. The effects of air blast may be mitigated by covering during the first three to four blasts. All residents in the area should be made aware of the blasting programme and safe evacuation distances for people and animals.

Vehicle usage may result in increased noise levels for rural smallholdings or Eggbert facilities along the access route (for Windmill shaft) and for the rural smallholdings on the west of the Witpoortje SDA.

 The potential impact is applicable in the construction, operation, closure and post-closure phases.  The potential impact can be mitigated by restricting deliveries to the SDA to day-time hours only, imposing reduced speed limits, ensuring that all min vehicles that access the SDA are in good condition and compliant with manufacturers specifications.

Activities on site may result in increased noise levels at adjacent residential properties located around the SDAs.

 The potential impact is applicable throughout the Life of Mine.  The potential impact can be mitigated by ensuring that construction activities, blasting and rock breaking, and waste rock stockpiling do not occur at night; maintaining earth moving equipment to ensure compliance with manufacturers specifications; if required, implementing acoustic screening between the SDA and residents; using acoustic barriers for equipment; ensuring that drill rigs are in good working condition and muffled where possible; developing a blasting plan; training drivers not to over-rev engines and turning off engines when standing for long periods; and designing internal roads for continuous flow to avoid unnecessary reversing.

Noise

The noise that is expected to be generated from the project will be nuisance noise from the operation of machinery, equipment and vehicles. It is likely that it would impact on people living close to the SDAs, especially during the construction phase. During the operational phase noise associated with the commuting of workers to and from the Windmill Shaft SDA will be produced. It is expected that the operation of the shaft headgears, winders and fans for the ventilation shaft will produce noise.

 Nature: Negative  Consequence: Moderate. The extent of the nuisance impact is local. The duration will continue throughout the life of mine, and will cease when the activities cease.  Probability: The probability for nuisance noise to be generated is definite.  Significance: The significance is Moderate prior to mitigation. With the implementation of mitigation, the probability can be reduced to probable, reducing the significance to Low.

Project Name: ERPM Extension 2 Mine 6 Report Title: Impact Assessment Project number: 181020 Date: September 2019 Blasting and vibrations

Blasting produces ground vibration, air blast and fly rock which can all be dangerous. Fly rock may directly injure people and animals. Air blast and vibration can have a negative effect on infrastructure, causing cracking and possible collapse. Air blast will be perceptible only for the first 3 - 4 blasts as the shafts are constructed. People and animals within approximately 500 m of the blasting may be startled.

 Nature: Negative  Consequence: Substantial. It is expected that extent of the potential damaging impacts of blasting will be local and occur during the construction phase only.  Probability: The probability for damage to result from blasting is unlikely.  Significance: The significance is Moderate prior to mitigation. With the implementation of mitigation, the probability can be reduced to highly unlikely, reducing the significance to Low.

Project Name: ERPM Extension 2 Mine 7 Report Title: Impact Assessment Project number: 181020 Date: September 2019 Post- Significance Mitigation Activity Impact Phase Mitigation Rating Significance Rating Ground vibration, air blast, fly  The effects of air blast may be mitigated by covering the rock - with the potential to cause first three to four blasts. All residents in the area must be  Blasting to sink shaft damage to infrastructure, and Construction Moderate Low made aware of the blasting programme and safe pose a danger to people and evacuation distances for people and animals (livestock). animals  Restrict deliveries to the SDA to day-time hours only  Impose reduced speed limits  Ensure that all vehicles that access the SDA are in good condition and compliant with manufacturers specifications.  Ensuring that construction activities, blasting and rock breaking, demolition and waste rock management do not occur at night  Maintaining earth moving equipment to ensure compliance with manufacturers specifications  Liaising closely with landowners and if required,  Vehicles on access roads implementing acoustic screening between the SDA and  Use of equipment and machinery residents on site, including reverse beepers Increased noise levels on site Construction  Ensuring that drill rigs are in good working condition and  Shaft headgears, winders, and at adjacent residential Operation Moderate Low muffled where possible ventilation fans property Decommissioning  Developing a blasting plan that includes consultation with  Drilling and blasting affected receptors  Deposition on WRD  Training drivers not to over-rev engines, turning off engines when standing for long periods, muffling engines as per manufacturers specifications, servicing vehicles regularly  Designing internal roads for continuous flow to avoid unnecessary reversing.  Minimise the noise level of audible warning devices for the health and safety of employees  Selecting the lower noise producing equipment and ensuring that equipment includes silencers or mufflers were available.

Project Name: ERPM Extension 2 Mine 8 Report Title: Impact Assessment Project number: 181020 Date: September 2019 2.3. Soil and Land Use

Soil loss, particularly at the Windmill Shaft SDA, resulting in decreased land capability – caused by development on agricultural potential soil, and the permanent loss of this soil under the footprint of the WRD which will remain at closure. Soil loss is also caused by soil erosion.

 The activities take place during the construction and operational phases however the potential impact is long-term to permanent.  The potential impact can be mitigated by keeping the infrastructure footprint and the area of disturbance as small as possible, forbidding the use of stockpiled soil for construction, identifying locations for soil stockpiles where they will not be disturbed during the operational life of the project, and contractually committing contractors and subcontractors to the Soil Management Plan. Soil erosion can be managed by implementing stormwater management and erosion control measures, limited clearing of vegetation, restricting the height of soil stockpiles and vegetating the side slopes.

Soil contamination due to leaks and spills, and construction materials such as cement.

 The potential impact is applicable in the construction, operation and decommissioning phases.  The potential impact can be mitigated by implementing a Hydrocarbon Management Plan which addresses storage and handling of hydrocarbons, cleaning up spillages of hazardous material, employing good waste management and housekeeping practices, managing contaminated soil appropriately (remediation or disposal), and ensuring that cement storage and batching occurs on an impermeable surface. A soil contamination assessment must be carried out at mine closure and remediation measures implemented.

Ineffective stockpiling and management of soil stockpiles may reduce the potential for successful vegetation establishment and rehabilitation.

 The potential aspect is applicable in the construction and operation phase however the impact shall be realised during rehabilitation in the closure phase.  The potential impact can be mitigated by undertaking strategic, planned stockpiling, using the soil stripping guideline presented in the Soil and Land Use Survey, ensuring that soil stripping occurs during the dry winter months (or ensure that soil is reasonably dry), and effective stockpile management. A soil contamination assessment must be carried out after stockpiling.

Ineffective rehabilitation may result in the area no longer being suitable for its intended land use.

 The potential impact is applicable in the post-closure phase.  The potential impact can be mitigated by implementing the measures described in the Final Rehabilitation Decommissioning and Closure Plan, and appropriate remedial measures as advised by an appropriately qualified contamination specialist.

Soil and land use

Soil is needed for the establishment of plants which in turn support land uses like agriculture and livestock grazing. Soil may be lost directly by constructing infrastructure on top of the soil, poor management of soil stockpiles, or by poor site management resulting in erosion. The integrity of the soil may also be diminished if the soil is contaminated.

Project Name: ERPM Extension 2 Mine 9 Report Title: Impact Assessment Project number: 181020 Date: September 2019  Nature: Negative  Consequence: Substantial. The extent of the loss of soil will be limited to the site and the duration is considered permanent.  Probability: The probability of soil loss occurring is definite.  Significance: The significance is Moderate prior to mitigation. With the implementation of mitigation, the consequence can be reduced to Moderate, reducing the significance to Low.

Project Name: ERPM Extension 2 Mine 10 Report Title: Impact Assessment Project number: 181020 Date: September 2019 Post- Significance Mitigation Activity Impact Phase Mitigation Rating Significance Rating  Keeping the infrastructure footprint and the area of  Vegetation clearing and grubbing disturbance as small as possible  Stripping and subsoil stockpiling  Forbidding the use of stockpiled soil for construction  Construction of surface  Identifying locations for soil stockpiles where they will not infrastructure and roads be disturbed during the operational life of the project  Excessive stormwater run-off from  Contractually committing contractors and subcontractors constructed hardstanding areas Construction Loss of soil (including soil to the Soil Management Plan and roads, and within the mining Operation erosion) leading to loss land use Moderate  Implementing and maintaining stormwater management Low footprint Decommissioning potential measures (such as installing erosion control measures)  Removal of surface infrastructure, Closure  Restricting activities to the demarcated areas access roads, etc.  Restricting the height of the topsoil stockpiles to 4 – 5 m  Excessive stormwater runoff from  Vegetating stockpile sides and exposed soils with locally newly rehabilitated areas which adapted perennial or annual grass seed mixtures have not been vegetated or  Implementing an appropriate fertilizer programme if revegetation has not re-established vegetation is slow, and stabilising erosion-sensitive areas.  Implementing a Hydrocarbon Management Plan which addresses storage and handling of hydrocarbons  Cleaning up spillages of hazardous material  Employing good waste management and housekeeping  Potential leaks and spills of Construction practices chemicals such as hydrocarbons, Soil contamination Operation Moderate  Managing contaminated soil appropriately (remediation or Low hazardous chemicals and cement. Decommissioning disposal)  Ensuring that cement storage and batching occurs on an impermeable surface.  A soil contamination assessment must be carried out at mine closure and remediation measures implemented.  Strategic, planned stockpiling, using the soil stripping  Stripping and stockpiling of topsoil guideline presented in the Soil and Land Use Survey, and subsoil and other site Reduced soil quality resulting in Construction ensuring that soil stripping occurs during the dry winter activities including heavy vehicles reduced potential for vegetation Moderate Low Operation months (or ensure that soil is reasonably dry), and and earth moving machinery on establishment and rehabilitation effective stockpile management. A soil contamination site assessment must be carried out after stockpiling.  Implementing the measures described in the Final  Ineffective rehabilitation and Sites are incompatible with Rehabilitation Decommissioning and Closure Plan, and Post-closure Moderate Low further degradation of soil quality future land use appropriate remedial measures as advised by an appropriately qualified contamination specialist.

Project Name: ERPM Extension 2 Mine 11 Report Title: Impact Assessment Project number: 181020 Date: September 2019 2.4. Archaeology and Palaeontology

Objects of heritage significance may be lost. Three sites of cultural heritage significance were located within the Witpoortje SDA, two of which were of negligible heritage importance and may be demolished upon approval by the relevant heritage authority. The third site included graves and therefore has a high heritage value.

 The loss of object of heritage value would occur during the construction phase.  The potential impact of disturbing unknown object of heritage value can be mitigated by implementing a chance finds procedure. SDA will not directly influence the graves but to ensure that the graves would not be desecrated, mitigation measures for protecting the grave sites by fencing the area and developing a management plan for the sustainable preservation thereof shall be implemented, or the remains could be exhumed and relocated and reinterred.

Graves were identified in the vicinity of the Witpoortje Vent Shaft SDA. These graves will have to be conserved either through protecting them in-situ or through exhumation, relocation and reinternment.

 Nature: Negative  Consequence: Substantial. The extent of the damage to grave sites or other heritage resources will be limited to local and the duration is considered permanent.  Probability: The probability of damage to heritage resources is unlikely.  Significance: The significance is Moderate prior to mitigation. With the implementation of mitigation, the consequence can be reduced to Moderate, reducing the significance to Low.

Project Name: ERPM Extension 2 Mine 12 Report Title: Impact Assessment Project number: 181020 Date: September 2019 Post- Significance Mitigation Activity Impact Phase Mitigation Rating Significance Rating  A chance finds procedure shall be implemented. Potential damage to  Fencing the grave site area and developing a archaeological and  Project activities Construction Moderate management plan for the sustainable preservation Low paleontological artefacts and thereof, or the remains could be exhumed and relocated desecration of graves and reinterred.

Project Name: ERPM Extension 2 Mine 13 Report Title: Impact Assessment Project number: 181020 Date: September 2019 2.5. Hydrology

The discharge of surplus underground water may result in the contamination of surface water. Although all groundwater intercepted during the construction and operation of the project is expected to be used by ERGO, the quantity of water is unknown. Therefore, it may be necessary to discharge the excess water to surface.

 The potential impact is applicable in the construction and operation phase.  The potential impact can be mitigated by treating water before discharge and reducing ingress into the mine where possible by grouting ingress points.

Dewatering of the shaft and mining area will result in localised groundwater drawdown impacting surface water and wetland volumes

 The potential impact is applicable in the construction and operational phases.  The potential impact can be mitigated by monitoring groundwater levels and stream flow volumes as well as sealing off individual high yielding inflow zones intercepted during excavation.

Contaminated runoff from SDAs resulting in loss of surface water quality.

 The potential impact is applicable in the construction, operational and closure phases.  The potential impact can be mitigated by monitoring surface water to identify and manage pollution sources, installing appropriate pollution control dams and clean and dirty water separation. Waste Rock Dumps should be designed and managed to control contaminated runoff.

Water decanting from the mine after closure may result in the contamination of surface water quality.

 The potential impact is applicable in the post-closure phase.  The potential impact can be mitigated by developing a numerical ground water model within five years of operations (and updating it every five years), planning discharge options for decant water at least 10 years prior to closure, ensuring that a suitable water use is identified for the treated water, and ensuring that there are sufficient funds in the trust for a long time after closure.

Discharge of excess water

The quantity of water in the catchment (contributing to stream flow) may increase should there be a need to discharge excess water to surface.

 Nature: Negative  Consequence: Substantial. It is currently not anticipated that discharge will be undertaken and as such the impact has not been fully assessed. However, should this unforeseen impact occur it will result in changes to the downstream environment of the natural watercourses, in both quantity and quality of the water. Should it occur, it is likely to extend from construction through to decommissioning. The mine has planned for a treatment facility should discharge be required.  Probability: Due to the lack of detailed assessment, the probability of discharge occurring is considered probable (precautionary principle).  Significance: The significance is Moderate before and after the implementation of mitigation measures.

Surface water quality

Project Name: ERPM Extension 2 Mine 14 Report Title: Impact Assessment Project number: 181020 Date: September 2019 A decrease in water quality in the surrounding surface water systems may occur as a result of contamination by hazardous chemicals and runoff from the WRD.

 Nature: Negative  Consequence: Moderate. Contaminated runoff will be limited to the areas downstream of the mine and will occur throughout the life of mine.  Probability: The probability of contaminated runoff leaving the site and contaminating surface water is possible.  Significance: The significance is Moderate prior to mitigation. With the implementation of mitigation, the probability can be reduced to Unlikley, reducing the significance to Low.

Decant of contaminated groundwater post-closure

Post closure, there is a risk that contaminated groundwater will decant and spill into the surrounding water courses.

 Nature: Negative  Consequence: Severe. The extent of decant is unknown as the possible decant locations are currently unknown. It is expected that the decant positions will be contained within the MRA. Should decant occur, it is likely to continue permanently.  Probability: The probability of decant occurring is currently unknown and therefore considered to be probable (precautionary principle).  Significance: The significance of decant occurring is considered High prior to and with mitigation.

Project Name: ERPM Extension 2 Mine 15 Report Title: Impact Assessment Project number: 181020 Date: September 2019 Post- Significance Mitigation Activity Impact Phase Mitigation Rating Significance Rating  Dewatering of the shaft and Loss of surface water and Construction  Sealing off individual high yielding inflow zones mining resulting in localised Low Low wetland volumes Operation intercepted during excavation and mining. groundwater drawdown Construction  Discharge of surplus underground  Treatment of water before it is discharged Contamination of surface water. Operation Moderate Moderate water  Grouting ingress points into the mine Closure  Installing appropriate pollution control dams and clean Construction Contamination of surface water and dirty water separation  Contaminated runoff from site Operation Moderate Low resources  WRD should be designed and managed to control Closure contaminated runoff.  Develop a numerical groundwater model within five years of operations (and updating it every five years) and Contamination of surface planning discharge options for decant water at least 10  Water decanting from mine after water, damage to aquatic life in Closure years prior to closure High High closure streams, and degradation of Post-closure  Ensuring that a suitable water use is identified for the the Vaal River water quality treated water  Managing the groundwater levels through pumping and treatment plants.

Project Name: ERPM Extension 2 Mine 16 Report Title: Impact Assessment Project number: 181020 Date: September 2019 2.6. Geohydrology

The dewatering during shaft excavation will lead to an impact on upper aquifer volumes (quantity) during construction.

 The potential impact is applicable in the construction phase.  The potential impact can be mitigated by monitoring groundwater levels for managing the dewatering processes as well as sealing off individual high yielding inflow zones intercepted during excavation.

The dewatering during mining operations will lead to an impact on deep aquifer volumes (quantity) during operation.

 The potential impact is applicable in the operational phase.  The potential impact can be mitigated by monitoring groundwater levels and inflow to better understand the groundwater in the deep aquifers as well as sealing off individual high yielding inflow zones intercepted during mining.

Contamination of groundwater due to poor quality seepage from the mining area and surface stockpiles.

 The potential impact is applicable in the construction, operational, closure and post closure phases.  The potential impact can be mitigated by implementing appropriate water and hazardous chemical management (including monitoring and clean and dirty water separation), sealing off individual high yielding inflow zones as well as appropriately lining the stockpiles to limit seepage.

Recovery of groundwater levels (quantity) from the deep aquifers. When mining processes are complete the mine will no longer require a dry working area and pumping of water out of the mine will stop. The water levels within the mine and the surrounding aquifers will rise and return to predevelopment levels.

 The potential impact is applicable in the decommissioning and post-operational phases.  This is a positive impact, thus no mitigation measures are required.

Potential for decant of contaminated groundwater on surface. The groundwater in the deep aquifers is expected to be of poor quality. As the groundwater levels return to pre-development levels (after closure), minerals in the surrounding rock also dissolve and are transported towards the surface, initiating the Acid Mine Drainage process. The volume of water that will be intercepted is unknown as is the expected quality therefore, the precautionary principle (worst case scenario) has been used in estimating the impact.

 The potential impact is applicable in the post-closure phase.  This impact can be mitigated by managing the groundwater levels through pumping and treatment plants. The development (within five years of operation) and regular update (every five years) of a numerical groundwater model will assist in understanding and managing the impact by the time the mine is closed. This would limit the scale and the magnitude of the impact however, the impact would remain permanent and definite.

Groundwater quantity

The void from mining excavations is kept dry through the practice of dewatering where the mine pumps the groundwater out of the surrounding aquifers faster than it can flow in. Dewatering of the upper aquifers drops the level of the groundwater in the immediate area which may affect the supply of groundwater to

Project Name: ERPM Extension 2 Mine 17 Report Title: Impact Assessment Project number: 181020 Date: September 2019 nearby boreholes as well as groundwater fed rivers and wetlands. This project is expected to have very deep excavations (about 2500 m) and the surface aquifers (active or fractured rock aquifers) will only be affected in the first 100 m during the sinking of the shaft, after which the groundwater levels are expected to return to pre-development levels.

The connectedness of the surface and the deep aquifers is unknown and there is a risk that dewatering of the deep aquifers may result in the dewatering of the surface aquifers.

 Nature: Negative  Consequence: Moderate. Drawdown of groundwater levels in the immediately vicinity of Windmill shaft is not expected to affect any surrounding privately-owned boreholes and is only expected to occur during the first 100m of shaft construction. Should there be a connection between the upper and deep aquifers, the consequence will increase to substantial.  Probability: The probability of drawdown affecting groundwater users or rivers / wetlands is possible. The unknown interconnectedness between the upper and deep aquifers increases the possibility to probable (precautionary principle).  Significance: Significance: The significance is Moderate before and after mitigation.

Generation of Acid Mine Drainage

During operation the dewatering of the underground area will draw mineral-derived contaminants towards the working areas. When the mine is decommissioned it expected that the mining area will slowly be flooded. As the working areas and shafts are flooded, contaminants in the water will be mobilised and form acid mine water. This impact depends on the geology, aquifer characteristics and the interconnectivity of the various mines.

 Nature: Negative  Consequence: Substantial. The generation of AMD is expected to extend beyond the boundaries of the MRA over time. The duration of this impact is considered permanent.  Probability: The probability of AMD generation is probable (precautionary principle).  Significance: The significance is Moderate before and after the implementation of mitigation measures.

Project Name: ERPM Extension 2 Mine 18 Report Title: Impact Assessment Project number: 181020 Date: September 2019

Post- Significance Mitigation Activity Impact Phase Mitigation Rating Significance Rating Geohydrology  Seal off individual high yielding inflow zones intercepted  Pumping of water to surface to Loss of groundwater volumes in Construction during excavation. Moderate Moderate ensure dry working conditions. upper aquifer. Operation  Develop groundwater model to determine potential linkages between upper and deeper aquifers Construction  Appropriate water and hazardous chemical management  Seepage from WRD, topsoil Operation Contamination of groundwater. Moderate  Seal off individual high yielding inflow zones Low stockpile and mining area Decommissioning  Appropriately lining the stockpiles to limit seepage. Closure  Develop a numerical groundwater model within five years of operation (and updating it every five years) and planning discharge options for decant water at least 10 Closure years prior to closure  Generation of Acid Mine Drainage Contamination of groundwater. Moderate Moderate Post-closure  Ensure that a suitable water use is identified for the treated water  Managing the groundwater levels through pumping and treatment plants

Project Name: ERPM Extension 2 Mine 19 Report Title: Impact Assessment Project number: 181020 Date: September 2019 2.7. Socio-economic

Direct impacts

It is estimated that the mine will create at least 976 employment opportunities. The jobs will likely be unskilled and semi-skilled jobs.

 The potential impact is applicable in the construction and operation phases.  The potential impact can be enhanced through the implementation of the Skills Development Plan (SDP) and measures regarding the management of downscaling and retrenchment as detailed in the Social Labour Plan (SLP), prioritizing persons with requisite skills from the surrounding areas for employment opportunities, maximising the potential benefits to the local economy by ensuring that that local labour and service providers are utilized wherever possible throughout the various phases of the life of mine, following a predetermined recruitment process as outlined in the socio-economic impact assessment (SEIA) report, and implementing a Stakeholder Engagement Plan to allow communication of the recruitment process with community members.

Loss of employment / retrenchment during decommissioning or downscaling.

 The potential impact is applicable in the decommissioning phase.  The potential impact can be mitigated by implementing the measures in the SLP relating to employee education and upskilling to mitigate the impacts of unavoidable job losses. These include the establishment of future forums, providing information and counselling to retrenched employees to promote their absorption into the labour market, and offering a post-retrenchment programme to equip retrenchees with knowledge and skills.

A SDP will be developed and implemented to provide quality training to employees and increase competency levels, recognise prior learning and facilitate career progression. The SDP also includes Adult Education and Training (AET), which aims to ensure all employees are functionally literate and numerate. A total of 76 employees and 71 community members are set to benefit from AET in years 1-5. Portable Skills Training will also be provided, which will provide training related to industries outside of mining. Learnerships, internships and bursaries are also included in the SLP, and will result in further skills development.

 The potential impact is applicable in the construction and operation phases.  The potential impact can be enhanced through adherence to the SDP as detailed in the SLP, prioritizing training opportunities for people living in the area to be affected by the mine and the youth (18-34 years).

Increased opportunities for Small, Medium and Micro Enterprises (SMMEs) and stimulation of growth in the local area to provide goods and services to the mine and its employees.

 The potential impact is applicable in the construction and operation phases.  The potential impact can be enhanced by identifying suitable Historically Disadvantaged South African (HDSA) and locally based companies that currently, or in future, could provide local procurement to the mine, maximising the potential benefits to the local economy by ensuring that local labour and service providers are utilised wherever possible, implementing the Procurement Progression Plan detailed in the SLP, and encouraging employees that are not resident in the area to rent accommodation locally.

Project Name: ERPM Extension 2 Mine 20 Report Title: Impact Assessment Project number: 181020 Date: September 2019 Negative economic impact on agricultural smallholdings and businesses in the vicinity of the mine due to visual intrusion, dust and noise.

 The potential impact is applicable in the construction, operation and decommissioning phases.  The potential impact can be mitigated by implementing the mitigation measures listed for air quality, noise and blasting.

In-migration of job-seekers into the project area potentially resulting in the establishment or expansion of informal settlements, and associated increase in social ills (including crime), and decreased safety and security of residents in both the smallholding residential areas and the high-density areas surrounding the proposed development.

 The potential impact is applicable in the construction and operation phases.  The potential impact can be mitigated by providing employees with transportation into and out of the mine area by mine by taxi and encouraging employees to take advantage of the transport service being provided by the mine, maintaining consultation with the CoE regarding the monitoring of informal settlement creation, encouraging contractors to provide transport for their employees, and to discourage settlement within the ERPM Ext 2 area, ensuring that recruitment by the mine is not conducted at the mine gate so as to dissuade job seekers gathering at the mine gate, and ensuring that mine security patrols monitor the perimeter areas thereby providing an increased security presence.

Indirect impacts

Increased security as a result of cessation of illegal mining and increased security presence at the mine.

 The potential impact is applicable in the construction, operation and decommissioning phases.

Influx of job-seekers into existing residential areas or the formation of new informal settlements leading to pressure on existing infrastructure and services, nuisance and social ills.

 The potential impact is applicable in the construction and operation phases.  The potential impact cannot be mitigated to a lower significance. Contractors that are appointed by the mine should be encouraged to provide transport for the employees so as to avoid them setting up near the mine site. The CoE’s involvement in the Community Engagement and Security Forum (CESF) should be encouraged so that issues raised regarding service delivery are brought to their attention.

Nuisance and safety impacts associated with the establishment of tuck shops and canteens near the mine.

 The potential impact is applicable in the construction and operation phases.  The potential impact cannot be mitigated to a lower significance. The mine should consider identifying suitable taxi pick-up points at established bus / taxi stops or junctions.

Impact on property values adjacent to the project.

 The potential impact is applicable in the construction, operation and decommissioning phases.

Project Name: ERPM Extension 2 Mine 21 Report Title: Impact Assessment Project number: 181020 Date: September 2019  The potential impact can be mitigated by implementing all mitigation measures relating to noise, dust, blasting, visual intrusion and the influx of people into the area as detailed in the SEIA and EIA, establishing a CESF as detailed in the SEIA, and encouraging ongoing open communication between the mine and all stakeholders near the mine to improve relations.

Increase in insurance premiums for homeowners.

 The potential impact is applicable in the construction, operation and decommissioning phases.  The potential impact cannot be mitigated, however the mine should make all blasting monitoring reports available to any stakeholders for negotiations with insurance companies if necessary, and adhering to mitigation measures relating to in-migration.

Loss of sense of place due to influx of people, increased noise and dust, and a change in the visual landscape.

 The potential impact is applicable in the construction, operation and decommissioning phases.  The potential impact cannot be mitigated however mitigation measures pertaining to dust, blasting, noise, traffic and visual intrusion should be adhered to.

Employment and stimulation of the local economy

It is estimated that the mine will create at least 976 employment opportunities. The jobs will likely be unskilled and semi-skilled jobs. The mine will provide increased opportunities for Small, Medium and Micro Enterprises (SMMEs) and stimulation of growth in the local area to provide goods and services to the mine and its employees.

 Nature: Positive  Consequence: Severe. The extent of the benefits of employment and SMME opportunities will be felt beyond the boundaries of the MRA, possibly regionally, and will continue for the life of mine and possibly beyond.  Probability: The probability of employment benefits is definite.  Significance: The significance of the impact is considered to be High before and after mitigation.

Downscaling and retrenchment at decommissioning and closure

Once the mine closes, there will be a loss of employment.

 Nature: Negative  Consequence: Severe. The extent of the negative impacts of retrenchment will be felt by employees and their families, possibly beyond the MRA after closure.  Probability: The probability of the negative impacts is considered to be definite.  Significance: The significance of the impact is considered to be High prior to mitigation. With the implementation of mitigation, the consequence can be reduced to Substantial, reducing the significance to Moderate.

In-migration of job-seekers

In-migration of job-seekers into the project area could potentially result in the establishment or expansion of informal settlements, and associated increase in social ills (including crime), and decreased safety and security of residents in both the smallholding residential areas and the high-density areas surrounding the

Project Name: ERPM Extension 2 Mine 22 Report Title: Impact Assessment Project number: 181020 Date: September 2019 proposed development.

 Nature: Negative  Consequence: Substantial. The extent of in-migration is unlikely to extend beyond the boundaries of the SDAs but is likely to be permanent. It is anticipated that the predicted associated impacts related to informal settlements and social ills will manifest along with in-migration.  Probability: With the probability of in-migration being unknown, a probability of probable has been selected (precautionary principle).  Significance: The significance of the impact is considered to be High before and after mitigation.

Project Name: ERPM Extension 2 Mine 23 Report Title: Impact Assessment Project number: 181020 Date: September 2019 Post- Significance Mitigation Activity Impact Phase Mitigation Rating Significance Rating  Prioritize persons with requisite skills from the surrounding areas for employment opportunities,  Maximising the potential benefits to the local economy by ensuring that that local labour and service providers are Employment utilized wherever possible Increased opportunities for  Implement a Stakeholder Engagement Plan to allow SMMEs and stimulation of the Construction High communication of the recruitment process with local economy High Positive Operation Positive community members. Skills development for  Identify suitable HDSA and locally based companies to employees and community provide local procurement to the mine, members  Employment opportunities and  Implement the Procurement Progression Plan detailed in Implementation of the SDP the SLP,  Encourage employees that are not resident in the area to rent accommodation locally.  Provide employees with transportation into and out of the mine area Establishment or expansion of  Maintain consultation with the CoE regarding the informal settlements, and Construction monitoring of informal settlement creation, High High associated increase in social ills Operation  Encourage contractors to provide transport for their (including crime). employees, ensure that recruitment is not conducted at the mine gate  Ensure that mine security patrols the perimeter areas  Implement the mitigation measures listed for air quality, Negative economic impact on noise, blasting, visual intrusion, and the influx of job- agricultural smallholdings within seekers the vicinity of the mine Construction  Establish a CESF Reduction in property values  Operation of the mine Operation Moderate  Ongoing open communication between the mine and all Low adjacent to the project Closure stakeholders near the mine. Loss of sense of place  Make all blasting monitoring reports available to any Increase in insurance premiums stakeholders for negotiations with insurance companies if for homeowners necessary  Implement measures in the SLP relating to employee  Decommissioning or downscaling Decommissioning education and upskilling, including future forums, and Retrenchment High Moderate at the mine Closure offering a post-retrenchment programme to equip retrenchees with knowledge and skills.  Establishment of tuck shops and Construction canteens near the mine and along Nuisance and safety impacts Low  None Low Operation the transport route  Increased security presence at Construction Cessation of illegal mining Low Positive  None. Low Positive the mine Operation

Project Name: ERPM Extension 2 Mine 24 Report Title: Impact Assessment Project number: 181020 Date: September 2019 2.8. Visual Aesthetics

The proposed infrastructure and activities will result in visual intrusion. Residents living adjacent to the area would be the most affected receptors due to the unobstructed nature of the surrounding environment and the lack of screening vegetation, particularly at Windmill Shaft SDA.

Construction and operation activities as well as dismantling and removal of infrastructure may result in the creation of nuisance dust which is also a visual intrusion.

 The potential impact is applicable in the construction, operation and decommissioning phases.  The potential impact can be mitigated by avoiding the unnecessary removal of trees along the boundaries of the SDAs, planting indigenous fast-growing trees along the mine boundary, avoiding the use of highly reflective material, and implementing the mitigation measures related to dust generation.

Night-time lighting will be required at the mine as it will be operating for 24 hours. If not effectively managed, night lighting may have a negative impact on the visual aesthetics of the area.

 The potential impact is applicable during the operation phase.  The potential impact can be mitigated by avoiding unnecessary illumination, providing lights with cover fittings that limit lateral and upwards “light spill” and positioning lights to shine towards the intended areas of illumination rather than using floodlights, making use of Low Pressure Sodium lighting or other types of low impact lighting, using low wattage bulbs to further reduce the impact, and using motion sensor activated lighting instead of lights that illuminate continuously.

Rehabilitation activities will result in the restoration of the visual character.

 The potential impact is applicable during the decommissioning and closure phases.

The waste rock dump will remain on site permanently at the Windmill Shaft resulting in a permanent change to the visual character of the area. Unsuccessful rehabilitation may also permanently change the visual character of the area

 The potential impact occurs during the Construction phase.  The potential impact can be mitigated by shaping the WRD to achieve deposit stabilisation and to blend with the natural topography, and establishing vegetation on the crests of the dump.

The shaft headgears will be approximately 50 m high and therefore visible to the surrounding area. The WRD is also to remain on-site permanently at the Windmill Shaft SDA. These will result in a change to the visual character of the landscape. Lighting at night may fundamentally change the appearance of the area at night and may be a nuisance to people near to the mine.

 Nature: Negative  Consequence: Moderate. The impact of visual intrusion is considered to be a nuisance (largely the night time lighting) but is not expected to extend beyond the local area although the head gears may be visible from further away. The visual intrusion impact will be permanent but have a small footprint.  Probability: The probability of visual intrusion is definite.

Project Name: ERPM Extension 2 Mine 25 Report Title: Impact Assessment Project number: 181020 Date: September 2019  Significance: The significance is Moderate prior to mitigation. With the implementation of mitigation, the consequence can be reduced to Slight, reducing the significance to Low.

Project Name: ERPM Extension 2 Mine 26 Report Title: Impact Assessment Project number: 181020 Date: September 2019 Post- Significance Mitigation Activity Impact Phase Mitigation Rating Significance Rating  Implementing the mitigation measures related to dust generation (see air quality).  Avoid the unnecessary removal of trees along the boundaries of Construction  the SDAs,  Site activities, including Operation  Plant indigenous fast-growing trees along the mine headgears and WRD Visual intrusion, nuisance Moderate Low Decommissioning boundary  Night time lighting Closure  Avoid the use of highly reflective material  Avoid unnecessary illumination, limit “light spill”  Shape the WRD to achieve stabilisation and to blend in with the natural topography; establish vegetation on the crests Beneficial to the overall visual Decommissioning  Removal of the shaft headgears quality of the surrounding Low Positive None Low Positive Closure landscape.  Rehabilitation may be Permanent change in the visual  Re-implement rehabilitation until closure objectives have Closure Low Low unsuccessful or ineffective character of the area been met.

Project Name: ERPM Extension 2 Mine 27 Report Title: Impact Assessment Project number: 181020 Date: September 2019 2.9. Terrestrial Ecology

Site activities may result in the loss of floral habitat and species diversity in the nearby grassland systems.

 The potential impact is expected to occur in the construction, operation and decommissioning phases.

Site activities may result in the loss of floral species of conservation concern (SCC).

 The potential impact is expected to occur in the construction, operation and decommissioning phases.

The potential impacts described above can be mitigated by demarcating no-go zones beyond the original development area, prohibiting the hunting / trapping or collection of flora and firewood, implementing an alien invasive species plan, storing excavated topsoil with associated native vegetation debris, and developing a floral rescue and relocation plan

Site activities may result in the loss of habitat for fauna, species diversity and species of conservation concern (SCC) at the SDAs (Excluding Eragrostis chloromelas Grassland habitat unit)

 The potential impact is expected to occur in the construction, operation and decommissioning phases. However, most habitat and species loss will be undertaken during construction.

Site activities may result in the loss of habitat for fauna, species diversity and SCC in the degraded Eragrostis chloromelas Grassland habitat unit which supports Mystromys albicaudatus (White-tailed Mouse, EN) and Atelerix frontalis (Southern African Hedgehog, NT).

 The potential impact is expected to occur in the construction, operation and closure phases.

The potential impacts can be mitigated by demarcating no-go zones beyond the original development area, prohibiting the hunting / trapping or collection of fauna / flora and firewood, implementing an alien invasive species plan, storing excavated topsoil with associated native vegetation debris, and developing a faunal rescue and relocation strategy.

Flora

Clearing during construction will lead to the direct loss of individual plants and grassland habitat. There are individuals of taxa of conservation concern in the area that may be lost however, these are not considered rare or endangered. It is possible that invasive species will flourish in the disturbed areas around the SDAs leading to a further loss of habitat. The influx of people to the area may collect wood, disturbing trees and other woody plants.

 Nature: Negative  Consequence: Moderate. The loss of vegetation and habitat for species of conservation concern will be restricted to the SDAs but the impact will be felt permanently, and the collection of firewood may continue throughout the life of mine.  Probability: The probability of the loss of vegetation is definite.  Significance: The significance is Moderate prior to mitigation. With the implementation of mitigation, the probability can be reduced to Probable, reducing the significance to Low.

Project Name: ERPM Extension 2 Mine 28 Report Title: Impact Assessment Project number: 181020 Date: September 2019 Fauna

Loss of fauna and faunal habitat is expected to occur during the construction phase. Although many individual animals are able to move away from construction areas, fossorial animals may be destroyed in their burrows. The SDAs do contain habitat which may support taxa of concern.

 Nature: Negative  Consequence: Substantial. The loss of certain fauna would be restricted to the site (most animals would leave) and the impact would be felt throughout the life of mine but possibly would cease at closure when animals may move back into the area.  Probability: The probability of a loss of animal species is possible.  Significance: The significance is Moderate prior to mitigation. With the implementation of mitigation, the consequence can be reduced to Moderate, reducing the significance to Low.

Project Name: ERPM Extension 2 Mine 29 Report Title: Impact Assessment Project number: 181020 Date: September 2019 Post- Significance Mitigation Activity Impact Phase Mitigation Rating Significance Rating  Demarcate no-go zones beyond the original development Loss of floral habitat integrity area  Site activities, especially clearing and species diversity including Construction  Prohibit the collection of flora and firewood vegetation. species of conservation concern Operation Moderate  Implement an alien invasive species plan Low  Ineffective rehabilitation Loss of habitat for fauna, Closure  Developing a floral rescue and relocation plan species diversity and SCC  Re-implement rehabilitation until closure objectives have been met.

Project Name: ERPM Extension 2 Mine 30 Report Title: Impact Assessment Project number: 181020 Date: September 2019 2.10. Aquatic Ecology and Wetlands

Site preparation and construction may result in loss of habitat for wetland species.

 The potential impact is expected to occur in the construction phase.  The potential impact can be mitigated by first constructing clean and dirty water separation systems, limiting vegetation clearing and soil disturbance, erosion protection, demarcating no-go areas at least 100m from the delineated edge of wetlands (no activities or stockpiles), limiting stockpile height to 2m, undertaking concrete mixing in bunded areas, and implementing dust suppression.

Loss of catchment yield from stormwater containment may result in loss of wetland habitat.

 The potential impact is expected to occur in the construction and operation phases.  The potential impact can be mitigated by ensuring that clean water captured in the clean water system is returned to the surrounding water systems.

The sinking of the Windmill Shaft may result in the creation of a cone of depression which would decrease the volume of water in wetlands.

 The potential impact is expected to occur in the construction phase.  The potential impact can be mitigated by monitoring groundwater levels and stream flow volumes and managing dewatering accordingly as well as sealing off individual high yielding inflow zones intercepted during excavation.

Site activities, including blasting, leaching from the WRD, and failure of PCD, could result in contamination of the nearby surface water / wetlands. Activities may also lead to soil erosion and subsequent sedimentation of the nearby watercourses.

 The potential impact is expected to occur throughout the Life of Mine.  The potential impact can be mitigated by keeping clean and dirty water areas separate at all times, sizing the dirty water system adequately, ensuring that facilities are lined as required, maintaining stormwater systems on site, and installing erosion protection measures.

Discharge of potentially contaminated water due to the sinking and operation of the Windmill and Witpoortje Shafts.

 The potential impact is expected to occur in the construction and operation phases.  The potential impact can be mitigated by treating water before discharge and reducing ingress into the mine where possible.

Rehabilitation may result in temporary disruption to down gradient wetland areas and soils.

 The potential impact is expected to occur in the closure phase.  The potential impact can be mitigated by implementing a site-specific rehabilitation plan, ensuring that invasive plants are removed by hand and prohibiting machinery in the wetlands.

Post-closure decant of contaminated water will have negative impacts on the natural ecosystem.

 The potential impact is applicable in the post-closure phase.

Project Name: ERPM Extension 2 Mine 31 Report Title: Impact Assessment Project number: 181020 Date: September 2019  This impact can be mitigated by managing the groundwater levels through pumping and treatment plants. This would limit the scale and the magnitude of the impact however, the impact would remain permanent / definite.

Aquatic ecosystems may be affected due to direct disturbance or through contaminated (chemical and silt) runoff entering the watercourses.

 Nature: Negative  Consequence: Moderate. The possible contamination of aquatic ecosystems will be local and will occur intermittently throughout the life of the mine.  Probability: The probability of contamination occurring is possible.  Significance: The significance is Low prior to and with mitigation.

Increase in surface water flow

The quantity of water in the catchment (contributing to stream flow) may increase as a result of discharge of excess mine water.

 Nature: Negative  Consequence: Substantial. The increase of water in the catchment is likely to be felt locally and possibly beyond, during construction, and potentially beyond, should decant occur.  Probability: The probability is currently unknown and therefore considered probable (precautionary principle).  Significance: The significance is Moderate prior to and with mitigation.

Project Name: ERPM Extension 2 Mine 32 Report Title: Impact Assessment Project number: 181020 Date: September 2019 Post- Significance Mitigation Activity Impact Phase Mitigation Rating Significance Rating  Construct clean and dirty water separation systems, erosion protection Loss of habitat for wetland Construction  Limit vegetation clearing and soil disturbance species Operation  Demarcate no-go areas at least 100m from the delineated  Site activities Moderate Low Contamination of the nearby Decommissioning edge of wetlands (no activities or stockpiles), l surface water / wetlands Closure  Limit stockpile height to 2m,  Undertake concrete mixing in bunded areas  Implement dust suppression.

Project Name: ERPM Extension 2 Mine 33 Report Title: Impact Assessment Project number: 181020 Date: September 2019 2.11. Traffic

Increased vehicle trips generated by activities at the mine are expected to result in traffic congestion and unsafe driving conditions on the road network.

 The potential impact is expected to occur in the construction and operational phases.  Mitigation measures include making public transport available for contractors, improving lane capacity to impacted intersections, and implementing signalisation of access intersection (i.e. Barry Marais Rd/Road A).

Increases in heavy vehicle volumes during construction may result in the deterioration of pavement quality and subsequent unsafe driving conditions.

 The potential impact is expected to occur in the construction and operational phases.  The potential impacts can be mitigated by not overloading trucks, and ensuring that wheel/axle loading are in accordance to legislation.

The construction and operation of the mine will increase the volume of traffic in the surrounding area. Apart from being a nuisance to people living in the area, the increased volume may lead to a decrease in road safety and a deterioration of the road surface.

 Nature: Negative  Consequence: Moderate. The nuisance impact of additional traffic will be local and limited to the road network used to access the mine. The impact will occur throughout the life of the mine.  Probability: The probability of nuisance traffic and potentially additional road safety concerns is probable.  Significance: The significance of the impact is considered to be Low before and after mitigation.

Project Name: ERPM Extension 2 Mine 34 Report Title: Impact Assessment Project number: 181020 Date: September 2019 Post- Significance Mitigation Activity Impact Phase Mitigation Rating Significance Rating  Make public transport available Traffic congestion and  Improve lane capacity to impacted intersections  Additional vehicle trips potentially unsafe driving Low Low Construction  Implement signalisation of access intersection (i.e. Barry conditions Operation Marais Rd/Road A). Deterioration in pavement Decommissioning  Increase in heavy vehicle volumes  Not overloading trucks, and ensuring that wheel/axle quality resulting in unsafe driving Low Low during construction loading are in accordance to legislation. conditions

Project Name: ERPM Extension 2 Mine 35 Report Title: Impact Assessment Project number: 181020 Date: September 2019 2.12. Cumulative Impacts

Cumulative impacts have been commented on in terms of their qualitative impact and impact significance ratings have not been assigned

Soil and land use

Although a number of mining relative activities are occurring in the vicinity of the project, no cumulative soil related impacts were identified.

Geohydrology

The different underground mines in the area (existing and proposed) may be interconnected thereby influencing the geohydrology and the flow of groundwater within and across basins. This may have a cumulative impact on closure planning and assessing the potential decant of the groundwater.

It is not possible to currently identify decant positions with the level of information that is available.

Socio-economic

The influx of job-seekers around the project area would place pressure on local infrastructure and services and may result in the establishment of informal settlements in the area, which may introduce a suite of social ills, including an increase in crime around the mine area.

Aquatic ecology and Wetlands

A CVB wetland was identified within the vicinity of the Witpoortje Vent Shaft, and HSS wetland identified within the vicinity of the Windmill Shaft. Both wetlands have been impacted on by historical and current mining activities within the greater catchment. Mining activities and poor stormwater management at the proposed mine may result in further degradation of the wetlands.

Terrestrial ecology

The habitat units associated with both shafts have been subjected to historic ground clearing activities and have experienced the establishment of alien invasive plants. Mining activities may result in the further loss of indigenous vegetation and habitats, and the proliferation of AIPs.

Traffic and road condition

The transport route is mainly damaged with potholes and deep rutting from existing traffic use. Increased traffic on the main road, particularly heavy vehicles, may result in further damage to existing roads.

Visual

The cumulative impact assessment considers the project within the context of other similar land uses, in the local study area and greater regional context. There are various other operational and historical mining features within sighting distance of the proposed SDAs. The cumulative visual impact resulting from additional changes to the landscape caused by the proposed development, in combination with existing developments, is therefore considered to be medium as the sense of place of the area is already one of mixed residential, agriculture and mining

Project Name: ERPM Extension 2 Mine 36 Report Title: Impact Assessment Project number: 181020 Date: September 2019

APPENDIX 21 CLOSURE REPORTS

ERPM EXTENSION AREA 1 (PTY) LTD

DRAFT FINAL REHABILITATION DECOMMISSIONING AND CLOSURE PLAN FOR THE PROPOSED ERPM EXTENSION 2 MINE, PREPARED IN TERMS OF THE NEMA EIA REGULATIONS (GN982 OF 2014 AS AMENDED) AND THE NEMA FINANCIAL PROVISIONING REGULATIONS (CURRENT, GN1147 OF 2015 AND PROPOSED, GN667 OF 2019)

SEPTEMBER 2019

Prepared for:

ERPM Extension Area 1 (Pty) Ltd Unit 206 Alto Level House 4 Fir Drive Northcliff 2195

TABLE OF CONTENTS

1. INTRODUCTION AND BACKGROUND ...... 5 1.1 Legislative Requirements ...... 6 1.2 Details and expertise of the EAP ...... 12 1.3 Details of the holder ...... 12 2. PROJECT DESCRIPTION ...... 13 2.1 Construction and Operation ...... 13 2.2 Decommissioning and Rehabilitation ...... 15 2.3 Mineral to be mined ...... 15 2.4 Mining Method ...... 15 3. ENVIRONMENTAL AND SOCIAL CONTEXT ...... 16 3.1 Air Quality ...... 16 3.2 Water Resources ...... 16 3.3 Soil, Land Cover and Land Use ...... 19 3.4 Ecology ...... 22 3.5 Noise Character ...... 23 3.6 Socio-economic ...... 23 3.7 Other mining activities nearby ...... 25 4. CLOSURE RELATED ISSUES ...... 26 4.1 Future Public Engagement ...... 27 5. CLOSURE VISION, OBJECTIVES AND TARGETS ...... 28 5.1 Sustainable end state/ Final land use ...... 28 5.2 Closure Alternatives ...... 28 6. MINE PLAN SCHEDULE INCLUDING CLOSURE AND POST CLOSURE PERIOD ...... 30 7. ENVIRONMENTAL RISK ASSESSMENT...... 32 7.1 Identification of receptors sensitive to closure ...... 32 7.2 Risk Assessment ...... 32 8. CLOSURE STRATEGY ...... 37 8.1 General Measures ...... 37 8.2 Underground Workings and Shafts ...... 40 8.3 Hazardous Waste ...... 40 8.4 Roads ...... 40 8.5 Waste Rock Dump ...... 40 8.6 Groundwater ...... 41 8.7 Surface water and watercourses ...... 42 8.8 Socio-Economic Structure ...... 42 9. RE-ASSESSMENT OF THE CLOSURE RISKS AFTER THE APPLICATION OF THE CLOSURE ACTIONS ...... 43 9.1 Outcomes ...... 44 10. ORGANISATIONAL CAPACITY ...... 45 10.1 Responsibilities ...... 45 10.2 Training ...... 45 11. MONITORING AND REPORTING ...... 46 11.1 Closure Monitoring ...... 46 11.2 Liability Assessment ...... 49 11.3 Additional Legislative Requirements ...... 49 12. QUANTUM FOR CLOSURE-RELATED FINANCIAL PROVISION ...... 50 13. GAPS AND ACTION PLAN ...... 56

Project Name: ERPM Extension 2 Mine ii Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

14. CONCLUSION ...... 57

FIGURES

Figure 1: Windmill Shaft SDA infrastructure layout ...... 14 Figure 2: Witpoortje Vent Shaft SDA infrastructure layout ...... 14 Figure 3: Catchment and water resources ...... 17 Figure 4: Land Cover map for the proposed project area ...... 20 Figure 5: Proposed project relative to the GPEMF zoning ...... 20 Figure 6: Existing infrastructure (including historical mining infrastructure) surrounding the proposed project area ..... 21 Figure 7: Habitat units within the project area ...... 23 Figure 8: Infrastructure to remain post-closure ...... 29 Figure 9: High level final end land use plan for the ERPM Ext 2 Mine ...... 29

TABLES

Table 1: Statistical Profile of Ward 105, 99, 82 and 74 ...... 24 Table 2: Closure related issues ...... 27 Table 3: Mine Plan Schedule ...... 31 Table 4: Closure-related risks and sensitive receptors ...... 32 Table 5: Assessment of the potential closure related risks associated with the proposed ERPM Ext 2 Mine ...... 34 Table 6: Closure and post closure monitoring ...... 46 Table 7: Relinquishment criteria for the closure of ERPM Ext 2 Mine ...... 48 Table 8: Total Quantum for Closure Related Financial Provision for the proposed ERPM Ext 2 Mine ...... 52 Table 9: Costs to be set aside for final rehabilitation, decommissioning and closure associated with the anticipated disturbance for the first year of operations at the proposed ERPM Ext 2 Mine ...... 54 Table 10: Costs to be set aside for residual and latent impacts associated with the anticipated disturbance for the first year of operations at the proposed ERPM Ext 2 Mine ...... 55 Table 11: Existing gaps within this final closure plan and proposed action plan ...... 56

ACRONYMS

AIP Alien and Invasive Plant BLM Bureau of Land Management CBA Critical Biodiversity Area CoE City of Ekurhuleni DME Department of Minerals and Energy DMR Department of Mineral Resources DWS Department of Water and Sanitation EA Environmental Authorisation ECO Environmental Control Officer EIA Environmental Impact Assessment EIAR Environmental Impact Assessment Report EMPr Environmental Management Programme ERPM East Rand Proprietary Mines Limited ESA Ecological Support Areas FET Further Education and Training FEV Far East Vertical

Project Name: ERPM Extension 2 Mine iii Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

FP Financial Provisioning GIS Geographical Information Systems GPEMF Gauteng Provincial Environmental Management Framework IAPs Interested and Affected Parties IDP Integrated Development Plan LED Local Economic Development LOM Life of Mine mBC Metres below collar MPRDA Mineral and Petroleum Resources Development Act No. 28 of 2002 MRA Mining Right Area NEMA National Environmental Management Act, No. 107 of 1998 NEMWA National Environmental Management: Waste Act (No. 59 of 2008) NWA National Water Act, (No. 36 of 1998) PCD Pollution Control Dam PES Present Ecological State Equivalent SDA Surface Development Area SAHRIS South African Heritage Resources Information System SANBI South African National Biodiversity Institute SANS South African National Standards SLP Social and Labour Plan SAWQG South African Water Quality Guidelines TSF Tailings Storage Facility WRD Waste Rock Dump WUL Water Use Licence

Project Name: ERPM Extension 2 Mine iv Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

1. INTRODUCTION AND BACKGROUND

ERPM Extension Area 1 (Pty) Ltd (ERPM Ext 1), is a subsidiary of East Rand Proprietary Mines Limited (ERPM), and is an underground mining operation. ERPM’s operations were established more than 100 years ago on the Witwatersrand basin, 10 km East of Johannesburg. ERPM owned two contiguous mining rights - GP151MR and GP150MR. While GP151MR allows for both underground and surface activities, GP150MR only grants for underground mining. These mining rights have since been sold to ERPM Ext 1. In addition, ERPM Ext 1 holds a prospecting right (GP243PR) which it intends to convert into a Mining Right.

GP243PR is situated to the south of and is adjacent to GP150MR. ERPM Ext 1 plans to consolidate the underground resources of GP243PR (referred to as Extension Area 2 [ERPM Ext 2]) with those of GP150MR and GP151MR. An additional twin shaft (which includes an access and vent shaft), termed Windmill Shaft, is proposed to be constructed on Portion 5 of Witpoortje 117 IR. This will allow access to the underground operations of the Ext 2 area and will include the development of the associated head gear. The existing Witpoortje Vent Shaft - located on Portion 19 of Witpoortje- will also be re-furbished and re-opened for use.

ERPM Ext 1 has appointed Prime Resources (Pty) Ltd to compile this Final Rehabilitation, Decommissioning and Closure Plan and to calculate the financial provision in line with the requirements of GN1147 of 2015 and GN667 of 2019 for the proposed ERPM Ext 2 Mine.

The objective of the Final Rehabilitation, Decommissioning and Closure Plan is to:

 Determine, review and revise as required, a sustainable end state for the mining operation, which includes a sustainable and achievable end state of the land, as well as sustainable post-closure management and monitoring measures;  Ensure early-, and regular, consultation throughout the LoM on closure objectives and the sustainable end state objectives;  Predict and model the mining activities, expected environmental impacts, the mineral extraction schedule and by applying and explaining a risk-based approach and hierarchy linked to closure activities throughout the LoM;  Determine, review and revise the rehabilitation and remediation activities related to the sustainable end state of the environment at closure and post-closure;  Determine an overall cost for implementing the avoidance, management and rehabilitation activities;  Determine the annual budget and schedule for the implementation of the avoidance, management and rehabilitation activities;  Audit and report on the implementation of the plan; and  Identity knowledge gaps and propose actions to actively address the identified gaps through among others, applicable research.

As ERPM Ext 2 is a new mine that has not yet commenced with operations, this is the first draft of the Final Rehabilitation, Decommissioning and Closure Plan and no updates or amendments to this plan have been made. Concurrent rehabilitation or remediation activities have also not yet been implemented and an Annual Rehabilitation Plan has thus not yet been compiled. Once the proposed project commences, an Annual Rehabilitation Plan must be compiled and updated annually. The Annual Rehabilitation Plan must use the findings of this Final Rehabilitation, Decommissioning and Closure Plan and must focus on annual rehabilitation and mitigation.

Project Name: ERPM Extension 2 Mine 5 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

The following data was obtained from ERPM Ext 1 and reviewed for context with regard to the closure commitments, liabilities and financial provision for ERPM Ext 2:

 The following specialist studies were utilised to characterize the baseline environment and identify the potential risks pertaining to closure: o Air Quality and Noise (IMA Trader 20 cc, 2019) o Blasting (Blast Management and Consulting (Pty) Ltd, 2019) o Soil and Land use, Socio-economic and Visual Aesthetics (Prime Resources (Pty) Ltd, 2019) o Archaeology and Cultural Heritage (Archaetnos Culture & Cultural Resource Consultants, 2019) o Palaeontology (Prof Marion Bamford - University of the Witwatersrand, 2019) o Groundwater / Geohydrology (Future Flow Groundwater & Project Management Solutions, 2019) o Hydrology (African Environmental Development, 2019) o Aquatic Ecology and Wetlands and Hydropedology (Scientific Aquatic Services, 2019) o Watercourse Rehabilitation and Management Plan (Scientific Aquatic Services, 2019) o Terrestrial Ecology (Scientific Terrestrial Services, 2019) o Traffic (Merchelle’s Collective (Pty) Ltd, 2019)  EIA and EMPr;  Mining Work Programme; and  Social and Labour Plan.

1.1 Legislative Requirements

1.1.1 NEMA and the EIA Regulations

The National Environmental Management Act 107 of 1998 (NEMA) defines mine rehabilitation, closure cost assessment and closure planning. Section 24P of NEMA deals with financial provision for remediation of environmental damage and Section 24P(3) states that every holder must annually assess his or her environmental liability and must increase his or her financial provision to the satisfaction of the Minister for Mineral Resources. Section 24R(1) states that every holder of an old order right or owner of works remain responsible for any environmental liability, pollution or ecological degradation, the management and sustainable closure thereof, notwithstanding the issuing of a closure certificate. Section 24R(3) states that every holder must plan, manage and implement procedures and requirements in respect of the closure of a mine as may be prescribed.

Appendix 5 of the EIA Regulations (GN982 of 2014 as amended) provides the prescribed content to be included in the closure plan.

1.1.2 Current Financial Provisioning Regulations (GN1147 of 2015)

The National Environmental Management Act, No. 107 of 1998 (NEMA) Financial Provisioning Regulations (GN1147 of 2015), published in accordance with NEMA Section 24P, officially came into effect on 20 November 2015, with amendments, GN1314 in October 2016, GN452 in April 2018 and GN991 in September 2018.

Project Name: ERPM Extension 2 Mine 6 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

GN991 included the extension of the transitional period whereby a holder, or holder of a right or permit who applied for such right or permit prior to 20 November 2015, regardless when the right was obtained:

 must by no later than 19 February 2020 comply with these Regulations (GN1147); and  shall, until 19 February 2020, be regarded as having complied with the provisions of these Regulations if such holder has complied with the provisions and arrangements regarding financial provisioning, approved as part of the right issued in terms of the Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002).

ERPM Ext 1 is therefore required to re-evaluate the financial aspects of rehabilitation and closure in terms of GN1147 by the target date of February 2020. GN1147 require a change in the methodology in which the financial aspects of rehabilitation and closure are calculated and reported. In accordance with Section 11 of the Financial Provisioning Regulations the following three reports need to be compiled:

 Annual Rehabilitation Plan;  Final Rehabilitation, Decommissioning and Closure Plan; and  Environmental Risk Assessment Report.

This report serves to fulfil the requirements for a draft Final Rehabilitation, Decommissioning and Closure Plan as per Section 11(1)b, when read in conjunction with Appendix 4 of the current Financial Provisioning Regulations.

1.1.3 Proposed NEMA Financial Provisioning Regulations (GN667 of 2019)

The proposed Financial Provisioning Regulations were published on 17 May 2019 but have not yet been brought into law. The proposed Regulations facilitate progressive rehabilitation, with the implementation of agreed closure objectives to achieve a sustainable end state.

This document serves to meet the requirements in terms of Section 6(2)(b), when read in conjunction with Appendix 2 of GN667 of 2019, where the final rehabilitation, decommissioning and mine closure plan must annually check that the planned closure objectives are in line with sustainably principles and will achieve an agreed sustainable end state. The calculation of costs associated with the final rehabilitation, decommissioning and mine closure must be based on the rehabilitation and environmental management of the full extent of the area disturbed and must be expressed as an annual figure based on the rate of extraction and extent of current disturbance.

This Final Rehabilitation, Decommissioning and Closure Plan has been prepared in accordance with the requirements of Appendix 5 of GN982 as amended, Appendix 4 of GN1147 and Appendix 2 of GN667 as follows

App 5 EIA Regulations App 4 (GN1147 of 2015)/ [Relevant (GN982 as amended) App 2 (GN667 of 2019) section of Minimum Content of a Closure Minimum Content of a Final Rehabilitation, this plan] Plan Decommissioning and Closure Plan (1)(f)(iii) comply with any prescribed environmental management standards or practices; and [1.1] (iv) comply with any applicable provisions of the Act regarding closure (1)(a)Details of— (3)(1) Details of─ [1.2]

Project Name: ERPM Extension 2 Mine 7 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

App 5 EIA Regulations App 4 (GN1147 of 2015)/ [Relevant (GN982 as amended) App 2 (GN667 of 2019) section of Minimum Content of a Closure Minimum Content of a Final Rehabilitation, this plan] Plan Decommissioning and Closure Plan (i) the EAP who prepared the closure (1) the person or persons that prepared the plan; [1.3] plan; and (2) the professional registrations and experience of the (ii) the expertise of that EAP person or persons who prepared the plan; (3) the applicant or holder, including but not limited to the name, physical address, postal address and contact details. (3)(2) The context of the project, including but not limited to─ (1) minerals to be or being mined, mining method, area already mined or to be mined, in the case of a Greenfields [2] site, the backlog in rehabilitation if relevant, annual extraction rate, overall extraction rates, life of mine and any material information and issues that have guided the development of the plan (GN667 only); (3)(2)(2) an overview of- (2)(1) the environmental context, including but not limited to air quality, quantity and quality of surface and groundwater, land soils, terrestrial and aquatic biodiversity; (2)(2) the social context that may influence closure [3] activities and post-mining land use or be influenced by closure activities and post-mining land use: and (2)(3) other mining activities within a 20 km radius of the mining area (GN667 only). (1)(i) details of all public participation processes conducted in terms of regulation 41 of the Regulations, including— (i) copies of any representations and comments received from registered interested and affected parties; (ii) a summary of comments received from, and a summary of issues raised by registered interested and affected parties, the date of receipt (3)(3) stakeholder issues and comments that have of these comments and the response [3.7] informed the plan of the EAP to those comments; (iii) the minutes of any meetings held by the EAP with interested and affected parties and other role players which record the views of the participants; (iv) where applicable, an indication of the amendments made to the plan as a result of public participation processes conducted in terms of regulation 41 of these Regulation (3)(4) the mining plan and schedule for the full approved operations, including - (1) appropriate description of the mine plan: (2) drawings and figures to indicate how the mine [2.1] develops; [6] (3) what areas are disturbed and will be disturbed; and (4) how infrastructure and structures (including ponds, residue stockpiles etc.) develop during operations; (3)(5) details of the preferred sustainable end state of the [1.1] operations including – [11.3]

Project Name: ERPM Extension 2 Mine 8 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

App 5 EIA Regulations App 4 (GN1147 of 2015)/ [Relevant (GN982 as amended) App 2 (GN667 of 2019) section of Minimum Content of a Closure Minimum Content of a Final Rehabilitation, this plan] Plan Decommissioning and Closure Plan (1) the legal and governance framework and interpretation of these requirements for the closure design principles; (GN667 only) (2) a description of the sustainable end state, objectives and targets, which objectives and targets must reflect the local environmental and socio-economic context, the [5] regulatory and corporate requirements and stakeholder expectations; (GN667 only) (3) a description and evaluation of alternative closure and past closure options where these exist, that are practical [5.2] within the socio economic context; and (4) environmental opportunities and constraints in which [3] the operation is located (GN667 only). (1)(e) information on any proposed (3)(6) Findings of an environmental risk assessment and avoidance, management and modelling process leading to the most appropriate closure mitigation measures that will be strategy, including: taken to address the environmental (1) a description of the risk assessment methodology [7.2.1] impacts resulting from the including risk identification and quantification, to be undertaking of the closure activity undertaken for all areas of infrastructure or activity or aspects for which an applicant and holder has a (1)(f) a description of the manner in responsibility to mitigate an impact or risk at closure; which it intends to— (2) an identification receptors most sensitive to potential (i) modify, remedy, control or stop risks and the monitoring of such risks with a view to [7.1] any action, activity or process which informing rehabilitation and remediation activities; causes pollution or environmental (3) an identification and modelling of conceptual closure degradation during closure; strategies to avoid, manage and mitigate the impacts and [0] (ii)remedy the cause of pollution or risks; degradation and migration of pollutants during closure; (4) a reassessment of the risks to determine whether, after the implementation of the closure strategy, the (1)(h) the process for managing any residual risk has been avoided and / or how it has resulted [9] environmental damage, pollution, in avoidance, rehabilitation and management of impacts pumping and treatment of and whether this is acceptable to the mining operation extraneous water or ecological and stakeholders; degradation as a result of closure Initial plan, no (5) explanation of changes to the risk assessment results, updates or as applicable in annual updates to the plan; and amendments as yet (1)(b) closure objectives (6) design principles for achieving the closure objectives, including the proposed final sustainable end state which is appropriate, feasible and possible to implement and which [5] meets the principles of sustainable development. Including - (1) descriptions of appropriate and feasible final post- mining land use for the project area; [5.1] (2) map of the proposed final sustainable end state of the land; (3) a motivation for the preferred closure option within the [5] context of the risks and impacts that are being mitigated; (4) a definition and motivation of the closure and post closure period, taking cognisance of the probable need to [6] implement post closure monitoring and maintenance for a [11] period sufficient to demonstrate that the risk threshold criteria have been achieved; and

Project Name: ERPM Extension 2 Mine 9 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

App 5 EIA Regulations App 4 (GN1147 of 2015)/ [Relevant (GN982 as amended) App 2 (GN667 of 2019) section of Minimum Content of a Closure Minimum Content of a Final Rehabilitation, this plan] Plan Decommissioning and Closure Plan (5) details associated with any ongoing research on [13] closure options; (3)(6)(7) closure actions, including - (1) a detailed description of any assumptions made to develop closure actions in the absence of detailed [7.2.2] knowledge on site conditions, potential impacts, material availability, stakeholder requirements and other factors for which information is lacking; (2) the development and documenting of a description of specific technical solutions related in infrastructure and facilities for the preferred closure option, which must [8] include all areas, infrastructure, activities and aspects associated with mining for which the mine has the responsibility; and (3) the development and implementation of plans to address threats and opportunities and any uncertainties associated with the proposed closure actions, which will be [7.2.2] used to identify and define any additional work or research that is needed to reduce the level of uncertainty; (1)(d) measures to rehabilitate the (3)(6)(8) a schedule of actions for the annual environment affected by the rehabilitation plan (GN667 only), and the final undertaking of any listed activity or rehabilitation, decommissioning and mine closure plan specified activity and associated which will ensure avoidance, rehabilitation and closure to its natural or management of impacts including ongoing pumping and [6] predetermined state or to a land use treatment of extraneous water -

which conforms to the generally (1) linked to the mining work programme, if greenfields, accepted principle of sustainable including assumptions and schedule drivers; and development, including a handover (2) including a spatial map, showing planned spatial report, where applicable progression throughout operations; (3)(6)(9) an indication of the organisational capacity that will be put in place to implement the plan including - (1) organisational structure as it pertains to the plan [10] (2) responsibilities; and (3) training and capacity building that may be required to build closure competence; (3)(6)(10) An indication of gaps in the plan, including an [13] auditable action plan and schedule to address the gaps; (3)(6)(11) closure and risk threshold criteria for each [9] activity or infrastructure in relation to environmental [11] aspects with auditable indicators; [Table 7] (GN667 only) (1)(j) where applicable, details of (3)(6)(12) the closure cost based on cost estimates for any financial provision for the operations, or components of operations as follows- rehabilitation, closure and on-going (1) costing, calculated using market related figures and post decommissioning management the current value of money and no discounting or net of negative environmental impacts present value calculations; (2) costs must be calculated for the rehabilitation, remediation, maintenance and long term monitoring being undertaken on all disturbed areas and associated [12] environmental impacts; (3) costs calculations must be based on rehabilitation, remediation, maintenance and long term monitoring of activities undertaken by a third party; (4) where appropriate, a differentiation between capital, operating, replacement and maintenance costs; (5) the closure cost estimation must include cost

Project Name: ERPM Extension 2 Mine 10 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

App 5 EIA Regulations App 4 (GN1147 of 2015)/ [Relevant (GN982 as amended) App 2 (GN667 of 2019) section of Minimum Content of a Closure Minimum Content of a Final Rehabilitation, this plan] Plan Decommissioning and Closure Plan assumptions and auditable calculations of cost per activity or infrastructure; and (6) cost estimates for operations, or components of operations as follows: For end of life of operation >30 years to design effort is pre-conceptual/class 5 estimate/up to 2% of complete definition with a degree of accuracy in cost estimation of - 50% to +50%. (8) the estimated costs must be expressed for each year based on the rate of extraction and extent of disturbed area; (9) the risk modelling and the calculation of closure cost estimation must be updated annually during the operation’s life to reflect known developments, including changes from the annual review of the closure strategy assumptions and inputs, scope changes, the effect of a further year's inflation, new regulatory requirements and any other material developments. (1)(g) time periods within which the measures contemplated in the (10) schedule of reporting requirements as per these closure plan must be implemented Regulations; and (1)(c) proposed mechanisms for [11] (11) monitoring, auditing and reporting requirements as monitoring compliance with and per these Regulations; performance assessment against the closure plan and reporting thereon (12) motivations for any amendments made to the final Initial plan no rehabilitation, decommissioning and mine closure plan, updates or given the monitoring results in the previous auditing amendments period and the identification of gaps as above. as of yet

Project Name: ERPM Extension 2 Mine 11 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

1.2 Details and expertise of the EAP

Name of Firm Prime Resources (Pty) Ltd Physical Address: 70 - 7th Avenue, Parktown North, Johannesburg Postal Address: PO Box 2316, Parklands, 2121 Telephone Number: 011 447 4888 Fax Number: 086 604 2219 Email: [email protected] Professional Affiliations: PrEng; PrSciNat, SAIMM

Prime Resources is a specialist environmental consulting firm providing environmental and related services, and was established in 2003. Prime Resources was founded by Peter Theron (PrEng, SAIMM), who has over 30 years’ experience in the field of environmental science and engineering.

Gené Main (Pr.Sci.Nat, Environmental Science) is the Project Manager and Principal Consultant for the proposed project, has a M.Sc. (Botany) from the University of the Western Cape and 11 years’ experience in the field of environmental science.

Louise Jones, the environmental scientist and author, has a M.Sc. (Environmental Sciences) from the University of the Witwatersrand and six years’ experience in the field of environmental consulting.

1.3 Details of the holder

Name: ERPM Extension Area 1 (Pty) Ltd Dr. Le-Marlie Marais, Managing Director Contact Person: Njovu Strategic and Operational Advisors (Pty) Ltd Physical Address: Office 206, Alto Level House, 4 Fir Drive, Northcliff, 2195 Postal Address: PO Box 6213, Cresta, 2118 Telephone Number: 084 050 4613 Fax Number: 086 684 8245 Email: [email protected]

Project Name: ERPM Extension 2 Mine 12 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

2. PROJECT DESCRIPTION

2.1 Construction and Operation

The required workforce is currently estimated at 976 permanent employment opportunities (excluding procurement or contractors). The bulk of these will consist of unskilled and semi-skilled labour.

Surface infrastructure associated with the development of Windmill Shaft, is to be developed within the proposed Windmill Shaft surface development area (SDA) of approximately 20 Ha (refer to Figure 1 below). The surface infrastructure required for development is as follows:

 Shaft A and Shaft B o Shaft A will be 3 025 metres below collar (mBC) (50 m headgear, men and material winder). o Shaft B will be 2 500 mBC (50 m headgear, men and material winder, and vent shaft). o The shafts will be lined for the first 30 – 40 m only and both will be 6 m in diameter. o It is estimated that construction of both shafts will take 6 years. Shaft B (the shallow shaft) will be commissioned first and Shaft A (the deeper shaft) will be commissioned at the end of year 1.  A refrigeration plant, that will allow for the cooling of underground mining operations;  A water treatment plant is potentially required for the treatment of underground water;  Security office, change house, administrative buildings, workshops, salvage yard, stores and general waste storage area;  Powerlines (power supply connection) and substations will connect to existing power sources;  Water supply pipeline for potable and service water supply from the municipal reticulation system;  Stormwater and pollution control infrastructure, including diversion berms, storm water channels and pollution control dams;  A backup generator and a fuel supply tank within a bunded area;  Explosives handling area;  Waste rock dump (WRD) (waste rock from sinking of the shafts only);  Existing access roads will be used as far as possible, however a small road network around the refrigeration plant and a parking area will be constructed; and  A grout plant (backfill plant) to provide material to support underground mine workings.

Ore and waste rock will be stored below ground. Mined ore will be crushed and mixed with groundwater to form a slurry which will be transported to the surface via a hydraulic hoist system. This slurry, will then be directed using existing pipelines to either the Knights Plant, north-west or to the Ergo Plant, north-east of the Windmill Shaft SDA. Waste rock will be used as backfill material. It is proposed that any excess water from below ground, not used as service water by ERPM Ext 1, will be transferred to DRD Gold for use in their operations.

Topsoil will be used to create a berm upstream of the infrastructure area, and will further be vegetated to screen the residential areas from noise and visual impacts.

Operations will be 24 hours per day.

Project Name: ERPM Extension 2 Mine 13 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

Figure 1: Windmill Shaft SDA infrastructure layout

Figure 2: Witpoortje Vent Shaft SDA infrastructure layout

Project Name: ERPM Extension 2 Mine 14 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

Surface infrastructure associated with the development of Witpoortje Vent Shaft, which is an existing shaft to be refurbished, is to be developed within the proposed Witpoortje Vent Shaft SDA of approximately 7 Ha (refer to Figure 2 above). The surface infrastructure required for development is as follows:

 Ventilation shaft (4.8 m in diameter);  Surface ventilation fans;  Generator and compressor; and  Access road.

2.2 Decommissioning and Rehabilitation

A period of 5 years has been assumed for decommissioning and rehabilitation. All surface infrastructure will be removed with the exception of the WRD which is to remain on surface and be rehabilitated. The area where the proposed surface infrastructure is to be removed will be rehabilitated to return the area to the pre-mining state (i.e. aligned to the baseline environment) able to support a suitable land use based on the planning objectives for the area.

2.3 Mineral to be mined

The minerals to be mined at ERPM Ext 2 include the following:

 Gold  Silver  Pyrite  Nickel  Uranium  Platinum Group Metals  All associated minerals coincidentally mined

2.4 Mining Method

The proposed ERPM Ext 2 Mine is an underground mine, with the depth of the mineral approximately 2 500 mBC. The mining method will be Sequential Grid System and Down Dip. Originally developed for Elandsrand Gold Mine (now Kusasalethu) where dip-orientated dislocations predominate, and which has subsequently found favour in a number of other deep mining operations, particularly where structural features dislocate, complicate and interrupt the reef horizon and render continuous longwalling problematic. Contiguous longwall panels are advanced on breast in both directions from reef raises or centre gullies in a controlled sequence towards dip-orientated pillars. These pillars can be located and orientated such that they contain or bracket any troublesome dip-orientated geological features. Strike access and service tunnels need to be sited very deep in the footwall (in the order of 100 m to 120 m or more, measured normal to strata) to avoid the high induced stress levels associated with traversing overlying dip pillar regions.

Project Name: ERPM Extension 2 Mine 15 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

3. ENVIRONMENTAL AND SOCIAL CONTEXT

This section details the pre-mining environmental and social context that may influence closure activities.

3.1 Air Quality

Sources of air pollutants in the CoE were compiled during the development of an Air Quality Management Plan for Ekurhuleni Metropolitan Municipality (EMM) in 2004. Source types within CoE include:

 Industrial and commercial – including fuel burning by businesses, hospitals and schools;  Waste treatment and disposal – waste incineration, landfills and waste water treatment works;  Residential – household combustion of coal, paraffin, liquid petroleum gas and wood;  Transport – petrol and diesel driven vehicle tailpipe emissions, vehicle entrained road dust, brake and tyre wear fugitives, rail-related and aviation emissions;  Mining – especially wind-blown emissions from mine tailings impoundments; and  Other – tyre burning, wild fires, fugitive dust emissions from open areas and agricultural activities.

Identified sources within close proximity to the mine include:

 Small industrial sources and fuel burning appliances such as boilers at schools and hospitals, stand- by generators, and air heaters;  Waste - emissions emanating from landfill areas;  Household fuel combustion  Windblown emissions from nearby tailings storage facilities  Vehicle tailpipe emissions  Fugitive dust sources from roads, open areas, agricultural activities and mining  Biomass burning

The CoE falls within the Highveld Priority Area, as identified by the Department of Environmental Affairs.

3.2 Water Resources

3.2.1 Surface water

The study area falls within the C22C Quaternary Catchment, within the Upper Vaal Water Management Area (Figure 3). The most noticeable water feature within the MRA is that of the Rietspruit River - a perennial river, which flows in a north to south-westerly direction, until it joins the Klip River at the outlet of the quaternary catchment C22C. The Klip River then flows in a south-westerly manner, passing the town of Meyerton, and then into the Vaal River, which is immediately above the Vaal Barrage, near the town of Vereeniging.

Project Name: ERPM Extension 2 Mine 16 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

Figure 3: Catchment and water resources

3.2.2 Aquatic Ecology and Wetlands

A Channelled Valley Bottom wetland was identified within the Witpoortje Vent Shaft SDA, and a Hillslope Seep wetland was identified within the Windmill Shaft SDA. Both the Hillslope Seep and Channelled Valley Bottom wetlands have been impacted on by historical and current mining and agricultural activities within the greater catchment.

The Channelled Valley Bottom wetland is primarily hydrologically driven by overland flow from the greater catchment. The wetland is primarily hydrologically driven by overland flow from the greater catchment. Historic construction of artificial impoundments within the active channel of the wetland, as well as infilling and excavation related to mining activities, have impacted on the geomorphological processes of the wetland. Increased water inputs, and thus increased sediment inputs, arising from the road infrastructure that traverse the system has likely resulted in greater sediment loads within the wetland.

3.2.3 Closure recommendations

 Refer to the Watercourse Rehabilitation and Management Plan, which provides mitigation measures to manage and rehabilitate potential impacts that could affect the Hillslope Seep wetland and the Channelled Valley Bottom wetland during the proposed expansion and mining activities.  Maintain the Present Ecological State of the wetlands associated with the development of the Witpoortje Vent Shaft and Windmill Shaft, and where possible improve the ecological conditions of

Project Name: ERPM Extension 2 Mine 17 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

the system through rehabilitation of historic anthropogenic activities that have altered the ecological functioning of these systems;  Minimise impacts on surface water and groundwater quality;  Reinstate ecological services and topographical sequences;  Alien invasive plant species control, protection and the reinstatement of indigenous vegetation;  Erosion control and siltation management, including topsoil management and bank stabilisation; and  Prudent monitoring to ensure timeous detection of, and response to damage caused by mining activities and the development of infrastructure; and  The Watercourse Rehabilitation and Management Plan advocates the use of several environmental management tools and mitigatory measures appropriate to the overall planning process of the construction, operational.

3.2.4 Groundwater

The study area has a moderate aquifer vulnerability according to the aquifer vulnerability map of South Africa. With the exception of the Malmani dolomite, all the aquifers in the study area are classified as minor aquifer systems. As a result, the groundwater is of limited quantity, but potentially important for local water supply and base flow for rivers. The dolomite is classified as a major aquifer system, which is viewed as a high yielding aquifer with generally good quality water.

The depth to groundwater level as measured during the hydrocensus is less than 10m. Groundwater levels generally mimic topography in the areas where the boreholes are located and there is no indication of the aquifers being dewatered. Groundwater flow contours are directed from the higher lying quaternary catchment boundaries towards the lower lying Withokspruit and Rietspruit that drains the study area.

In general, the groundwater quality is good with only some individual elements showing concentrations that exceed applicable SANS241:2015 drinking water guidelines. These include:

 Chloride (borehole HBH6 measured 314 mg/L, exceeding the guideline of 300 mg/L).  Sulphate concentrations (boreholes HBH2 and HBH5 measured 1130 mg/L and 788 mg/L, respectively, exceeding the guideline of 500 mg/L for health impacts).  Nitrate (boreholes HBH1 and HBH8 measured 12.9 mg/L and 32.5 mg/L, respectively, exceeding the guideline of 11 mg/L).  Aluminium (borehole HBH5 measured 0.359 mg/L, slightly exceeding the SANS241:2015 guideline of 0.3 mg/L).  Manganese concentration (borehole HBH7 measured 0.51 mg/L, exceeding the SANS241:2015 guideline value of 0.4 mg/L).  Total Coliform (borehole HBH5 measured 1500 CFU/100mL, exceeding the guideline value of 10 CFU/100mL. Concentrations above 100 CFU/100mL are indicative of poor water treatment, post- treatment contamination or definite growth in the water distribution system. There is a significant and increasing risk of infectious disease transmission.

3.2.5 Closure recommendations

 All contaminated stormwater from the site must be collected and contained and not allowed to infiltrate into the groundwater.  Groundwater levels are expected to return to pre-mining levels after mine closure.

Project Name: ERPM Extension 2 Mine 18 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

 Groundwater level monitoring must be conducted at the designated monitoring boreholes on a monthly basis throughout operations and for five years post-closure.  Groundwater quality monitoring must be conducted at the designated monitoring boreholes on a quarterly basis throughout operations and for five years post-closure.

3.3 Soil, Land Cover and Land Use

3.3.1 Windmill Shaft SDA

The proposed location of the Windmill Shaft SDA lies on a soil described in the Pretoria-Witwatersrand- Vereeniging Peri-Urban Soil Survey (Yager et al., 1990) as soil series dHu27. This indicates that the soil form is Hutton. Hu27 has a sandy-clay to clay texture, and is underlain with rock with moderate leaching. The soil is expected to be deep, i.e. greater than 1.2 m, and is suitable for agriculture. The Hydropedological study indicated that the Dresden / Mispah soil form also exist within the footprint. The soils of the proposed site appear to be relatively undisturbed, with typical highveld-grassland vegetation cover.

3.3.2 Witpoortje Vent Shaft SDA

The Witpoortje Vent Shaft SDA lies on a soil described in the Pretoria-Witwatersrand-Vereeniging Peri-Urban Soil Survey as soil unit GsA which typically has a sandy clay loam texture. This soil unit is a composite of soil series Glenrosa and Avalon soil forms which are Lithosols (shallow and rocky) and structureless soils respectively. The hydropedological study identified the soil form at the Witpoortje SDA as Mispah / Glenrosa which are both shallow, characterised by an Orthic A horizon which grades directly into hard rock or lithocutanic material (SAS, 2019b).

The soils of the proposed site appear highly disturbed with mostly bedrock exposed and the remaining soil appearing shallow and rocky.

The proposed SDA for the ERPM Ext 2 Mine is in relatively sparse in urban development, and the landscape is made up mostly of open land, which is utilised mainly for agriculture and livestock grazing.

Land cover data for the area was obtained from the SANBI GIS Land Cover Map 2015. The land cover associated with the proposed mining area is classified as grassland, mining, plantation/woodlots, low shrubland and wetlands (refer to Figure 4).

According to the Gauteng Provincial Environmental Management Framework (GPEMF), the proposed SDAs fall within Zones 3 and 4 (refer to Figure 5). Zone 3 is “High control (outside urban development)” and Zone 4 is “Normal control”. Zone 3 is considered sensitive to development activities and in several cases also have specific values that need to be protected. Conservation and related tourism and recreation activities should dominate development in this zone. Zone 4 is dominated by agricultural uses outside of urban development, thus the intention is to promote agriculture and rural development that supports agriculture in these areas. Mining is considered to be compatible with Zone 5, conditionally compatible with Zone 4 and an undesirable development/ land use in Zones 1, 2 and 3.

Site visits were conducted in February 2019 and May 2019 and the following land uses were identified within the proposed site and surrounds: natural open space, historical prospecting and mining activities (mine dumps, pipelines, cleared areas etc.), substations and powerlines, railway lines, tarred roads, gravel roads/footpaths, grazing and chicken houses.

Project Name: ERPM Extension 2 Mine 19 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

Figure 4: Land Cover map for the proposed project area

Figure 5: Proposed project relative to the GPEMF zoning

Project Name: ERPM Extension 2 Mine 20 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

3.3.3 Existing infrastructure on site and in the surrounding areas

Well-established historical mining infrastructure exists within the MRA (Figure 6). The SDAs have remained relatively free from urban developmental pressures and are made up of open land that may be utilized for livestock grazing.

Figure 6: Existing infrastructure (including historical mining infrastructure) surrounding the proposed project area

3.3.4 Closure recommendations

 Stockpiled soil should be used to rehabilitate disturbed sites. The utilisable soil removed during the construction phase must be redistributed in a manner that achieves an approximate uniform stable thickness consistent with the approved post development end land use, and will attain a free draining surface profile. Replaced soils require both physical and chemical amelioration.  In areas where no topsoil is available for rehabilitation, it is possible to establish plant growth in subsoil material (Non-plinthic “B” horizon materials). Non-plinthic “B” horizon materials are physically suitable for rehabilitation but contain little or no organic matter and, accordingly, will not supply planted grasses with nutrients if used as topsoil. Organic or inorganic fertilisers, as per specialist recommendation, are to be used with regular maintenance as per specialist recommendation until natural nutrient recycling occurs.  Soil fertility should be restored. The fertility remediation requirements of the topsoil need to be verified at the time of rehabilitation, and informed by the results of sampling. Input from a soil specialist should be obtained regarding fertility remediation requirements, which should be adhered

Project Name: ERPM Extension 2 Mine 21 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

to prior to re-vegetation. The chemical soil composition should be ameliorated to closely match the baseline values as far as possible, particularly for pH and EC.  Soil contaminated with hydrocarbons must be moved to an allocated area where it will be rehabilitated and soil that cannot be rehabilitated must be disposed of at an appropriate landfill facility.  Rehabilitated areas should be cordoned off to limit equipment, human and animal movement on the rehabilitated areas.  All areas susceptible to erosion must be monitored.  Monitor the recovery of vegetation annually for a period of five years following rehabilitation.

3.4 Ecology

From the Terrestrial Ecology Assessment conducted by Scientific Terrestrial Services in July 2019 three habitat units were identified, namely the Eragrostis chloromelas Grassland, Degraded Secondary Grassland (Witpoortje Vent Shaft) and Hyparrhenia hirta Secondary Grassland (Windmill Shaft) (refer to Figure 7).

At the Witpoortje Vent Shaft, the floral habitat and diversity of the Eragrostis chloromelas Grassland has been severely degraded due to edge effects from surrounding vegetation clearing and anthropogenic activities. Despite a limited number of species considered indigenous to the Tsakane Clay Grassland, the habitat unit can no longer be considered as primary grassland. Alien plant proliferation was evident, however several of these plants produce flowers and seed material which serve as a food source for insects and avifauna. The Witpoortje vent shaft area did provide suitable habitat for floral species of conservation concern (SCC) considered declining within the province, namely Eucomis autumnalis and Hypoxis hemerocallidea, although a limited number of individuals were observed. In addition, the Witpoortje Vent Shaft, in particular the Eragrostis chloromelas Grassland is considered important for the faunal SCC Mystromys albicaudatus (White-tailed Mouse, EN) and Atelerix frontalis (Southern African Hedgehog, NT). Historic earth moving activities within the Degraded Secondary Grassland habitat have led to the loss of topsoil, loss of faunal habitat and consequently a notable decrease in food resources. This has led to a notable drop off in the species diversity and abundance within this habitat unit.

At the Windmill Shaft the Hyparrhenia hirta Grassland Habitat unit has been subjected to historic agricultural and ground clearing activities which has altered the floral species composition and subsequently the floral habitat and diversity of the area and led to the dominance of the grass species Hyparrhenia hirta, with intermittent patches of Cynodon dactylon, a further indicator of habitat disturbance. This habitat unit is considered to be of moderate floral importance and sensitivity and moderately low faunal importance and sensitivity, due to the homogenous grass layer, lower food resources and continued disturbances as a result of extensive grass harvesting by the local communities for thatching material.

3.4.1 Closure recommendations

 Limit the shaft footprint to the study area;  Implement concurrent rehabilitation of Alien and Invasive Plant (AIP) proliferated areas and bare soils; and  Control AIP species.

Project Name: ERPM Extension 2 Mine 22 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

Figure 7: Habitat units within the project area

3.5 Noise Character

From the Environmental sound level survey and Noise Impact Assessment conducted by IMA Trader in June 2019, current environments in the vicinity of the Windmill SDA and Witpoortje SDA and the EPRM Ext MRA during the day-time and the night-time are quiet to medium sound level environments.

3.6 Socio-economic

The following information was obtained from the City of Ekurhuleni (CoE) Regional Spatial Development Framework for Region E, (2015) and from Stats SA (2016).

3.6.1 Local context

There are approximately 503 000 residents living within Region E, which makes the region the 3rd most populous in the municipality. About half of the inhabitants living here reside within the townships of Tsakane (155 000), KwaThema (103 000) and Duduza (75 000) (StatsSA, 2016), all considered densely populated.

Ward 82 contains the agricultural smallholdings of Withok Estates and a portion of Tsakane. Ward 99 is made up of the majority of the MRA, the existing ERGO tailings dam and a portion of Villa Liza high density suburb. Ward 105 contains the residential areas of Dalpark Ext. 1, Minnebron, Sallies Village and Denneoord. Ward 74 contains the suburbs Tornado, Selcourt and portion of Springs. Languages spoken are IsiZulu, Sesotho and Sepedi. Table 1 below gives an overview of the demographics in each ward.

Project Name: ERPM Extension 2 Mine 23 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

Table 1: Statistical Profile of Ward 105, 99, 82 and 74 Category Ward 105 Ward 99 Ward 82 Ward 74 Total population 22 035 43 871 28 765 28 203 Number of households 7 126 13 965 8 157 10 220 Density (people per km2) 633 506 1 124 976 Female 50 45 51 53 Male 50 55 49 47 Black African 24 93 80 80 Coloured 2 6 18 1 Indian or Asian 3 0 0 0 White 70 1 2 18 0 - 18 25 32 32 26 18 - 64 68 67 65 69 Over 65 8 1 4 5 Born in South Africa 90.4 81.9 95.5 92.3 Born in Gauteng 67 39 78 61

The region is afflicted by limited economic opportunities, which have hindered social development. This is evidenced by high levels of unemployment, in which only 55.59% of those able to work are doing so. There are many reasons as to why there is a low participation rate of the labour force, however one of the major drivers for this may be attributed to the need for more opportunities to be created or for better access to employment. Unemployment is worst in wards 99 and 82 which has 38.3% and 40.8% unemployment, respectively. The annual income for wards 99 and 82 is between R14 600 and R57 500 per annum. Ward 105 however, has an annual income of R117 000, in which it also has a higher employment rate of 66.4% (StatsSA, 2016).

The following socio-economic sensitive receptors were identified:

 Residential smallholding farmhouses, one to the immediate east of the Windmill Shaft location (approximately 350 m) and one to the north west (approximately 700 m).  Rooikraal Landfill Site adjacent to the proposed Windmill Shaft to the west.  The high density suburbs of Villa Liza, Windmill Park and Dawn Park to the west and south west of the Windmill Shaft.  Informal settlements of Villa Farm, Somalia and Holomisa adjacent to Villa Liza and Dawn Park .  The high density areas of Kwa-Thema and Tsakane to the west of the MRA.  Agricultural small holding suburb in Withok Estates, which is approximately 3 km west of the Windmill Shaft SDA and directly adjacent to the Witpoortje Vent Shaft in the south.  Eggbert Eggs laying and rearing sites, within the MRA, approximately 1 km from the Windmill Shaft.  Afrisam Rooikraal Quarry, approximately 3.5km south of the Windmill Shaft.

3.6.2 Closure recommendations

 At closure the unemployment rate in the area may increase. The provisions of the Social and Labour Plan (SLP) relating to minimizing the negative impact of retrenchment must be implemented to mitigate this eventuality.  Implement the Skills Development Plan (SDP) and measures regarding the management of downscaling and retrenchment as detailed in the SLP.  Maximise the potential benefits to the local economy by ensuring that local labour and service providers are utilised wherever possible throughout the various phases of the life of mine.  Establishment of Future Forums;

Project Name: ERPM Extension 2 Mine 24 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

 Provide information and counselling for retrenched employees to promote their absorption into the labour market;  Offer a post retrenchment programme designed to equip retrenchees with knowledge and skills.  The mitigation measures relating to noise, dust, blasting, groundwater, traffic and visual intrusion detailed in the SEIA and EIA should be implemented.

3.7 Other mining activities nearby

Other mining activities within a 20 km radius of the proposed ERPM Ext 2 Mine include:

 DRDGOLD South African Operations (Pty) Limited (includes ERPM and Ergo Mining Proprietary Limited (Ergo))  GoldOne Modder East Operations  Impala Refining Services  Grootvlei  S.A. Lands Mine (Sallies mine)  Marievale Consolidated Mine  East Geduld Mine  East Daggafontein Mine  Megamine

Project Name: ERPM Extension 2 Mine 25 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

4. CLOSURE RELATED ISSUES

This document comprises the first draft of the Closure Plan, and a version of this plan formed part of the documents made available for public review and comment. Public participation was conducted as per the requirements of Chapter 6 of the NEMA EIA Regulations, GN982 of 2014 as amended by GN326 of 2017 as part of the ERPM Ext 2 Mine Scoping and EIA process and entailed the following:

 The landowners of the properties where the surface infrastructure is to be located have been identified and notified of the proposed project activities via registered mail or email. A meeting was held with Eggbert Eggs (landowners of Portion 5 of Witpoortje 117 IR) on 15 May 2019. Contact details for the landowner of Portion 19 of Witpoortje 117 IR (Ms Suzanne Weitze) could not be obtained. Ongoing efforts will be made to contact her.  A media notice was published in two local newspapers (Brakpan Herald and the African Reporter) on 8 March 2019. The media notice provides a brief project description, legislative requirements, and the registration process to be followed for Interested and Affected Parties (IAPs), details on the availability of the Scoping Report, and contact details for more information.  Site notices were posted on site and at conspicuous locations within the surrounding communities on 8 March 2019, providing a brief project description, legislative requirements, the process to be followed to register as an IAP, details on the availability of the Scoping Report, and contact details for more information.  The Scoping Background Information Document (BID), which provided a brief description of the project and potential impacts, the legislated environmental process, availability of the Scoping Report, the process to follow to register as an IAP, and contact details for queries, was made available to State Departments and IAPs via email on 8 March 2019, and to surrounding residents by hand on 8 March 2019. The BID was also made available to IAPs requesting further information.  The Scoping Report was made available for review and comment to State Departments (including the Competent Authority) via email or hard copy as requested, and placed within the public domain on the Prime Resources website (www.resources.co.za), and at the Vosloorus, Tsakane, Kwa-Thema, Geluksdal and Brakpan Public Libraries for a commenting period of 30 calendar days (8 March to 8 April 2019).  A meeting was held with members of the Withok Community on 03 April 2019.  An Environmental Impact Assessment Report (EIAR) and Environmental Management Programme (EMPr) was compiled and made available for review and comment to State Departments (including the Competent Authority) via email or hard copy as requested, and placed within the public domain on the Prime Resources website (www.resources.co.za), and at the Vosloorus, Tsakane, Kwa-Thema, Geluksdal and Brakpan Public Libraries for a commenting period of 30 calendar days (9 September to 10 October 2019).  An IAP register was opened and representatives from all of the relevant State Departments, as well as any IAPs requesting to register, were added to the database.  A Comments and Response Report was compiled incorporating all comments received (and responses thereto) during the public consultation periods.

Issues and concerns raised during the public participation process were responded to and proposed alternatives and mitigation measures assessed where applicable were incorporated. The stakeholder issues

Project Name: ERPM Extension 2 Mine 26 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

and comments relating to closure, raised during the aforementioned public participation process, are detailed in Table 2 below.

Table 2: Closure related issues Issues raised Where addressed in this plan Since the NEMA Financial Provisioning Regulations came into effect the Applicant is required to put aside funds for rehabilitation before mining begins.

Are there are sufficient securities, The required financial provision must be provided for/set aside, either through a guarantees and controls in place financial guarantee or by payment into the DMR account and proof of availability to ensure that when the mine is for financial provisioning must be provided on the effective date of a Mining Right closed there are sufficient funds and is therefore in place prior to the commencement of the mining. available for rehabilitation

Every financial year the holder must review and re-assess the closure plans and reports. The results of reviews, confirmations or adjustments of the adequacy of financial provision must be audited by an independent auditor who must draft an audit report to be submitted to the Minister of the DMR, and must be made From previous experience with available on a website, at a site office and on request. The holder must also ERGO, the funds set aside for publish the outcome of the Ministers decision in a newspaper circulating in the rehabilitation had not been area. available when the time came for

the money to be used and asked Financial Provision has been included as a regulatory cost (under the how the community can be environmental cost category) in the Mining Work Programme for the proposed certain that this will not happen ERPM Ext 2 Mine. again

Refer to Section 1.1, 11.2 and 12. The reopening and equipping of the shafts will increase security presence in the area around the SDA and could have a positive impact on safety and security Concern for safety in terms of during operations. illegal miners, and that once a mine closes, people try to access The closure plan addresses the aspects related to closure. At closure, the shafts the mines illegally. must be sealed with approved seals designed by a professional engineer and in accordance with specifications provided by the DMR and rendered safe. Refer to Section 8.2.

4.1 Future Public Engagement

A Stakeholder Engagement Plan will be compiled prior to construction (including a grievance mechanism), which will provide a defined process for two-way communication between the community and the mine. The grievance mechanism will prescribe methods for community members to raise complaints which are to be addressed effectively.

The main objectives of a Stakeholder Engagement Plan will include:

 Identification of stakeholders;  Disclosure of planned project activities;  Identification of concerns and grievances from stakeholders;  Harnessing of local expertise and knowledge from stakeholders;  Ongoing disclosure of project activities and monitoring results; and  Response to grievances and enquiries (via the Grievance Mechanism).

Project Name: ERPM Extension 2 Mine 27 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

5. CLOSURE VISION, OBJECTIVES AND TARGETS

The current preferred option for closure of the mine is to rehabilitate the areas disturbed by mining activities to an acceptable and sustainable end land-use, in line with planning objectives where possible.

The current closure vision is to:

 Develop a landform that is free draining, with established (in terms of re-vegetation), self-sustaining vegetation;  Develop a landscape that is aesthetically acceptable (i.e. as inconspicuous as possible in relation to the existing landscape);  Ensure that closure supports sustainable end land uses considering pre-mining conditions and are in agreement with commitments to stakeholders;  Ensure that community safety is not adversely impacted (i.e. the area is stable and that shafts are sealed effectively); and  Ensure adherence to local, provincial and national regulatory requirements.

5.1 Sustainable end state/ Final land use

The shafts will be sealed and the WRD at Windmill Shaft is to remain in situ at closure. Infrastructure determined to be required for residual pollution control will also remain post-closure. Refer to Figure 8 for the infrastructure to remain post-closure.

Although the shafts will be sealed during the closure phase, the land use at the Windmill Shaft (specifically around the sealed shafts and WRD) will not be appropriate for urban development due to potential safety concerns. The proposed final end land use for the disturbed areas is industrial and / or large commercial development or low intensity grazing and/or wilderness land (Refer to Figure 9).

5.2 Closure Alternatives

Potential land use alternatives include:

 Return the remaining area to grasslands suitable for grazing or agricultural activities;  Create a wilderness area;  Create a natural open space that can be utilised by residents in the surrounding communities and the new residential development as per the municipalities strategic development plan; or  Create a recreational area.

Project Name: ERPM Extension 2 Mine 28 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

Figure 8: Infrastructure to remain post-closure

Figure 9: High level final end land use plan for the ERPM Ext 2 Mine

Project Name: ERPM Extension 2 Mine 29 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

6. MINE PLAN SCHEDULE INCLUDING CLOSURE AND POST CLOSURE PERIOD

The estimated Life of Mine (LoM) is as follows:

 6 years for sinking and establishment;  47 years in production; and  5 years for decommissioning and rehabilitation.

In order to proceed with closure activities in a legally approved manner, the relevant legal authorisations will be required, including the NEMA listed activity specifically relating to closure (Activity 22 of Listing Notice 1). This authorisation will provide the detail of the intended closure activities at the time of closure. It is anticipated that a 2 year period would be required for this pre-closure activity. In order to meet the timelines associated with the pre-closure phase a detailed closure plan will need to start to be developed approximately 5 years prior to known closure. The purpose of the detailed closure plan will be to take the draft closure plan (this document) that has been developed and updated annually throughout the remaining LoM, to that point and increase the level of detail therein to be sufficiently detailed. Once the legal authorisations to implement closure have been obtained it is anticipated that a 1 year period is required to fully implement the closure activities. A post closure maintenance and monitoring period of 5 years is being proposed to ensure for full rehabilitation. The monitoring period required to determine whether any latent impacts have either manifested or could potentially manifest is still to be confirmed once operations begin.

Table 3 below provides an indication of the current anticipated timelines associated with the LoM and proposed closure period.

Project Name: ERPM Extension 2 Mine 30 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

Table 3: Mine Plan Schedule Post closure Monitoring for Phase Construction Operation Pre-closure Closure maintenance latent impacts and monitoring 47 years in 2 years prior to To be Actions Duration 6 years 1 year 5 years production production ending confirmed Shaft sinking (Windmill) and ventilation shaft refurbishment

(Witpoortje) and development of surface infrastructure Underground mine operational Approximately 5 Develop detailed closure plan years prior to known closure Submit an application for closure certificate and an application for EA for decommissioning Topsoil inventory and preliminary soil fertility monitoring Underground mining activities cease Removal of surplus hazardous material and all waste from the operational phase Assessment of structural integrity / stability of underground supports Removal of all material from the underground workings Sealing of shafts Demolition of surface infrastructure not remaining post-closure

(water management infrastructure to be decommissioned last) Removal of all salvageable material and demolition waste Polluted water in PCD processed Water management infrastructure to be decommissioned Contaminated land assessment and remediation Rehabilitation of disturbed footprint and WRD Assessment of structural integrity / stability (surface dumps and infrastructure to remain in situ for residual pollution control) Vegetation establishment Post closure monitoring and maintenance Monitoring programme to determine whether any latent impacts have either manifested or could potentially manifest

Project Name: ERPM Extension 2 Mine 31 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

7. ENVIRONMENTAL RISK ASSESSMENT

The aim of the Environmental Risk Assessment is to identify potential risks which may manifest during and immediately after the closure activities implemented by the mine (as per the timeline described in Section 6), and recommend management and monitoring measures, which should be applied by ERPM Ext 1 in order to prevent or minimise the impact of potential latent risks post closure.

7.1 Identification of receptors sensitive to closure

The potential risks relating to the closure and rehabilitation activities at ERPM Ext 2 are detailed in Table 4 below, per sensitive receptor and the quantification of these risks is detailed in Section 0 and Table 5 below. The relevant closure actions/strategies to achieve the closure vision, objectives and targets and to avoid, manage and mitigate the impacts and risks are detailed under Section 8.

Table 4: Closure-related risks and sensitive receptors Potential closure-related risk Sensitive receptor  Air quality  Generation of dust  Visual aesthetics and landscape character  Socio-economic  Loss of habitat integrity, species diversity and SCC  Flora  Latent impacts of vegetation losses  Fauna  Compaction of soils  Alteration of hydrological recharge paths/ natural drainage patterns leading to possible loss of recharge to down-  Aquatic Ecology and Wetlands gradient areas and impact on down-gradient biota  Soil and land capability  Possible sedimentation of down-gradient areas  Surface water  Sedimentation and erosion  Disruption of the aquatic ecology of the impacted watercourses  Contaminant migration away from pollution sources (mining area and surface stockpiles)  Contamination of the catchment by decant  Groundwater  Reduced soil quality  Surface water  Decrease in quality of groundwater baseflow contribution to  Soil and land capability the downstream watercourse resulting in the decrease in the  Socio-economic water quality in the receiving catchment  Impact on surrounding residents and surface water users  Recovery of groundwater level  Groundwater  Increased unemployment rate in the area  Health risk to people and animals from dust  Socio-economic  Potential occurrence of subsidence  Improved overall visual quality of the surrounding landscape  Visual aesthetics and landscape character  Permanent change in the visual character of the area

7.2 Risk Assessment

7.2.1 Methodology

The risk assessment aims to identify the risk associated with the above closure risks and the implementation of the intended closure actions listed in Section 8 below.

The following assessment model was used for determination of the significance of closure related risks.

Project Name: ERPM Extension 2 Mine 32 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

Consequence

Extreme Human health morbidity /mortality. Loss of species

Severe Materially reduced faunal populations, loss of livelihoods, individual economic loss

Substantial Material reduction in environmental quality – air, soil, water. Loss of habitat, loss of heritage, amenity

Moderate Nuisance

Slight Negative change – with no other consequences

Probability

1 Highly unlikely

2 Unlikely

3 Possible

4 Probable

5 Definite

Significance

Extreme Moderate High High Fatally flawed Fatally flawed

Severe Low Moderate High High High

Substantial Low Moderate Moderate Moderate Moderate

Moderate Low Low Low Low Moderate

Consequence Slight Low Low Low Low Low

Highly Unlikely Possible Probable Definite unlikely

Fatally flawed Unacceptable level of risk

High Requires strict conditions and high levels of compliance and enforcement

Moderate Requires conditions and routine inspections

Low Little risk of environmental degradation

The significance of the risks identified was determined using the above methodology. Refer to Table 5 below for the ERPM Ext 2 closure risk assessment. The individual risks were then reassessed to determine whether the residual impacts can be reduced or avoided by implementing the closure strategy (post-closure strategy values (post mitigation) are indicated in Section 9).

Project Name: ERPM Extension 2 Mine 33 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

Table 5: Assessment of the potential closure related risks associated with the proposed ERPM Ext 2 Mine Sensitive Process Risk Consequence Probability Significance Receptor  Access roads  Management of topsoil, overburden and waste rock  Nuisance dust emissions towards sensitive receptors Moderate Definite Moderate stockpiles  Earthworks during rehabilitation  Use, storage and handling of hazardous chemicals  Fine particulate matter emissions towards sensitive Air quality Substantial Possible Moderate and fuel receptors (with potential health impacts)  Use of internal combustion vehicles and equipment

 Use, storage and handling of hazardous chemicals  Emission of NO2, SO2 CO2 and BTEX released to the Substantial Unlikely Moderate and fuels atmosphere (with potential health impacts)  Increased vehicle trips  Loss of floral habitat integrity and species diversity Terrestrial  Site activities, especially clearing vegetation. including species of conservation concern Moderate Definite Moderate Ecology  Ineffective rehabilitation  Loss of habitat for fauna, species diversity and SCC  Vehicles on access roads  Use of equipment and machinery on site, including  Increased noise levels on site and at adjacent Noise Moderate Definite Moderate reverse beepers residential property  Rehabilitation activities

Aquatic  Loss of habitat for wetland species Ecology and  Rehabilitation activities  Contamination of the nearby surface water / Moderate Possible Moderate Wetlands wetlands

 Discharge of surplus underground water Substantial Probable Moderate  Contaminated runoff from site  Contamination of surface water resources  Seepage from WRD, topsoil stockpile and mining Moderate Possible Moderate  Contamination of groundwater Water area resources  Generation of Acid Mine Drainage Substantial Probable Moderate

 Contamination of surface water, damage to aquatic  Water decanting from mine after closure Severe Probable High life in streams, and degradation of the water quality

Socio-  Decommissioning or downscaling at the mine  Retrenchment Severe Definite High economic

Project Name: ERPM Extension 2 Mine 34 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

Sensitive Process Risk Consequence Probability Significance Receptor  Removal of surface infrastructure, access roads, etc.  Loss of soil (including soil erosion) leading to loss  Excessive stormwater runoff from newly Substantial Definite Moderate land use potential Soil and rehabilitated areas which have not been vegetated land or vegetation has not re-established capability  Potential leaks and spills of chemicals such as  Soil contamination Substantial Definite Moderate hydrocarbons, hazardous chemicals and cement.  Ineffective rehabilitation and further degradation of  Sites are incompatible with future land use Substantial Definite Moderate soil quality  Site activities, including headgears and WRD  Visual intrusion, nuisance Moderate Definite Moderate  Night time lighting Visual  Beneficial to the overall visual quality of the  Removal of the shaft headgears Moderate Definite Low Positive aesthetics surrounding landscape.  Permanent change in the visual character of the  Rehabilitation may be unsuccessful or ineffective Moderate Definite Low area  Traffic congestion and potentially unsafe driving  Additional vehicle trips Moderate Probable Low conditions Traffic  Increase in heavy vehicle volumes during  Deterioration in pavement quality resulting in unsafe Moderate Probable Low construction driving conditions

Project Name: ERPM Extension 2 Mine 35 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

7.2.2 Assumptions and Uncertainties

The main assumptions made in the compilation of this report are:

 The risk assessment is a quantitative process which needs to be informed by future specialist studies undertaken on an ongoing basis;  The accuracy of the financial provision calculations is entirely reliant on the accuracy and completeness of the supplied data;  All costs related to closure planning, feasibility studies and environmental authorisations are operational costs and thus no provision has been made for these aspects;  Infrastructure sizes were based on high level plans (no detailed design drawings were provided); and  The calculated cost included for post-closure monitoring is for the latent and residual impacts likely to manifest from the activities associated with the first year of construction only and will need to be review and re-assessed on an annual basis.

Threats, opportunities and uncertainties associated with the proposed closure actions include:

 Threats: o Stakeholder agreement to proposed final land use; o Social implication of closure; and o Lack of detailed designs for site infrastructure.  Opportunities: o Unknown.  Uncertainties: o Success of establishing indigenous vegetation; o Potential for waste rock to produce acid rock drainage or other contamination through rainwater/ groundwater infiltration; o Change in legislative requirements over the operational period; o The effects on groundwater flow and potential for groundwater contamination; o Decant potential, points / diffuse zone areas, and volumes; o The usability of the soil for establishing grazing vegetation or agricultural use; o The effects of residual contamination on future land uses; o Subsidence.

Throughout the LoM any uncertainties that may arise relating to closure must be described and potential closure strategies identified. Additional work proposed to address the above is covered in Section 13.

Project Name: ERPM Extension 2 Mine 36 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

8. CLOSURE STRATEGY

The following section details the current identified closure strategies and rehabilitation actions to be implemented to avoid, manage or otherwise mitigate the identified risks to ensure that closure objectives are met.

8.1 General Measures

The general measures detailed under this section apply to all areas affected by mining and related activities.

8.1.1 Soil handling and management

Stockpiled soils must be removed and used for rehabilitation at closure after soil contamination investigations and remedial actions, as per Section 8.1.4, are undertaken. To ensure that the proper soil handling and management is carried out, the following should be taken into account:

 During decommissioning, a survey should be compiled on the volume of topsoil available for rehabilitation;  The fertility remediation requirements of the topsoil need to be verified at the time of rehabilitation, and informed by the results of sampling. Preliminary soil fertility monitoring on stockpiled topsoil should also be carried out, prior to rehabilitation, to accurately determine the fertiliser requirements that may be needed. A representative sampling of the stripped and stockpiled soils must be analysed to determine the nutrient status and chemistry of the utilisable materials. As a minimum the following elements must be tested for: EC, CEC, pH, Ca, Mg, K, Na, P, Zn, Clay % and organic carbon. These elements provide the basis for determining the fertility of soil;  Input from a soil specialist should be obtained regarding fertility remediation requirements, which should be adhered to prior to re-vegetation. The chemical soil composition should be ameliorated to closely match the baseline values as far as possible, particularly for pH and EC;  In areas where no topsoil is available for rehabilitation, it may be possible to establish plant growth in subsoil material. This material should be sufficiently porous to store and release water and should not cap or crust excessively on surface exposure. Re-establishment of sustainable vegetation will require the application of fertilisers and the establishment of a process whereby the re-development of the natural soil fertility cycle can begin. This requires the use of organic or inorganic fertilisers at establishment and also regular maintenance applications of these fertilisers until natural nutrient recycling occurs. Plants used to establish vegetative cover in these conditions are often different to the surrounding natural vegetation and, accordingly, a botanist should be consulted prior to re- vegetative efforts.  Deposited soil should be ripped to reduce compaction during rehabilitative actions;  Rehabilitated areas should be cordoned off to limit the movement of equipment, humans and animals on the rehabilitated areas;  All areas susceptible to erosion must be monitored;  A minimum of 70 % aerial cover will be established through vegetation for at least one growing season before rehabilitation can be considered complete; and  Monitoring of soil quality and re-application of fertilisers post-closure.

Project Name: ERPM Extension 2 Mine 37 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

8.1.2 Dismantling and demolition of infrastructure

It is anticipated that all of the infrastructure will be dismantled and removed at mine closure. During dismantling, the following should be undertaken:

 All power and water services are to be disconnected and certified as safe prior to commencement of any demolition works;  Electrical, water and other services that are more than 700 mm below ground surface will remain, all others at a shallower depth must be excavated and disposed of;  All aboveground electrical, water and other service infrastructure and equipment to be removed and disposed of as general waste or, if they are salvageable, be removed to a designated temporary salvage yard;  All conveyor belts must be removed and shredded prior to disposal;  All temporary infrastructure (fencing, pumps and pipelines, turnstiles and compressors) should be dismantled and removed from site;  All permanent infrastructure must be dismantled / demolished to ground level;  The associated foundations / hard-standing areas must be demolished by ripping and levelling of areas, extending to 1 m below the final surface in order to reduce compaction;  Demolition waste should be sorted and disposed of accordingly: o Inert waste such as concrete can be used to backfill excavations or should be disposed of at a licensed landfill facility; o Recyclable materials (particularly metal) should be collected and removed by an appointed recycling contractor; and o Non-recyclable waste must be safely removed and disposed of by a contractor at a licensed landfill facility.

8.1.3 Rehabilitation

 General surface rehabilitation is applied to disturbed surfaces and should be aligned to the elected post closure land use. General surface rehabilitation should include rehabilitating the surface topography to emulate the surrounding areas. Landscaping that will facilitate surface run-off and result in free draining areas and where possible the reinstatement of drainage lines. Attention must be given to shape and / or remove heaps of excess material and create an area suitable for revegetation. Application of the below measures shall be incorporated: o All excavations must be filled in with inert material, followed by at least 1 m of subsoil and reshaped to a slope not greater than 1:5 wherever the natural topography allows; o Deep ripping with a tine of at least 50 cm will be undertaken. Where space allows, cross ripping to be undertaken, with the final rip to be parallel to contours; o Stockpiled soil must be used to rehabilitate disturbed sites and must be redistributed in a manner that achieves an approximate uniform stable thickness consistent with the end land use (i.e. industrial and large commercial development); o In areas where no topsoil is available for rehabilitation, it is possible to establish plant growth in subsoil material. Organic or inorganic fertilisers, as per specialist recommendation, are to be used with regular maintenance as per specialist recommendation;

Project Name: ERPM Extension 2 Mine 38 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

o All soils compacted as a result of decommissioning and rehabilitation activities must be ripped to a depth of 20 cm and fertilised; o The areas where topsoil has been deposited must be re-vegetated with indigenous grass and shrub species to reflect a species composition and density similar to that of a reference analogue site established in a similar ecotype under the supervision of a botanist; o Revegetation should ideally occur during spring and summer; o In areas where topography requires a slope steeper than 1:5, Vetiver grass should be planted to stabilize the slopes and minimise erosion; o Soil should be ameliorated and fertilized as required (if re-establishment of vegetation does not occur successfully or as per recommendations of a specialist); o Once the topsoil in the stockpiles has been completely removed for rehabilitation, the footprint must be rehabilitated; o Plant indigenous vegetation in disturbed areas should natural revegetation prove unsuccessful; o Rehabilitated areas should be cordoned off to limit equipment, and human movement on the rehabilitated areas; o Protect newly seeded/planted areas against compaction and erosion; o Water and weed newly seeded/planted areas regularly. Check the plants for pests and diseases at least every two weeks during the early stages and treat if necessary. Replace unhealthy or dead plant material any repair any damage caused by erosion. Re-instate vegetation to levels which will allow the natural climax vegetation community suitable for supporting the intended post closure land use; o Prohibit contractors from driving off-road and from collecting plants and firewood and starting informal fires; o Re-introduce any ecologically important species which may be important for socio-cultural reasons, ecosystem functioning reasons and for conservation reasons. Species reinstatement need only occur if deemed necessary; o AIP species monitoring and eradication must be conducted during decommissioning and rehabilitation and ongoing thereafter; and o After closure, all areas susceptible to erosion must be monitored annually and repair, maintenance and prevention measures implemented (if erosion is noted) for 2 to 3 years, until vegetation has re-established and is self-sustaining.

8.1.4 Contaminated land

 A soil contamination assessment must be carried out after stockpiling and at mine closure to verify that the soil is not contaminated before re-spreading the soil for rehabilitation. Soil analyses should include pH, EC and the metals, metalloids, hydrocarbons and anions as listed in terms of the “SSV from GN331 of 2014 National Norms and Standards for the Remediation of Contaminated Land and Soil Quality” to determine if there are any exceedances relative to the SSV 2 – Commercial and Industrial guidelines. This will determine if further analyses need to be carried out, especially if any visual stains or hydrocarbon odours are observed during the inspection.  If the soil contamination investigation indicates that soil is contaminated, the first management priority is to treat the contamination by means of in situ bioremediation. The acceptability of this

Project Name: ERPM Extension 2 Mine 39 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

option must be verified by an appropriate soil specialist and by the Department of Water and Sanitation (DWS) on a case by case basis, before implementation; and  If in situ treatment is not possible or acceptable then the contaminated soil must be assessed according to legislation (currently the Norms and Standards for the Assessment of Waste for Landfill Disposal, GN635 of 2013) and disposed of at an appropriate licensed landfill facility.

8.2 Underground Workings and Shafts

 During decommissioning, a rock mechanics specialist will assess the underground mine workings and make recommendations in order to prevent any subsidence or seismic activity occurring post- closure;  All infrastructure associated with the shafts, underground workings and ventilation system must be dismantled and removed as per Section 8.1.2 and the disturbed footprints rehabilitated as per Section 8.1.3; and  Shafts must be sealed with approved seals designed by a professional engineer and in accordance with specifications provided by the DMR and rendered safe.

8.3 Hazardous Waste

 All waste on site should be removed to an appropriately licenced facility and disposal certificated should be kept as evidence;  The self bunded diesel storage facility must be removed;  All tanks, pipes and sumps containing hydrocarbons to be flushed or emptied prior to removal to ensure no hydrocarbon/chemical residue remains;  All hazardous material to be inventoried to prevent surplus material being present on site during decommissioning and rehabilitation. Any residual hazardous materials must be removed from site;  Tests for the presence of residual ammonia / nitrate contamination must be undertaken at closure. Should there be any explosives remaining at closure, they must be removed from the site by qualified personnel before commencing with rehabilitation;  A contaminated land assessment, as per Section 8.1.4, must be undertaken for the disturbed footprint;  Dismantling / demolishing of the infrastructure must be carried out as per Section 8.1.2; and  Rehabilitation of the disturbed footprint must be conducted as per Section 8.1.3.

8.4 Roads

 All access roads, which are not going to remain for use by the surrounding communities post-closure, must be rehabilitated as per Section 8.1.3.

8.5 Waste Rock Dump

Rehabilitate the WRD to have a minimal visual impact by:

 Shaping the WRD to achieve deposit stabilisation and to blend with the natural topography as much as possible, however increasing the affected surface footprint should be prevented as far as possible;  Placing subsoil and topsoil on the dump;

Project Name: ERPM Extension 2 Mine 40 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

 Establishing vegetation on the dump with a grass mixture dominated by local climax species and vegetation that provides screening should be established;  Constructing stormwater control berms on the crests of the dump to prevent concentrated flow down the slopes is recommended;  Constructing toe protection structures around the dump to prevent silt migrating from the dumps and being spread into the environment as necessary; and  Conducting on-going monitoring of run-off water from the dump during the operational phase to confirm that it is not acid generating. If the WRD is acid generating alternative closure measures will be required to be developed by an appropriate specialist.

8.6 Groundwater

 ERPM Ext 1 must obtain a better understanding of the interconnectivity of the underground workings and geochemistry by compiling the numerical groundwater model to forecast the closure scenarios which can be improved by ongoing monitoring and investigation, thus better allowing ERPM Ext 1 to consider treatment options.  Reduce ingress of fissure water into mine workings by grouting ingress points and sealing the shaft system.  To prevent the post-closure impacts resulting from decant, a regional groundwater investigation and model must be developed and updated during the LoM to assess: o The different interconnected mines and the geological information available from each of the mines be done in order to be able to identify decant positions and volumes to an acceptable level of confidence; o The presence of geological structures connecting the underground mine to surface that could lead to decant on surface once the groundwater levels have recovered to near predevelopment levels; o The interconnection between the different mines in the area (ERPM Ext 2, ERPM Ext 1, the South East Vertical Shaft, the Hercules Shaft, the Central Shaft, the Rose Deep compartment, and others) and how that influences the decant potential, locality of expected decant points, decant volumes and decant qualities. o Should further groundwater modelling investigations show that decant will not be able to be prevented, the decant points must be fitted with post-closure decant control dams/ passive treatment systems at expected decant points that can treat decant prior to discharge to the environment. Decant must be treated to qualities stipulated by DWS prior to discharge and must be discharged to the environment in a manner that prevents flooding.  Perform geochemical assessment of the material that will be stored on the topsoil stockpile and the WRD to calculate the waste classification and determine the lining requirements of the stockpile areas at the hand of Regulation 635 and 636 of the Waste Act;  Proper lining of waste facilitates according to Regulation 636 of the Waste Act;  Proper removal of, and rehabilitation of, water management dams and surface stockpiles during decommissioning where possible;  Sloping, capping and vegetating of the remaining WRD. This will reduce rainfall recharge and thus also the volume of seepage from the WRD to the underlying aquifers.

Project Name: ERPM Extension 2 Mine 41 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

8.7 Surface water and watercourses

 Begin to plan for closure at least 10 years before known closure will occur, longer, if possible. This is particularly important for planning for the treating of water that will decant from the mine sometime after closure. The time between pumping ceasing to the time when the water begins to decant could be many years, even decades, depending on the amount of water entering the mine at or close to closure. It must be kept in mind that the treatment process must continue for years, decades or even centuries after mine closure. There must be sufficient funds in the trust to finance the water treatment after closure;  Treat underground water and identify a suitable water use;  Follow general maintenance and safety precautions to prevent diesel and hydraulic fluids contaminating soil;  Employ good housekeeping practices in terms of hazardous substances, and general and hazardous waste management - remove all rubble and materials from the site;  Design and shape the final landform to ensure the site is free draining, incorporating adequate stormwater management measures. If needed, the design should include contoured terraces to reduce velocity and spread volume of run-off water. Terracing entails creating level embankments at different elevations across a slope, along its elevation contours, in order to minimize run-off and soil erosion. The different terrace levels would promote efficient water infiltration into the soil and minimise erosion and siltation impacts after closure; and  Monitor (and repair as needed) erosion-sensitive areas until the area is stable and vegetation is established.

8.8 Socio-Economic Structure

 SLP measures, such as alternative livelihood projects, will be put in place as a matter of priority to avoid the negative impacts associated with decommissioning and closure (incl. retrenchment and downscaling and to ensure community sustainability over the long term);  Employees will need to be provided with alternative income-generating opportunities through the company's LED and skills development programmes;  All affected individuals and communities in the local area will be openly consulted with regard to the activities of ERPM Ext 1. Communication forums including the use of social media, will be established so as to ensure participatory and transparent dissemination of information;  Management strategies for the post-closure period will also be developed with local stakeholders within the closure planning process. Strategies that avoid dependency amongst the social intervention beneficiaries and promote independence amongst individuals and businesses in the community will be developed to ensure post-closure sustainability; and  On-going consultation and advisory roles potentially facilitated through the Future Forum structures or its relevant sub-committees will be utilised to ensure that the programmes and plans continue to deliver sustainable and effective benefits. The continued contribution and on-going management role of local government in this respect will be essential in this post-closure management process.

Project Name: ERPM Extension 2 Mine 42 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

9. RE-ASSESSMENT OF THE CLOSURE RISKS AFTER THE APPLICATION OF THE CLOSURE ACTIONS

The negative closure risks were re-assessed to determine whether, after the implementation of the closure strategy (as described in Section 8 above), the residual risk has been avoided. Residual traffic impacts are not expected.

Significance pre and post implementation Closure-related risk Comment of the closure strategy Before After  By dampening dust generating surfaces or applying dust palliatives, protecting stockpiles and cleared areas from wind by establishing vegetation or installing windbreaks as necessary, choosing efficient low sulphur diesel Noise and nuisance dust for vehicles and machines, developing a storage entrainment and dispersion, fine and handling plan for the chemicals and fuels to particulate matter emissions and be used, ensuring the legal storage of chemical Moderate - Low - emission of NO2, SO2 CO2 and and fuels, and implementing an emergency BTEX released to the atmosphere response plan for spills and fires, and training towards sensitive receptors users, making use of mass transport to reduce the number of vehicles and by keeping them in good operating condition this risk can be reduced  Ensuring successful rehabilitation through monitoring will also reduce this risk  By ensuring that the plant rescue and relocation plan is implemented throughout the LoM will Loss of habitat integrity, species reduce this risk during closure. diversity and SCC Moderate - Low -  Using indigenous vegetation, removing AIP and Latent impacts of vegetation losses ensuring successful rehabilitation through monitoring will also reduce this risk. Compaction of soils Alteration of hydrological recharge paths/ natural drainage patterns leading to possible loss of recharge  Due to the flatness of the site erosion is not to down-gradient areas and impact expected to be of major concern. By ensuring on down-gradient biota Moderate - Low - successful rehabilitation and if identified early Increased sedimentation and through monitoring, it is relatively easy to erosion address. Disruption and loss of habitat of the aquatic ecology of the impacted watercourses  By installing appropriate pollution control dams and clean and dirty water separation and by designed and managing contaminated runoff Contaminant migration away from Moderate - Low - from the WRD (potentially by lining the WRD) remaining pollution sources (WRD) the potential for contamination is reduced thereby reducing the consequence and likelihood.  Through the compilation and continual updating Contamination of the catchment by of groundwater model/s and by implementing decant and impact on surrounding the identified closure strategies the residents and surface water users High - High - consequence and likelihood of this risk can be and a decrease in quality of managed. groundwater baseflow contribution  Water may also need to be treated before it is to the downstream watercourse discharged.

Project Name: ERPM Extension 2 Mine 43 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

 This impact is difficult to mitigate but can be managed by establishing a Future Forums, providing information and counselling for Increased unemployment rate in retrenched employees to promote their the area due to downscaling and High - Moderate - absorption into the labour market and by retrenchment offering a post retrenchment programme designed to equip retrenchees with knowledge and skills.  Due to the depth of the proposed mine there is not expected to be any risk of subsidence. Potential decline in community  Through implementing the closure strategies, health and safety (Dust, subsidence Moderate - Low - the shafts are to be adequately sealed; all etc) surface infrastructure is to be dismantled and removed from site and no waste is to remain on site will reduce this risk  Shaping the WRD to achieve stabilisation and to WRD to remain leading to a blend in with the natural topography and by permanent change in the visual Moderate - Low - establishing vegetation on the crests and areas character of the area where infrastructure is removed will reduce this risk.

9.1 Outcomes

As indicated in the table above, if the closure strategies (as detailed in Section 8) are achieved through the implementation of the actions described, the overall significance of the majority of closure-related risks identified can be suitably managed to an acceptable degree (Low). The following latent or residual risks were, however, identified which will be further evaluated in the Environmental Risk Assessment Report:

 Contaminant migration away from any remaining pollution sources (WRD);  The risk of groundwater decanting on surface and the associated contamination of the catchment and impact on surrounding residents and surface water users and a decrease in quality of groundwater baseflow contribution to the downstream watercourse; and  The socio-economic risks associated with mine closure.

Project Name: ERPM Extension 2 Mine 44 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

10. ORGANISATIONAL CAPACITY

10.1 Responsibilities

Closure and rehabilitation will be the ultimate duty of the Mine Manager under guidance of a multidisciplinary team, with input from the various mine technical disciplines including engineering and mining, mine surveyor, Safety Health and Environment Quality (SHEQ), the social department and the finance section.

As the mine approaches closure, mine closure will be approached as a project with a dedicated team to ensure the implementation of the plan. The project team will be responsible for appointing and managing suitable subcontractors to implement the physical work.

Closure and rehabilitation responsibilities must be carried out under the supervision of a suitably qualified Environmental Control Officer (ECO) to ensure that the various closure and rehabilitation actions detailed herein are implemented and that the necessary monitoring and reporting is conducted (refer to Section 11). The ECO should be suitably qualified to fulfil the responsibilities. The ECO will also be responsible for employing the relevant suitably qualified specialists to conduct monitoring and audits as required.

10.2 Training

Training and capacity building of employees of the mine who may be able to assist in the facilitating the closure of the mine will be undertaken through the various training structures.

The ECO will also be responsible for training and supervising the staff to be employed to undertake decommissioning and rehabilitation activities to ensure competence in appropriate closure and rehabilitation measures. Staff will undergo environmental awareness training as part of induction prior to the commencement of decommissioning activities, and copies of the EMPr, this plan, Environmental Awareness Plan and Emergency Preparedness and Response Plan will be provided to all staff.

Project Name: ERPM Extension 2 Mine 45 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

11. MONITORING AND REPORTING

11.1 Closure Monitoring

A closure period of five years is assumed to account for decommissioning and rehabilitation. This is a period of maintenance and monitoring of the areas that would have been associated with the various project related structures and infrastructure. The activities are limited to monitoring activities and limited erosion and vegetation repair if necessary.

The objective of the closure and rehabilitation monitoring programme will be to track the recovery of the mining area towards the long-term post-closure land use goals, in accordance with the overall closure objectives.

The closure and rehabilitation monitoring programme has been designed to collect information to demonstrate that the relinquishment criteria (refer to Table 7) have been achieved and the anticipated closure and post closure monitoring is addressed in Table 6 below. Post-closure monitoring and maintenance is also addressed in the Environmental Risk Assessment Report.

Table 6: Closure and post closure monitoring Monitoring Description Scheduling aspect  Monitor dust fallout (Quantity in mg to calculate  Annually throughout winter (3-month dust fallout rate in mg/m2/day) survey)  NO2, SO2 and BTEX concentrations Air Quality  Annually in winter (one-month survey)  Continuous Particulate Matter (PM10, PM2.5, in  Annually in winter (one-month survey, mg/m3 Wind direction & Wind speed) coincident with continuous PM) at the proposed monitoring locations  A representative sample of each stockpile must be analysed after stockpiling and prior to rehabilitation to determine the nutrient status and chemistry of the utilisable materials.  A soil contamination assessment must be carried out. Soil analyses should include pH, EC and the metals, metalloids, hydrocarbons and anions as listed in terms of the “SSV from  At mine closure, prior to rehabilitation Soil and GN331 of 2014 National Norms and Standards activities commencing erosion for the Remediation of Contaminated Land and monitoring Soil Quality” to determine if there are any exceedances relative to the SSV 2 – Commercial and Industrial guidelines. If exceedances are found then appropriate remediation measures must be implemented such that the soil quality is in line with the planned land use for the area.  All areas susceptible to erosion must be monitored and repair, maintenance and  Annually for at least two growing seasons prevention measures implemented. Surface water  Monitor for at least 5 years after mine quality  Against parameters as required by the WUL closure monitoring To monitor the contaminant migration Parameters and elements to be monitored should Groundwater  Monitor quality and levels quarterly for at comply with the WUL and other guidelines. It is monitoring least 5 years after mine closure recommended that the monitoring program include:  General chemistry such as pH, TDS and EC;

Project Name: ERPM Extension 2 Mine 46 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

Monitoring Description Scheduling aspect  Major elements such as calcium, magnesium, sodium, potassium, sulphate, nitrate, fluoride, chloride, phosphate;  An ICP scan of minor elements including aluminium, arsenic, barium, boron, bismuth, cadmium, copper, chrome (total), cyanide, iron, manganese, mercury, molybdenum, nickel, lead, antimony, selenium, vanadium and zinc. Rehabilitation efforts must be implemented and monitored for a period of at least five years  The immediate surrounding area (50m from the after decommissioning and closure perimeters) should be regularly checked during the decommissioning phase for alien vegetation A six monthly monitoring report to be compiled proliferation to prevent spread into surrounding during the rehabilitation phase and annually Vegetation natural areas. for at least 3 years post rehabilitation. The and wetland  The AIP control plan must be implemented until report should include as a minimum: monitoring indigenous basal cover is sufficient to prevent  List of observed species within the wetland proliferation of AIPs and terrestrial zones;  Monitor wetland and terrestrial vegetation zones  Photos of species and densities throughout during rehabilitation the construction and rehabilitation phases;  Wetland PES; and  Changes in wetland structure and extent. Maintained together with findings, follow up actions Photographic and close out records as part of the Environmental Per monitoring occasion above records Management System

11.1.1 Reporting

The following external reporting requirements apply to the monitoring programme:

 Water monitoring reports must be prepared (including recommendations as to whether treatment is required) by the relevant specialist for each monitoring survey.  Soil and erosion monitoring reports must be prepared (including recommendations) by the relevant specialist for each monitoring survey.  Vegetation monitoring reports (including photographs of the species identified as well as appropriate eradication measures for any AIP species) must be prepared by a botanist.  Photographic records should be maintained together with findings, follow up actions and close out records as part of the Environmental Management System.

11.1.2 Internal

 A record of all rehabilitation and closure requirements and actions should be kept by the ECO. If monitoring records indicate that closure risks are being realized, the appropriate specialist should be consulted and the recommended management measures implemented.  A closure report must be prepared by the ECO, including all of the monitoring data recorded. This must be submitted to the DMR. Closure reporting by the ECO must include whether the relinquishment criteria have been achieved. Refer to Table 7 below for the relinquishment criteria and indicators. Recommendations for additional actions to be taken, where relinquishment criteria have not been achieved, must also be included in the report.

Project Name: ERPM Extension 2 Mine 47 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

Table 7: Relinquishment criteria for the closure of ERPM Ext 2 Mine Environmental Relinquishment criteria Indicators Reporting requirements attribute Dust generation is decreasing as Ensure that dust is not being generated from vegetation is establishing in rehabilitated Dust monitoring reports compiled by a qualified air quality Air Quality wind erosion across rehabilitated areas areas; dust levels are within acceptable specialist limits All disturbed habitat areas rehabilitated to reflect Adequate rehabilitation and reseeding with Monitoring reports compiled by qualified botanist confirming Biodiversity / natural areas (improved state compared to an indigenous seed mixture to ensure that rehabilitation has been with indigenous species to promote Vegetation baseline). faunal habitat is re-instated biodiversity and AIP eradication has taken place Developing a landform that is free draining, with No pooling is occurring within the Photographic evidence taken after large rainfall events to established, self-sustaining vegetation rehabilitated site indicate that no pooling is occurring If decant occurs it is treated to qualities stipulated No flooding or erosion taking place; Water resources by DWS prior to discharge and discharged to the monitoring of surface water shows no Surface water monitoring reports compiled by a qualified environment in a manner that prevents flooding negative impact on surface water specialist. and erosion. resources. The area is stable; the shafts are Structural integrity risk assessments undertaken at adequately sealed; all surface decommissioning and signed off by an appropriately qualified Safety Ensuring community safety infrastructure is dismantled and removed engineer; photographic evidence of the sealed shafts and from site; no waste remains on site rehabilitated stable areas; and waste disposal certificates No erosion taking place; area has the Ensuring that the land is acceptable for the end Soil and Land capacity to withstand long-term wind and Photographic evidence of land returned to planned end land land use in line with planning objectives (i.e. Capability water erosion; land capability rendered use and no erosion taking place industrial and large commercial development) suitable for the planned end land uses All surface infrastructure is dismantled and Photographic evidence of removal of all surface Developing a landscape that is aesthetically removed from site; no waste remains on infrastructure; an inconspicuous and rehabilitated project acceptable in relation to the existing landscape site; the landscape is inconspicuous in site; safe waste disposal certificates; and close-out reports Aesthetic relation to the existing landscape quality Slope stability of permanent WRD is vegetated, does not contribute to poor embankments; capacity of drainage Photographic evidence and report of assessment of run-off water quality, its stability is not systems; leaching of harmful substances rehabilitated WRD. compromised and erosion is not observed. is not occurring.

Project Name: ERPM Extension 2 Mine 48 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

11.2 Liability Assessment

As per Section 24(P)(3) of NEMA, ERPM Ext 1 must annually assess their environmental liability and, if circumstances so require, must adjust their financial provision to the satisfaction of the Minister responsible for Mineral Resources. The process for annual review of financial provision is outlined in Regulation 12 of the NEMA Financial Provisioning Regulations (GN667 of 2019).

The annual review and assessment must be undertaken by a specialist with a view to re-assessing the environmental impacts, closure objectives and sustainable end state of land to determine the appropriateness of the mitigation and rehabilitation measures, the acceptability of the risks and the adequacy of the financial provision.

On completion of the above actions the financial provision must be confirmed or adjusted and within 30 days of receipt of the findings of the specialists regarding the review and re-assessment, the holder must set aside the adjusted financial provision and submit the findings including the following to the Minister for approval:

 reviewed and amended annual rehabilitation plan  confirmation of the adequacy of the financial provision or the adjusted financial provision  reviewed and amended final rehabilitation, decommissioning and mine closure plan  reviewed and amended environmental risk assessment report  proof of payment of the adjusted financial provision or the amended guarantee

The holder must ensure that the results of the reviews, confirmations or adjustments of the adequacy of the financial provision must be audited by an independent auditor, included in the form of an auditor’s report and submitted for approval to the Minister.

As this is the initial plan compiled to align with the requirements of GN667 of 2019 there are no updates or amendments as yet. This plan is to be audited annually and updated when necessary (i.e. progressive rehabilitation takes place, changes in the mine layout or description occur, additional potential risks arise, additional closure actions are required and/ or adjustments are made to the financial provision).

11.3 Additional Legislative Requirements

In terms of current legislation, within 180 days of the cessation of mining operations, an application for a closure certificate, in terms of Regulation 43 of the MPRDA, must be submitted to the DMR. This application must be accompanied by the required information, programmes, plans and reports prescribed in terms of the MPRDA and NEMA including a Final Performance Assessment of the site, this plan, and an Environmental Risk Report.

After the application has been submitted, an application for Environmental Authorisation (EA) in terms of NEMA, as per the NEMA EIA Regulations (GN982 of 2014 as amended), must be applied for as the decommissioning of any activity requiring a closure certificate in terms of Regulation 43 of the MPRDA is a listed activity in terms of the NEMA EIA Listing Notice 1 (GN983 of 2014 as amended). Upon approval of the EA, decommissioning, rehabilitation and closure activities may commence. The associated EMPr and Closure Plan is required to be audited, the frequency of which will be stipulated in the EA.

Project Name: ERPM Extension 2 Mine 49 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

12. QUANTUM FOR CLOSURE-RELATED FINANCIAL PROVISION

As per GN1147 of 2015 and GN667 of 2019 the financial provision must be determined through a detailed itemisation of all activities and costs based on actual market related rates for implementing activities for annual rehabilitation, final rehabilitation, decommissioning and closure and remediation of latent or residual environmental impacts. Costs must be calculated for the rehabilitation, remediation, maintenance and long- term monitoring activities undertaken by a third party. The degree of accuracy of the costs is dependent on the time to the end of life of the mine, with the accuracy of -50% to +50% for the end of operation > 30 years from the year of assessment.

The total quantum for closure-related financial provision in terms of the above has been determined for all of the proposed infrastructure and activities (R 137,280,940, refer to Table 8).

As per GN667 of 2019, the determination of the financial provision for new operations must include the costs associated with rehabilitation and management of impacts arising from:

 The anticipated disturbance of the first year of mining operations;  The residual and latent impacts associated with the anticipated disturbance for the first year of mining operations; and  The impacts of inflation on the costs of a third-party closure.

Therefore, in order to calculate the costs to be set aside by ERPM Ext 1 for rehabilitation, decommissioning and mine closure of ERPM Ext 2, which is a new operation, the following formula was used (refer to Table 9):

Total 1 + Total 2 = sum (1 + CPI plus 2%) x VAT

 Total 1 reflects the costs calculated in the final rehabilitation, decommissioning and mine closure plan for the rehabilitation and impact management related to the disturbance that will occur in the first year of the operation; and  Total 2 reflects the costs calculated in part 2 of the risk assessment report for the determination of residual and latent liability, which are the costs calculated for the management and rehabilitation of residual and latent impacts that are expected to manifest in the future based on an unscheduled closure on the anticipated disturbed area for the first year of operation.

The Guideline for Evaluation of the Quantum for Closure-Related Financial Provision compiled by the then Department of Minerals and Energy (DME) (now DMR) was used to inform the itemised breakdown. The guideline rates were however adjusted using market related contractor rates to provide actual costs for decommissioning and rehabilitation.

Identification of the extent of the disturbance through measurement of areas, volumes and lengths of proposed infrastructure and developments for each applicable closure component were calculated using the proposed high level mine plan. Since ERPM Ext 2 is a new mine and the construction stage will take approximately 6 years, the closure plan currently includes the costs for the rehabilitation of the activities which are planned for the first year of construction only:

Project Name: ERPM Extension 2 Mine 50 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

 Removal of access roads – rip, doze and shape roads, placement of topsoil and establishment of vegetation  Removal and rehabilitation of buildings – Dismantling and removing of buildings, rip levelled land, and vegetation establishment  Sealing of shaft B – Remove associated infrastructure, seal shaft  Rehabilitation of WRD – profiling of disturbed areas, and establishment of vegetation on dump  Rehabilitation of PCD – removal and disposal of single HDPE liner, backfilling of the final void, profiling and establishment of vegetation  General rehabilitation – general ripping, profiling of disturbed areas, establishment of vegetation and reinstatement of drainage lines  Removal of fences – dismantling of security fence.

The financial provision for the final rehabilitation, decommissioning and closure (Total 1, refer to Table 9) of the mining activities related to the disturbance that will occur in the first year of operation of the proposed ERPM Ext 2, has been calculated to be R 7,384,237.

The financial provision for the residual environmental impacts (Total 2, refer to Table 10) that are expected to manifest in the future based on an unscheduled closure on the anticipated disturbed area for the first year of operation is calculated as R 1,062,818.

The total amount to be set aside for closure and rehabilitation of the activities proposed in the first year of operation of the proposed ERPM Ext 2 (Total 1 + Total 2 = sum (1 + CPI plus 2%) x VAT), is R 8,447,055.

Project Name: ERPM Extension 2 Mine 51 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

Table 8: Total Quantum for Closure Related Financial Provision for the proposed ERPM Ext 2 Mine

Provision for final rehabilitation, decommissioning and mine closure plan Closure Main Description (as Relevant Component (As per contractor Component Description Unit Rate Quantity Total 2019 per DME Guideline) rates) No. Dismantling of Refrigeration plant, Water treatment 1 processing plant and Light/Medium plant structures m2 R 268.08 7557 R 2,025,845 plant and grout plant at Windmill related structures General Steel Structures, pump Fans at Witpoortje m2 R 1,284.75 50 R 64,238 station, extractor fans Demolish and remove from site Demolition of steel Shaft B 50m headgear at Windmill m3 R 4,707.90 20350 R 95,805,765 (Super) 2(A) buildings and Steel structures (permanent shed structures Workshops and stores at Windmill m2 R 60.72 2194 R 133,223 type) 0m – 5m high Cost to remove above ground Diesel Fuel storage facility at Windmill no R 2,144.71 1 R 2,145 tanks and oils Remove concrete liner from dam PCD at Windmill m3 R 565.05 156.75 R 88,572 Medium concrete thickness between Winder house floor at Windmill m3 R 748.41 903.75 R 676,375 Demolition of 750 and 250 mm reinforced concrete Light concrete thickness less than Refrigeration plant, Water treatment 2(B) m3 R 426.23 1889.25 R 805,259 buildings and 250 mm plant and grout plant at Windmill structures Bases and floors after removal of Shaft B headgear at Windmill m2 R 245.23 407 R 99,808 super structures Water Tanks and bund walls 2 Water storage tanks at Windmill m2 R 261.69 1748 R 457,437 Rehabilitation of 3 Gravel road with engineered surface Access roads at Windmill and Witpoortje m2 R 19.66 31015 R 609,736 access roads Administrative buildings, Change house m2 R 437.81 5130 R 2,245,986 Demolition of Demolition of housing and/or and Lamp house at Windmill housing and/or administration facilities Winder house and Explosives handling at 5 m2 R 411.23 1748 R 718,830 administration Windmill facilities Substation 2 at Windmill and 1 at Witpoortje m2 R 483.38 2594 R 1,253,890 Sealing of shafts, 7 5 m diameter Shaft B and Vent shaft no R 2,262,923.28 2 R 4,525,847 adits and inclines Rehabilitation of 8(A) overburden and WRD re-shaping and profiling WRD at Windmill ha R 149,539.08 2.1638 R 323,573 spoils Platforms and Waste Rock WRD at Windmill ha R 334,244.50 2.1638 R 723,238 Ripping of footprint areas (general - General surface Windmill and Witpoortje ha R 17,516.40 7 R 122,615 rehabilitation, dozer with 3 ripper tines to 500mm) 10 3 including grassing of Compaction Windmill and Witpoortje m R 15.09 10000 R 150,914 all denuded areas Establishment of vegetation SDA at Windmill and Witpoortje ha R 37,552.98 13.2558 R 497,795 Eradication of exotic vegetation SDA at Windmill and Witpoortje ha R 17,516.40 2 R 35,033

Project Name: ERPM Extension 2 Mine 52 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

Clean up area/tank (each) Diesel Fuel storage facility at Windmill m2 R 52.31 104 R 5,440 tanks and oils Fence surrounding Windmill and 12 Fencing Dismantling of security fencing m R 61.29 1816 R 111,299 Witpoortje SUM OF CLOSURE COMPONENT COSTS R 111,482,862 SUM OF CLOSURE COMPONENT COSTS (1+CPI plus 2%) R 118,450,541 ADD VAT R 17,767,581 PROVISION FOR FINAL REHABILITATION, DECOMMISSIONING AND MINE CLOSURE R 136,218,122

Provision for residual environmental impacts which will occur in the future Care and maintenance (Low intensity) ha/yr R 1,337.67 13.2558 R 17,732 Surface water no R 4,848.84 80 R 387,907 2-3 years of Groundwater no R 4,760.73 80 R 380,859 14 maintenance and Dust closure monitoring no R 5,231.00 2 R 10,462 aftercare Erosion monitoring no R 5,231.00 5 R 26,155 Implement erosion control measures ha R 11,677.60 4 R 46,710 SUM OF CLOSURE COMPONENT COSTS R 869,825 SUM OF CLOSURE COMPONENT COSTS (1+CPI plus 2%) R 924,189 ADD VAT R 138,628 PROVISION FOR RESIDUAL ENVIRONMENTAL IMPACTS WHICH WILL OCCUR IN THE FUTURE R 1,062,818

TOTAL COST OF CLOSURE AND REHABILITATION R 137,280,940

Project Name: ERPM Extension 2 Mine 53 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

Table 9: Costs to be set aside for final rehabilitation, decommissioning and closure associated with the anticipated disturbance for the first year of operations at the proposed ERPM Ext 2 Mine

Provision for final rehabilitation, decommissioning and mine closure plan Closure Main Description (as per Relevant Component On-site (As Component Description Unit Rate Quantity Total 2019 DME Guideline) per contractor rates) No. Demolition of steel Cost to remove above ground Diesel 2(A) buildings and Fuel storage facility at Windmill no R 2,144.71 1 R 2,145 tanks and oils structures Demolition of reinforced concrete 2(B) Remove concrete liner from dam PCD at Windmill m3 R 565.05 156.75 R 88,572 buildings and structures Rehabilitation of Access roads at Windmill and 3 Gravel road with engineered surface m2 R 19.66 31015 R 609,736 access roads Witpoortje Demolition of housing and/or Administrative buildings, Change m2 R 437.81 1000 R 437,814 Demolition of housing administration facilities house and Lamp house at Windmill 5 and/or administration Demolition of housing and/or Explosives handling at Windmill m2 R 411.23 543 R 223,298 facilities administration facilities Substation 2 at Windmill and 1 at Witpoortje m2 R 483.38 2594 R 1,253,890 Sealing of shafts, 7 5 m diameter Shaft B no R 2,262,923.28 1 R 2,262,923 adits and inclines Rehabilitation of 8(A) WRD re-shaping and profiling WRD at Windmill ha R 149,539.08 0.5 R 74,770 overburden and spoils Platforms and Waste Rock WRD at Windmill ha R 334,244.50 0.5 R 167,122 Ripping of footprint areas (general - Windmill and Witpoortje ha R 17,516.40 7 R 122,615 General surface dozer with 3 ripper tines to 500mm) rehabilitation, Compaction Windmill and Witpoortje m3 R 15.09 10000 R 150,914 10 including grassing of Establishment of vegetation SDA at Windmill and Witpoortje ha R 37,552.98 13.2558 R 497,795 all denuded areas Eradication of exotic vegetation SDA at Windmill and Witpoortje ha R 17,516.40 2 R 35,033 Clean up area/tank (each) Diesel Fuel storage facility at Windmill m2 R 52.31 104 R 5,440 tanks and oils Fence surrounding Windmill and 12 Fencing Dismantling of security fencing m R 61.29 1816 R 111,299 Witpoortje SUM OF CLOSURE COMPONENT COSTS R 6,043,365 SUM OF CLOSURE COMPONENT COSTS (1+CPI plus 2%) R 6,421,076 ADD VAT R 963,161 PROVISION FOR FINAL REHABILITATION, DECOMMISSIONING AND MINE CLOSURE R 7,384,237

Project Name: ERPM Extension 2 Mine 54 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

Table 10: Costs to be set aside for residual and latent impacts associated with the anticipated disturbance for the first year of operations at the proposed ERPM Ext 2 Mine

Provision for residual environmental impacts which will occur in the future Closure Main Description (as per Component Description Unit Rate Quantity Total 2019 DME Guideline) No. Care and maintenance (Low intensity) ha/yr R 1,337.67 13.2558 R 17,732 Surface water no R 4,848.84 80 R 387,907 2-3 years of Groundwater no R 4,760.73 80 R 380,859 14 maintenance and aftercare Dust closure monitoring no R 5,231.00 2 R 10,462 Erosion monitoring no R 5,231.00 5 R 26,155 Implement erosion control measures ha R 11,677.60 4 R 46,710 SUM OF CLOSURE COMPONENT COSTS R 869,825 SUM OF CLOSURE COMPONENT COSTS (1+CPI plus 2%) R 924,189 ADD VAT R 138,628 PROVISION FOR RESIDUAL ENVIRONMENTAL IMPACTS WHICH WILL OCCUR IN THE FUTURE R 1,062,818

TOTAL COST OF CLOSURE AND REHABILITATION R 8,447,055

Project Name: ERPM Extension 2 Mine 55 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

13. GAPS AND ACTION PLAN

As this is the initial closure plan, compiled to align with the requirements of the enacted financial provisioning regulations, there are no updates or amendments as of yet. This document is to be audited and updated annually.

The current gaps and proposed actions and additional research that will be required to address these gaps are detailed in Table 11 below.

Table 11: Existing gaps within this final closure plan and proposed action plan Gaps Action plan to address knowledge gaps Timelines Lack of detailed surface ERPM Ext 1 is to finalise the mine design and plans so that the By the next financial layouts and underground closure plans can be updated accordingly. year mine plan Lack of understanding of  The potential for the WRD to be removed from surface should Once construction what volume of waste be investigated. commences rock will remain at  As operations continue, the volume of waste rock remaining at closure and risks closure will become clear and the financial implications for associated with the closure actions relating to the WRDs will be able to be more WRDs post closure accurately calculated and the risks associated with the WRDs (i.e. dust generation, seepage of contaminated runoff and visual impact) more accurately assessed. Lack of understanding of A detailed regional assessment of the different interconnected Once mining groundwater impacts mines and the geological information available from each of the commences and and potential decant post mines be done to assess: updated as required closure  The presence of geological structures connecting the thereafter underground mine to surface that could lead to decant on surface once the groundwater levels have recovered to near predevelopment levels;  The interconnection between the different mines in the area (ERPM Ext 2, ERPM Ext 1, the South East Vertical Shaft, the Hercules Shaft, the Central Shaft, the Rose Deep compartment, and others) and how that influences the decant potential, locality of expected decant points, decant volumes and decant qualities. Lack of understanding of Undertake an investigation into the social closure requirements of 5 years prior to the social impact of the mine. ERPM Ext 1 to consider the LED strategy for the area, known closure closure and investigate which useful infrastructure (i.e. roads, power lines and sewage treatment plants) are to remain in place post-closure for use by the surrounding communities. ERPM Ext 1 also to consider alternative uses for surface infrastructure e.g. office buildings which can be converted to a clinic to remain post-closure prior to the end of operations. The outcome of the investigation must be used to update this plan. ERPM Ext 1 must consult with the DMR, the landowners as well as surrounding communities regarding the infrastructure to remain in place post-closure to ensure all parties agree on the benefits of leaving the infrastructure in place. Lack of understanding of Annually review and re-assess the closure plans to better Annually the monitoring period understand the potential latent impacts and the monitoring period required for potential that will be required. latent impacts once operation begin

Project Name: ERPM Extension 2 Mine 56 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

14. CONCLUSION

Section 11 of the current NEMA Financial Provisioning Regulations (GN1147 of 2015 as amended), as well as Section 12 of the proposed NEMA Financial Provisioning Regulations (GN667 of 2019), requires that the holder of a right must, once per financial year, review and update the closure plans and reports, with a view to re-assessing the environmental impacts, closure objectives and sustainable end state of land to determine the appropriateness of the mitigation and rehabilitation measures, the acceptability of the risks and the adequacy of the financial provision.

The measures and recommendations made in this report serve to assist the holder of the Mining Right in responsibly and timeously planning for and implementing closure of the proposed ERPM Ext 2 Mine. This plan must be assessed annually and updated as necessary, with the end target being a closed mine having minimal residual impact on the environment or safety of people.

Within 180 days of the cessation of mining operations an application for a closure certificate, in terms of Regulation 43 of the MPRDA, must be submitted to the DMR. After the application has been submitted an application for EA in terms of NEMA must be applied for prior to commencing with decommissioning, rehabilitation and closure activities. No closure certificate may be issued unless each government department charged with the administration of any law which relates to any matter affecting the environment has confirmed in writing that the provisions pertaining to health and safety and management of pollution to water resources, the pumping and treatment of extraneous water and compliance to the conditions of the EA have been addressed. Notwithstanding the issue of a closure certificate, liability for the environmental degradation on the site remains the responsibility of the holder of the right.

An application to the DMR must be made to transfer the responsibility regarding the maintenance of the surface infrastructure to remain on site for use by the community, to the relevant authority post issuing of a closure certificate.

If the holder fails to rehabilitate or to manage any impact on the environment, or is unable to undertake such rehabilitation or to manage such impact, the Minister responsible for Mineral Resources may, upon written notice, use all or part of the financial provision to rehabilitate or manage the environmental impact in question.

The financial provision for the final rehabilitation, decommissioning and closure of the mining activities related to the disturbance that will occur in the first year of operation of the proposed ERPM Ext 2, has been calculated to be R 7,384,237.

The financial provision for the residual environmental impacts that could manifest in the future based on an unscheduled closure on the anticipated disturbed area for the first year of operation is calculated as R 1,062,818.

The total amount to be set aside for closure and rehabilitation of the activities proposed in the first year of operation of the proposed ERPM Ext 2, is R 8,447,055.

Project Name: ERPM Extension 2 Mine 57 Report Title: Final Rehabilitation, Decommissioning and Closure Plan Project number: 181020 Date: September 2019

ERPM EXTENSION AREA 1 (PTY) LTD

DRAFT ENVIRONMENTAL RISK ASSESSMENT REPORT FOR THE PROPOSED ERPM EXTENSION 2 MINE, PREPARED IN TERMS OF THE NEMA EIA REGULATIONS (GN982 OF 2014 AS AMENDED) AND THE NEMA FINANCIAL PROVISIONING REGULATIONS (CURRENT, GN1147 OF 2015 AND PROPOSED, GN667 OF 2019)

SEPTEMBER 2019

Prepared for:

ERPM Extension Area 1 (Pty) Ltd Unit 206 Alto Level House 4 Fir Drive Northcliff 2195

TABLE OF CONTENTS

1. INTRODUCTION ...... 1 1.1 Introduction ...... 1 1.2 Legislative requirements ...... 1 1.3 Details and Expertise of the EAP ...... 3 1.4 Details of the holder ...... 4 1.5 Details of rights, permits, licences and authorisations associated with the operation ...... 4 2. SUMMARY OF THE CLOSURE OBJECTIVES ...... 5 2.1 Closure Objectives ...... 5 3. ENVIRONMENTAL RISK ASSESSMENT ...... 6 3.1 Risk Assessment Methodology ...... 6 3.2 Risk Identification and Quantification ...... 6 4. MANAGEMENT AND MONITORING ACTIVITIES ...... 10 4.1 Monitoring...... 10 4.2 Maintenance Plan ...... 11 4.3 Alternatives ...... 11 4.4 Updates and Amendments ...... 12 5. QUANTUM FOR CLOSURE-RELATED FINANCIAL PROVISIONING ...... 13 6. CONCLUSION ...... 17

TABLES

Table 1: Latent Risks identified and potential drivers that could result in the manifestation of these risks after closure .. 7 Table 2: Latent Risks, timelines and triggers used to identify risks ...... 8 Table 3: Costs to be set aside for residual and latent impacts associated with the anticipated disturbance for the first year of operations ...... 15 Table 4: Costs to be set aside for final rehabilitation, decommissioning and closure associated with the anticipated disturbance for the first year of operations ...... 16

ACRONYMS

DME Department of Minerals and Energy DMR Department of Mineral Resources DWS Department of Water and Sanitation EIA Environmental Impact Assessment EMPr Environmental Management Programme Report LED Local Economic Development LoM Life of Mine MPRDA Mineral and Petroleum Resources Development Act (No. 28 of 2002) NEMA National Environmental Management Act (No. 107 of 1998) PCD Pollution Control Dam SAWQG South African Water Quality Guidelines SDA Surface Development Area WRD Waste rock dump

Project Name: ERPM Extension 2 Mine ii Report Title: Environmental Risk Assessment Report Project number: 181020 Date: September 2019

1. INTRODUCTION

1.1 Introduction

ERPM Extension Area 1 (Pty) Ltd (ERPM Ext 1), is a subsidiary of East Rand Proprietary Mines Limited (ERPM), and is an underground mining operation. ERPM’s operations have been established more than 100 years ago on the Witwatersrand basin, 10 km East of Johannesburg. ERPM had owned two contiguous mining rights - GP151MR and GP150MR. While GP151MR allows for both underground and surface activities, GP150MR only grants for underground mining. These mining rights have since been sold to ERPM Ext 1. In addition, ERPM Ext 1 holds a prospecting right (GP243PR) which it intends to convert into a Mining Right.

This document serves to fulfil the requirement of the National Environmental Management Act, No. 107 of 1998 (NEMA) Financial Provisioning Regulations (GN1147 of 2015 and GN667 of 2019) in terms of the Environmental Risk Assessment. As such, a review of the specialist studies was undertaken to identify the pre-mining environmental and social context, closure commitments, potential risks pertaining to closure, and the recommendations relating to closure.

The objective of the Environmental Risk Assessment report is to:

 ensure the timeous prediction and quantification of environmental risk associated with the operations;  ensure timeous risk reduction through appropriate interventions;  identify the potential residual and latent environmental risks which will manifest post closure:  detail the approach to managing post closure risks;  quantify the potential risks and liabilities associated with the management of the risks;  the quantification must be based on market related costs:  calculate a risk threshold and timeframe in which to reach the risk threshold; and  outline and cost the post closure monitoring, auditing and reporting requirements.

1.2 Legislative requirements

1.2.1 NEMA Regulations (GNR667 of 2019)

Section 2 of the Financial Provisioning Regulations (GN667 of 2019) states that (paraphrased) the purpose of these regulations is to:

a) establish the obligation of an applicant and holder to plan, manage and implement procedures and requirements to remediate and rehabilitate environmental damage caused by reconnaissance, exploration, prospecting, mining and production operations;

Project Name: ERPM Extension 2 Mine 1 Report Title: Environmental Risk Assessment Report Project number: 181020 Date: September 2019

b) regulate the manner in which an applicant or holder is to determine, provide, set aside, maintain and manage financial security for undertaking progressive rehabilitation, decommissioning, closure and post closure activities associated with reconnaissance, prospecting, mining, exploration and production operations; c) identify the circumstances under which the Minister may use the financial provision set aside to effect the obligation of the holder to remediate and rehabilitate negative environmental impacts and environmental damage; and d) ensure that the State does not become liable for those costs which should be covered by a holder and to facilitate environmentally sustainable mining.

Section 4 states that every applicant and holder has an obligation to plan, manage and implement such procedures and requirements in respect of progressive rehabilitation, closure and post closure activities related to a reconnaissance, prospecting, exploration, mining and production operations as identified in the annul rehabilitation plan, the final decommissioning and mine closure plan and the environmental risk assessment report for the determination of residual and latent liability for reconnaissance, prospecting, exploration, mining and production operations.

Section 6.2 states that an applicant or holder must determine the financial provision through a detailed itemisation of all activities and costs, based on actual market related rates for:

 implementing the activities for remediation and management of residual and latent environmental impacts, including the ongoing pumping and treatment of polluted or extraneous water, determined in an environmental risk assessment report conforming to the content requirements of Appendix 3.

This Environmental Risk Assessment serves to meet the requirements in terms of Section 6(2)(c), when read in conjunction with Appendix 3 of the Financial Provisioning Regulations, regarding an Environmental Risk Assessment, which must follow an iterative risk profiling approach which through modelling must predict environmental risk, identify their potential to manifest, the timeframes in which they will manifest and the costs associated with their management and rehabilitation once the impacts have manifested. The risk assessment process must calculate a risk threshold for the operations and predict the time period to reach the risk threshold.

As per Appendix 3 of the Financial Provisioning Regulations, an Environmental Risk Assessment report must include the following:

[Relevant GNR667 of 2019 section of this Minimum Content of an Environmental Risk Assessment document] (3)(1) Details of (1) the person or persons that prepared the plan: (2) the professional registrations and experience of the person or persons who prepared the plan; [1.3] (3) the applicant or holder including but not limited to: name; physical address; postal address. [1.4] contact details; and [1.5] (4) rights, permits, licences and authorisations associated with the operation including the right or permit number, environmental authorisation number, and similar details of all other authorisation received e.g. water use licence. waste licence etc. (3)(2) details of the assessment process used to identify and quantify the post closure, residual and possible latent risks, including - (1) description of the risk assessment methodology inclusive of risk identification and [3] quantification;

Project Name: ERPM Extension 2 Mine 2 Report Title: Environmental Risk Assessment Report Project number: 181020 Date: September 2019

[Relevant GNR667 of 2019 section of this Minimum Content of an Environmental Risk Assessment document] (2) substantiation why each risk will occur post closure, including why the risk was not or could not be mitigated during concurrent rehabilitation and remediation or during the implementation of the final rehabilitation, decommissioning and mine closure plan; (3) a detailed description of the drivers that could result in the manifestation of the risks after closure; (4) a description of the expected timeframe in which the risk is likely to manifest, typically as expected years after closure, and the duration of the impact, including motivation to support these timeframes; (5) a detailed description of the triggers which can be used to identify that the risk is imminent or has manifest, how this will be measured and any cost implications thereof; (6) results and findings of the risk assessment or risks which will occur post closure; (7) an explanation of changes to the risk assessment results as applicable in annual updates to Initial plan, no the plan; changes as yet (3)(3) Management activities, including - (1) monitoring of results and findings, which informs adaptive or corrective management and/or risk reduction activities; (2) an assessment of alternatives to mitigate or manage the impacts once the risk has become [4] manifested, which must be focussed on practicality as well as cost of the implementation; (3) motivation why the selected alternative is the appropriate approach to mitigate the impact; (4) a detailed description of how the alternative will be implemented; (3)(4) calculation of costs for implementing the activities to manage and monitor residual and latent impacts until the agreed risk threshold is reached using market related figures and the current value of money and no discounting or net present value calculations which must- (1) include costs to determine whether the risk is imminent or has manifest are to be included in the assessment as there are monitoring costs likely to be incurred during the implementation of the strategy to manage or mitigate the impact once the risk has become manifest; (2) be based on the management, rehabilitation, remediation. maintenance and long term monitoring of activities undertaken by a third party; (3) be calculated for the management rehabilitation; remediation, maintenance and long term monitoring of residual and latent impacts for all disturbed areas and associated environmental impacts; (4) include the costs for the management, rehabilitation, remediation, maintenance and long [5] lean monitoring of activities for residual and latent impacts must include cost assumptions and auditable calculations of costs per activity or infrastructure; (5) include the risk modelling and the calculation of post closure cost estimation must be updated annually during the operation's life to reflect known developments, including changes from the annual review of the closure strategy assumptions and inputs, scope changes; and (6) include the cost estimates for modelling and calculating the post closure costs must be calculated using accuracy estimations as follows: For end of life of operation >30 years to design effort is pre-conceptual/class 5 estimate/up to 2% of complete definition with a degree of accuracy in cost estimation of -50% to +50%.

1.3 Details and Expertise of the EAP

Project Name: ERPM Extension 2 Mine 3 Report Title: Environmental Risk Assessment Report Project number: 181020 Date: September 2019

1.4 Details of the holder

1.5 Details of rights, permits, licences and authorisations associated with the operation

Right / Licence / Authorisation Description Submitted with reference number: GP 30/5/1/2/2 10078 MR but not yet Mining Right (ERPM Extension Area 2) approved Environmental authorisation number Not yet approved Prospecting right (ERPM Extension Area 2) GP243PR (Expired) A Pre-Application Water Use Enquiry has been submitted to DWS via the Water Use Licence (ERPM Extension Area 2) e-WULAAS online system. Contiguous mining rights (ERPM and ERPM GP151MR and GP150MR Ext 1)

Project Name: ERPM Extension 2 Mine 4 Report Title: Environmental Risk Assessment Report Project number: 181020 Date: September 2019

2. SUMMARY OF THE CLOSURE OBJECTIVES

In order to assess where residual impacts may originate from or how they may be exacerbated the following relevant closure objectives and rehabilitation actions for the ERPM Ext 2 Mine must be considered. A detailed description of the closure objectives and rehabilitation actions can be found in the Final Rehabilitation Decommissioning and Closure Plan for the proposed ERPM Ext 2 Mine.

2.1 Closure Objectives

The current closure vision is to:

Project Name: ERPM Extension 2 Mine 5 Report Title: Environmental Risk Assessment Report Project number: 181020 Date: September 2019

3. ENVIRONMENTAL RISK ASSESSMENT

3.1 Risk Assessment Methodology

The following risk assessment methodology and rationale was used to assess the significance of the potential latent risks, following closure and rehabilitation of the ERPM Ext 2 Mine. This risk assessment is based on identifying potential latent risks which may manifest after the successful implementation of the closure activities of the mine. The criteria considered to determine a potential latent risk is provided below:

Insignificant latent risk

Environmental latent risk that will not be of concern after successful closure and rehabilitation activities have been completed. Insignificant risks must adhere to the following criteria:

 Nature / Intensity: No significant harm to the specific aspect of the environment after completion of closure and rehabilitation activities.  Spatial Extent: Risk does not extend past the immediate boundary of the site after completion of closure and rehabilitation activities.  Duration: Potential risk ceases to exist upon finalisation of closure and rehabilitation activities.  Probability: Likelihood of an impact materialising from the risk is very low.

Potential significant latent risk

Environmental latent risk that may arise after completion of closure activities. To be classified as a “potential significant risk”, the risk must fall into one or more of the following criteria:

 Nature / Intensity: There could be a detrimental impact on the environment after implementing closure.  Spatial Extent: Risk that could have an impact off site after completion of closure and rehabilitation activities.  Duration: Potential risk could continue to exist after closure and rehabilitation activities have ceased.  Probability: The likelihood exists of an impact occurring as a result of the risk.

3.2 Risk Identification and Quantification

Based on the above methodology, following closure of the ERPM Ext 2 Mine and rehabilitation of the mining area, the potential exists for the following Potential significant latent risks to occur post closure.

3.2.1 Contamination of water resources

When the mine is decommissioned it expected that the underground mining areas will slowly be inundated by groundwater. As the working areas and shafts are flooded, contaminants in the water will be mobilised and there is a possibility that these contaminants (probably acid generating) will be brought to the surface and decant into the surface water systems. This impact depends on the geology, aquifer characteristics and the interconnectivity of the various mines. If the water were to decant, it is possible that this may happen at the lowest point in the Eastern Basin, and not near the Surface Development Areas (SDAs).

Project Name: ERPM Extension 2 Mine 6 Report Title: Environmental Risk Assessment Report Project number: 181020 Date: September 2019

As a result of this decant, there is potential for a decrease in quality of groundwater baseflow contribution to the downstream watercourse causing and the associated reduction in surface water quality and subsequent negative impacts on biota and vegetation, altered flow regimes, and habitat degradation.

This risk can be diminished through the compilation and continual updating of groundwater model/s, by implementing the identified closure strategies, by planning for the discharge options for decant water at least 10 years prior to closure (including treatment and suitable water uses for the treated water) and by ensuring that there are sufficient funds for the management thereof.

There is also a risk of contaminant migration away from remaining pollution sources, which will be the WRD. By lining the WRD the potential for contamination is reduced thereby reducing the consequence and likelihood.

3.2.2 Socio-Economic Risks

At closure the unemployment rate in the area will increase as retrenchments will be required.

The provisions of the Social and Labour Plan (SLP) relating to minimising the negative impact of retrenchment must be implemented to mitigate this eventuality. Implement the Skills Development Plan (SDP) and measures regarding the management of downscaling and retrenchment as detailed in the SLP. This impact can be managed by establishing Future Forums, providing information and counselling for retrenched employees to promote their absorption into the labour market and by offering a post retrenchment programme designed to equip retrenchees with knowledge and skills.

Table 1 below presents a summary of the potential moderate latent or residual risks that were identified, as per the Final Rehabilitation, Decommissioning and Closure Plan, as well as the potential drivers that could result in the manifestation of these risks after closure.

Table 1: Latent Risks identified and potential drivers that could result in the manifestation of these risks after closure Why risk cannot be mitigated during concurrent rehabilitation or during implementation of Drivers that could result in the Latent Risk final rehabilitation, manifestation of the risks after closure decommissioning and mine closure plan The only way to completely Ongoing groundwater ingress and surface Contaminant migration away mitigate this risk is by removing runoff from WRD. from any remaining pollution the WRD which is not currently Continued rainwater ingress into the WRD sources (WRD) planned. after closure. Groundwater decanting on surface and the associated contamination of the catchment Dewatering of the mine is required Groundwater recharge after pumping and impact on surrounding in order to allow for the continued activities cease upon closure of the mine. residents and surface water mining activities. Upon mine Discharging mine polluted water into the users and a decrease in quality closure the underground workings surrounding water courses. of groundwater baseflow will be allowed to flood. contribution to the downstream watercourse The retrenchment of mine Socio-economic risks associated employees during decommissioning No Future Forums established. with mine closure or downscaling is unavoidable.

Project Name: ERPM Extension 2 Mine 7 Report Title: Environmental Risk Assessment Report Project number: 181020 Date: September 2019

Why risk cannot be mitigated during concurrent rehabilitation or during implementation of Drivers that could result in the Latent Risk final rehabilitation, manifestation of the risks after closure decommissioning and mine closure plan Lack of information and counselling provided to retrenched employees to promote their absorption into the labour market.

Absence of a of post retrenchment programme designed to equip retrenches with knowledge and skills.

Table 2 below gives a description of the expected timeframe in which these risks are likely to manifest after closure, the duration of the impact, and a description of the triggers which can be used to identify that the risk is imminent or has manifested.

Table 2: Latent Risks, timelines and triggers used to identify risks Triggers to Latent Risk Timelines Description identify the risk The plumes from the topsoil and the WRD footprint areas Pollution levels will merge over time as the plumes develop and extend identified within Contaminant approximately 450 to 500 m from the topsoil and WRD groundwater and migration The risk will manifest footprint areas. At 50 years post closure the contaminant surface water away from during the LoM in the plume is expected to extend approximately 800 m from monitoring any form of a pollution the WRD and topsoil footprint areas. By 80 to 90 years samples coupled remaining plume and could post closure the plume is expected to reach the with pollution continue for >90 unnamed, non-perennial tributary to the Rietspruit that implementing sources years post closure. lies to the south of the ERPM Ext2 mine area. The total modelling of the (WRD) salt load contribution to the stream is calculated to be migration of the 150 g/day. This is less than 1% of the total daily salt pollution plume. load in the stream. This risk will manifest The surface streams in the area are structurally during post controlled and water losses to those structures are decommissioning possible. This occurs throughout the Central Basin. phase when Therefore it is possible that decant from the mine can groundwater levels occur via these geological structures. Decant positions Contamination and flow patterns in can also be influenced by interconnection with the ERPM at and along the the underground Ext1 mine area, and by extension interconnection to the decant points mining area start to South East Vertical Shaft, the Hercules Shaft, the Central and in the recover to near pre- Shaft, the Rose Deep compartment, and others. Due to Groundwater associated operational levels the complexity of the karstic geology, the interconnection decanting streams. however it is not between different underground mines, and the internal Maintaining and expected that the operations of each of the mine in terms of plugging of updating the underground mine levels etc., it is not possible to currently identify decant water and salt area will be fully positions with the level of information that is available. It balance. submerged during is recommended that a detailed regional assessment of this time. The risk the different interconnected mines and the geological could continue for information available from each of the mines be done in >90 years post order to be able to identify decant positions and volumes closure. to an acceptable level of confidence. Socio- The retrenchment of mine employees during This risk will manifest Retrenchment of economic decommissioning or downscaling is unavoidable. The during closure of the mine employees risks impact of retrenchment and downscaling can be operation. The risk during associated mitigated by implementing the measures in the SLP could continue for >5 decommissioning with mine relating to employee education and upskilling to mitigate years post closure. or downscaling closure the impacts of unavoidable job losses:

Project Name: ERPM Extension 2 Mine 8 Report Title: Environmental Risk Assessment Report Project number: 181020 Date: September 2019

Triggers to Latent Risk Timelines Description identify the risk • Establishment of Future Forums; Unrest in the • Provide information and counselling for surrounding retrenched employees to promote their communities absorption into the labour market; • Offer a post retrenchment programme designed to equip retrenches with knowledge and skills.

Project Name: ERPM Extension 2 Mine 9 Report Title: Environmental Risk Assessment Report Project number: 181020 Date: September 2019

4. MANAGEMENT AND MONITORING ACTIVITIES

Within 180 days of the cessation of mining operations, an application for a closure certificate in terms of Regulation 43 of the MPRDA must be submitted to the DMR. After the application has been submitted, an application for Environmental Authorisation in terms of NEMA must be applied for prior to commencing with decommissioning, rehabilitation and closure activities.

A post closure monitoring and maintenance period of five (5) years after decommissioning and closure has been assumed. However, this may change based on the Environmental Authorisation process. The Competent Authority (CA) will ultimately determine the applicable period required for monitoring and maintenance.

The closure and rehabilitation monitoring programme has been designed to collect information to demonstrate that the relinquishment criteria have been achieved.

4.1 Monitoring

4.1.1 Water Monitoring Programme

 Monitoring of surface water quality must take place on a monthly basis throughout the LoM and annually for five years post-closure. o Analysis must include: pH; Electrical Conductivity; Total Suspended Solids; Total Hardness; Total Alkalinity; Na; K; Ca; Mg; Cl; F; SO4; NO3; NH4; Fe; Mn and; U. On a biannual basis the following will also be analysed Al; Sb; As; Ba; B; Cd; Cr; Co; Pb; Hg; Ni; Cu; Se; Fe; Mn; V and; Zn.

 Boreholes will be monitored for groundwater level and water quality quarterly at least five years post-closure. o Analysis must include: pH, TDS and EC, Major elements such as calcium, magnesium, sodium, potassium, sulphate, nitrate, fluoride, chloride, phosphate and Minor elements including aluminium, arsenic, barium, boron, bismuth, cadmium, copper, chrome (total), cyanide, iron, manganese, mercury, molybdenum, nickel, lead, antimony, selenium, vanadium and zinc.

4.1.2 Reporting

The ECO in conjunction with specialists must compile reports post rehabilitation at the timeframes described above for a period of 5 years. The reports must be based on the findings of disturbed and rehabilitated areas such the WRD, access roads and where infrastructure was located (including the before and after photographs and recommended management measures if required). The following requirements apply to the monitoring programmes:

 A report must be prepared by the specialist after each monitoring survey. If monitoring objectives are not met, the ECO will be responsible for reporting the findings to management who must then discuss mechanisms to reduce the impact, measure the effectiveness of management measures,

Project Name: ERPM Extension 2 Mine 10 Report Title: Environmental Risk Assessment Report Project number: 181020 Date: September 2019

and where necessary, intervene further. The effectiveness of additional measures will be assessed through further monitoring.  The report must be submitted to management to ascertain compliance with the required standards at sensitive receptors.  An annual report (including photographs and recommended management if required) must be made available incorporating the monitoring results. Trends must be identified and mitigation measures recommended where necessary.  A record of all rehabilitation requirements and actions should be kept by the ECO. If monitoring records indicate that closure risks are being realised, the appropriate specialist should be consulted and the recommended management measures implemented.  Any requests by the competent authority or other departments for provision of reports must be adhered to.

4.2 Maintenance Plan

A detailed description of the rehabilitation actions to be implemented at closure can be found in the Final Rehabilitation Decommissioning and Closure Plan. It is assumed that these closure measures will be implemented effectively. Post closure monitoring, as described in Section 4.1, will assist in determining the success of the closure rehabilitation actions. Should rehabilitation of an area be unsuccessful or poorly implemented, maintenance measures may be required. Maintenance measures should primarily be passive in nature with minimal long-term maintenance and operating costs. Maintenance which may be required until intervention achieves the necessary relinquishment criteria includes:

 Fertilising rehabilitated areas should a botanist indicate that vegetation establishment has not be successful;  Eradication of alien invasive vegetation, as per the eradication plan to be compiled by a botanist;  Erosion repair and, where required, the implementation of additional erosion protection measures (e.g. contours, berms, energy dissipaters such as gabions and application of straw mulches or soil binders to exposed soils); and  Measures to prevent water resource contamination, if required which may include erosion management, separation of clean and dirty water or the implementation of engineered impermeable barriers.

4.3 Alternatives

Although the shafts will be sealed during the closure phase, post closure, the land use at the Windmill Shaft (specifically around the sealed shafts and WRD) will not be appropriate for urban development due to potential safety concerns. The proposed final end land use for the disturbed areas is industrial and / or large commercial development or low intensity grazing and/or wilderness.

Alternative post closure land uses have been identified, taking the mine’s location into consideration. Due to the necessity of landowners, municipality and/ or other developers’ interest, it is recommended that within the next year these alternatives need to have been discussed with stakeholders.

Future land use alternatives identified are as follows:

Project Name: ERPM Extension 2 Mine 11 Report Title: Environmental Risk Assessment Report Project number: 181020 Date: September 2019

4.4 Updates and Amendments

As this is the initial plan compiled to align with the requirements of the regulations (GN1147 of 2015 and GN667 of 2019) there are no updates or amendments as yet. This document must be audited annually and updated when necessary (i.e. changes in the mine layout or description occur thus affecting the identified potential latent risks, additional potential latent risks arise).

Project Name: ERPM Extension 2 Mine 12 Report Title: Environmental Risk Assessment Report Project number: 181020 Date: September 2019

5. QUANTUM FOR CLOSURE-RELATED FINANCIAL PROVISIONING

The total quantum for closure-related financial provision in terms of the above has been determined for all of the proposed infrastructure and activities (R 137,280,940, refer to Table 3).

As per GN667 of 2019, the determination of the financial provision for new operations must include the costs associated with rehabilitation and management of impacts arising from:

Therefore, in order to calculate the costs to be set aside by ERPM Ext 1 for ERPM Ext 2, which is a new operation, the following formula was used:

Total 1 + Total 2 = sum (1 + CPI plus 2%) x VAT

Identification of the extent of the disturbance through measurement of areas, volumes and lengths of proposed infrastructure and developments for each applicable closure component were calculated using the proposed high level mine plan. Since ERPM Ext 2 is a new mine and the construction stage will take approximately 6 years, the risk assessment currently includes the costs for the management and rehabilitation of the following residual and latent impacts that could manifest in the future based on an unscheduled closure on the anticipated disturbed areas (access roads, buildings, Shaft B footprint, WRD and PCD) that are planned for the first year of operation:

 Care and maintenance (including biodiversity and revegetation monitoring);  Surface water monitoring;  Groundwater monitoring;  Dust closure monitoring;

Project Name: ERPM Extension 2 Mine 13 Report Title: Environmental Risk Assessment Report Project number: 181020 Date: September 2019

 Erosion monitoring; and  Implementation of erosion control measures.

The financial provision for the residual environmental impacts (Total 2, refer to Table 3) that are expected to manifest in the future based on an unscheduled closure on the anticipated disturbed area for the first year of operation is calculated as R 1,062,818.

The financial provision for the final rehabilitation, decommissioning and closure (Total 1, refer to Table 4) of the mining activities related to the disturbance that will occur in the first year of operation of the proposed ERPM Ext 2, has been calculated to be R 7,384,237.

Project Name: ERPM Extension 2 Mine 14 Report Title: Environmental Risk Assessment Report Project number: 181020 Date: September 2019

Table 3: Costs to be set aside for residual and latent impacts associated with the anticipated disturbance for the first year of operations

Provision for residual environmental impacts which will occur in the future Closure Main Description (as per Component Description Unit Rate Quantity Total 2019 DME Guideline) No. Care and maintenance (Low intensity) ha/yr R 1,337.67 13.2558 R 17,732 Surface water monitoring no R 4,848.84 80 R 387,907 2-3 years of Groundwater monitoring no R 4,760.73 80 R 380,859 14 maintenance and aftercare Dust closure monitoring no R 5,231.00 2 R 10,462 Erosion monitoring no R 5,231.00 5 R 26,155 Implement erosion control measures ha R 11,677.60 4 R 46,710 SUM OF CLOSURE COMPONENT COSTS R 869,825 SUM OF CLOSURE COMPONENT COSTS (1+CPI plus 2%) R 924,189 ADD VAT R 138,628 PROVISION FOR RESIDUAL ENVIRONMENTAL IMPACTS WHICH WILL OCCUR IN THE FUTURE R 1,062,818

TOTAL COST OF CLOSURE AND REHABILITATION R 8,447,055

Project Name: ERPM Extension 2 Mine 15 Report Title: Environmental Risk Assessment Report Project number: 181020 Date: September 2019

Table 4: Costs to be set aside for final rehabilitation, decommissioning and closure associated with the anticipated disturbance for the first year of operations

Project Name: ERPM Extension 2 Mine 16 Report Title: Environmental Risk Assessment Report Project number: 181020 Date: September 2019

6. CONCLUSION

This document serves as an Environmental Risk Assessment Report for potential latent risks and residual environmental impacts that could occur post closure. However, this document must be assessed annually and updated as necessary, with the end target being a closed mine having minimal residual impact on the environment or safety of people.

Without effective management or rehabilitation (as detailed in the Final Rehabilitation, Decommissioning and Closure Plan) most potential residual impacts would have a high or moderate significance, but if rehabilitation is implemented effectively many of the residual impacts could be avoided or sufficiently mitigated so as to reduce them to a lower significance.

The total amount to be set aside for closure and rehabilitation of the activities proposed in the first year of operation of the proposed ERPM Ext 2, is R 8,447,055.

Project Name: ERPM Extension 2 Mine 17 Report Title: Environmental Risk Assessment Report Project number: 181020 Date: September 2019

APPENDIX 22 A3 MAPS