NGWENYA IRON ORE MINE
ENVIRONMENTAL AUDIT REPORT - 2019
Prepared for Submitted by
PO Box: D189, The Gables Kingdom of Eswatini
Unit 5, RSTP Innovation Park Building Project proponent Environmental Consultant Phocweni, Kingdom of Eswatini 1
ENVIRONMENT AUDIT REPORT – 2019 NGWENYA IRON ORE MINE
PREPARED BY
PO BOX: D189, GABLES, EZULWENI, ESWATINI
ON BEHALF OF THE LIQUIDATOR, FOR SG IRON ORE MINING PTY LTD
IN VIEW OF RESCUSITATING THE NGWENYA IRON ORE MINE BY
VUKA LILANGA MINERALS PTY LTD PO BOX: N5519, MBABANE, ESWATINI Email: [email protected] URL: www.vukalilanga.com
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine 2
Statement of Declaration
The findings, conclusions and recommendations provided in this Audit are based on the Auditor’s legal and professional knowledge and information made available to the auditor and observations made during the site visits. Although due care and diligence has been exercised in rendering services and preparing documents, no liability is accepted as a result of use of the information contained in this document. In particular no liability is accepted for consequences should recommendations contained in this report not be implemented.
This audit report must not be altered or added to without the prior written consent of the auditor. This also refers to electronic copies of this Audit Report.
Declaration
R3 Services, as an independent consultant compiled this audit report and declare that it correctly reflects the findings made at the time of the audit. We further declare that we,
• Act as an independent consultant;
• Do not have any financial interest in the undertaking of the activity, other than remuneration for the work performed in terms of the Environmental Management Act, 2002;
• Undertake to disclose, to the competent authority, any material information that has or may have the potential to influence the decision of the competent authority or the objectivity of any report, plan or document required in terms of the Environmental Management Act, 2002;
• Based on information provided to us by the project proponent, and in addition to information obtained during this study, will present the results and conclusion within the associated document to the best of our professional judgement.
______Nsibandze Bhekisisa Dlamini Ceb’sile Portia Director - R3 Services Author & Environmental Consultant
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PROPONENT’S COMMITMENT
Vuka Lilanga Minerals (Pty) Ltd is committed to adhering with the CMP and other environmental requirements and legislation of the Kingdom of Eswatini to ensure that the proposed project is undertaken in an environmentally friendly manner.
______SIVARAMA PRASAD PETLA MANAGING DIRECTOR
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Table of Contents
Statement of Declaration ...... 2 Declaration ...... 2 Table of Contents ...... 4 List of Figures ...... 6 List of Tables ...... 8 Glossary & Acronyms ...... 9 Glossary ...... 9 Acronyms ...... 9 Executive Summary ...... 10 Introduction ...... 13 The Purpose of the Environmental Audit is to assess: ...... 13 The Objectives of the Environmental Audit are therefore to: ...... 13 The Scope of the audit ...... 13 Part 1: Background and Project Status ...... 14 1.1. Project Background ...... 14 1.2 The Swaziland Iron Ore Development Corporation ...... 15 1.3 SG Iron Ore Mining Pty Ltd ...... 15 1.4 Project Status ...... 15 Part 2: Audit Information ...... 16 2.1 Scope of the Work...... 16 2.2 Audit Methodology ...... 16 2.3 Consultations ...... 16 Part 3: Relevant Legislative Framework ...... 18 Part 4: Description of the Abandoned & Proposed Mine Operations ...... 25 4.1 Location ...... 25 4.2 Size ...... 25 4.3 Workforce ...... 25 4.4 Inputs and outputs ...... 26
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4.5 Manufacturing process ...... 26 4.5.1 Excavation and Segregation at source ...... 27 4.5.2 Dry Crushing and Screening ...... 28 4.5.3 Wet screening and jigging for coarser sizes ...... 28 4.5.4 Spiral Circuit for finer sizes (<1mm) ...... 28 4.5.5 Water Requirement, Sources and Recycling ...... 29 Part 5: Physical Environment ...... 33 5.1 Physical Landscape ...... 33 5.2 Climatology Information ...... 33 5.2.1 Rain Fall ...... 33 5.2.2 Wind speed and wind directions ...... 34 5.3 Biodiversity...... 36 5.3.1 Fauna ...... 36 5.3.2 Flora ...... 36 5.4 Infrastructure ...... 37 5.5 Transportation ...... 40 5.5.1 Previous Operations ...... 40 5.5.2 Proposed Operations ...... 40 Part 6: Audit Findings ...... 43 Part 7: Socio Economic Environment ...... 53 7.1 Surrounding Businesses ...... 53 7.2 Eswatini Economy Impact by the Project...... 58 7.3 Economy Boost ...... 59 7.3.1 Potential payments and levies ...... 59 7.3.2 Proposed operations ...... 59 Part 8: Environmental Impacts and Their Evaluation ...... 60 Part 9: Comprehensive Mitigation Plan ...... 69 9.1 Commitment by the Project Proponent ...... 69 9.2 Impacts and their mitigate measures ...... 69 Part 10: Monitoring ...... 85 10.1 Hydrological Monitoring ...... 85 10.2 Vibrations Monitoring ...... 85 10.3 Ecological Monitoring ...... 85
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10.4 Socio Economic Impacts Monitoring ...... 85 10.5 Air Quality Monitoring ...... 86 10.6 Independent third party consultation ...... 86 10.7 Budget allocations for the monitoring activity ...... 86 Part 11: Rehabilitation ...... 87 11.1 Progressive Rehabilitation ...... 87 11.2 Re-Vegetation ...... 88 11.3 Maintenance ...... 88 Part 12: Conclusions ...... 89 Part 13: References ...... 90 Annexures ...... 91
List of Figures Figure 1: Map Showing the Project Location ...... 14 Figure 2: Proposed high level process flow ...... 27 Figure 3: Location of water sources ...... 29 Figure 4: Location of the Plants ...... 30 Figure 5: Water circulation - schematic view...... 31 Figure 6: 30 meter Thickener and Ceramic Disc Filters ...... 31 Figure 8: Showing Malolotja minimum temperatures for 2014 – 2018...... 33 Figure 7: Showing Malolotja maximum temperatures for 2014 – 2018...... 33 Figure 9: Showing Malolotja rainfall averages...... 34 Figure 10: Wind Rose diagram for Ngwenya area (obtained from Data source: Lakes View, Canada) 35 Figure 11: High rate thickeners ...... 38 Figure 12: 100 t weigh bridge ...... 38 Figure 13: The condition of Magnetic Separation Plant ...... 38 Figure 14: Magnets in Magnetic Separation Plant ...... 38 Figure 15:Front-end Loader at Slimes Plant ...... 39 Figure 16: Crushing Plant at Jig-2 ...... 39 Figure 17: Pump House ...... 39 Figure 18: 400 kVA Generator ...... 39 Figure 19: Jigging Plant ...... 39 Figure 20: Crushing Plant at Jig -3 ...... 39 Figure 21: Jig Plant 1 ...... 39 Figure 22: Thickener ...... 39 Figure 23: Laser based temperature sensor ...... 41 Figure 24: Tire washing System ...... 42 Figure 25: Burnt Old Iron Ore mine visitors centre ...... 53 Figure 26: Abandoned Peterstow Site ...... 53
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Figure 27: Iron Ore export from Eswatini in ten years and the Quantity ...... 58 Figure 28: Typical Waste Dump Profile Plan ...... 88
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List of Tables Table 1: Consultations List ...... 17 Table 2: Relevant Legislation ...... 18 Table 3: Employment Details ...... 25 Table 4: Previous Operations Throughput Details ...... 26 Table 5: Water Balance Calculations...... 29 Table 6: Physical Environment - Audit Findings and Observations ...... 44 Table 7: Land Use & Working Conditions ...... 48 Table 8: Business Community Feedback & Comments from Audit ...... 54 Table 9: Actual paid out in Royalties and taxes during operating period ...... 59 Table 10: Projected Royalties, PAYE and taxes in the first five years of operation ...... 59 Table 11: Description of Impacts on Fauna & their Evaluation ...... 61 Table 12: Description of Impacts on Flora & their Evaluation ...... 62 Table 13: Description of Impacts on Water Quality & their Evaluation ...... 62 Table 14: Description of Impacts on Waste Management & their Evaluation ...... 63 Table 15: Description of Impacts on Air Quality & their Evaluation ...... 64 Table 16: Description of Impacts of Noise Pollution & their Evaluation ...... 65 Table 17: Description of Impacts on Aesthetics of site & their Evaluation ...... 66 Table 18: Description of Impacts on Land Use & their Evaluation ...... 66 Table 19: Description of Impacts on Health and Safety & their Evaluation ...... 67 Table 20: Description of Impacts on the Economy & their Evaluation ...... 68 Table 21: IMPACTS on fauna & their mitigation measures...... 70 Table 22: IMPACTS on flora & their mitigation measures ...... 72 Table 23: Impacts on Water Quality and mitigation measures ...... 73 Table 24: Impacts on Waste Management ...... 75 Table 25: Impacts on Air Pollution ...... 76 Table 26: Impacts of Noise Pollution and Mitigation Measures ...... 78 Table 27: Impacts of Aesthetics of site area and surroundings ...... 79 Table 28: Impacts of Land Use and Mitigation Measures ...... 80 Table 29: Impacts on Health & Safety and Mitigation Measures ...... 82 Table 30: Impacts on the Economy and mitigation measures ...... 84 Table 31: Budgetary allocations for Environmental Monitoring ...... 86
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Glossary & Acronyms 9
Glossary & Acronyms
Glossary Environment - Surroundings in which the operation takes place, including air, water, land, natural resources, flora, fauna, humans and their interrelation.
Environmental Audit - Exercise of identifying and evaluating the environmental impact of abandoned and proposed operations.
Comprehensive Mitigation Plan - Document or section of an environmental report with descriptions of the mitigation measures to be implemented in order to reduce, eliminate or manage environmental impacts of the operations.
Interested and Affected Parties - Individuals/groups with interests or affected by the environmental impacts of the operations.
Compliance – compliant to implementation of proposed mitigation measures in the EIA.
Non-compliance – not compliant to implementation of proposed mitigation measures in the EIA.
Partial non-compliance - A partial non-compliance refers to a deviation from compliance but does not represent full non- compliance to implementation of mitigation measures.
Acronyms PCR Project Compliance Report
EIA Environmental Impact Assessment CMP Comprehensive Mitigation Plan EAR Environmental Audit Report
ECC Environmental Compliance Certificate EEA Eswatini Environmental Authority EWSC Eswatini Water Service Corporation
RFID Radio-Frequency Identification
ROM Run of Mine
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Executive Summary 10
Executive Summary
Ngwenya Iron Ore Mining
Iron ore in Eswatini is predominantly found on the north-west boarders of the country. The area, which is now known as the Bomvu Ridge, was first explored in 1946 when the Geological Mines and Survey department first started prospecting the Ngwenya massif.
The Anglo-American Corporation of South Africa extracted the ore from 1964 until they stopped in 1978. When they stopped operations, they left the hematite rich waste dumps with no attempt to rehabilitate the site for more than three decades.
A mining licence was granted to Salgaocar Swaziland Pty Ltd (SSPL) in the year 2011 to reclaim the iron ore from the existing old dumps. However, with the declined mineral commodity prices especially the iron ore, the company went into liquidation in 2014.
Project Status
The project license was awarded to the liquidated company for a period of seven (7) years to reprocess the waste dumps to a quantum of 32 million tons generated by Anglo American. Out of 32 million tons the previous operations processed 4 895 309 tons between Oct 2011 to Sep 2014. A new approved investor, Vuka Lilanga Minerals was granted the mining licence included a mining lease together with all the necessary statutory permission transferred from SG Iron Ore Mining Pty Ltd to Vuka Lilanga Minerals Pty Ltd in order to resume the operations without any time delays. The liquidator will then clear all the debtors of the SG Iron Ore Mining Pty Ltd from the liquidation proceeds and Vuka Lilanga Minerals Pty Ltd will be free from any liabilities of the previous operator. The past operations liabilities inclusive of environmental liabilities lies with the Liquidator,
Mine Operations
It is worth mentioning that an Environmental Audit is normally undertaken on an ongoing activity or development that is in operation. In this case abandoned mining operations and proposed resuscitating mining operations were audited. This activity is ongoing in the sense that there was no decommissioning of the activity and rehabilitation of the site.
Mine Infrastructure
The site conditions are deteriorating on a fast pace since the operations were stopped abruptly and no further maintenance on either equipment/installation or site happened due to non-availability of technical know-how and financial support.
Mine Plant Processes
During Anglo’s operations the fine form (0-5 mm) of iron ore and the low-grade ores i.e., <63% Fe are considered as waste due to lack of technology to extract iron from those categories. The material was
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Executive Summary 11
dumped along with other waste rock and non-ferruginous material, which needs careful segregation and beneficiation techniques to extract the iron rich content to make it saleable.
In view of this, Vuka Lilanga Minerals Pty Ltd has envisaged the flowing process methodologies to adopt:
• Excavation & segregation at source
• Dry Crushing and Screening
• Wet Screening and Jigging for coarser sizes
• Spiral Circuit for finer sizes
• Dewatering and recycling of water
Transportation
Vuka Lilanga Minerals Pty Ltd proposes to carry on with the logistics operations from mine to Sidvokodvo rail by trucks and from then by rail to the ports. Vuka Lilanga Minerals Pty Ltd consulted with Eswatini Railway for exploring possibilities to rehabilitate the rail line from Kadake to Matsapha. Where Vuka Lilanga Minerals Pty Ltd obtained a positive response from Eswatini Railways that if the mine operations assured with more than 20 years the railway line will be resuscitated within 36 months.
To ensure road safety, Vuka Lilanga Minerals Pty Ltd will ensure the carrying load of each truck as per the statutory permitted axle load and that the operators are working as per the statutory hours by imposing strict vigilance over the transport operators. An elaborate system has been devised that will help prevent accidents along the route of operation.
Biodiversity
The only mammals that were found signs of on the project area during the audit were baboons and porcupines. There is also strong evidence of an existence of a leopard as a porcupine kill was found with quills scattered around. Other carnivores have been recorded in this area including a thriving black back jackal population. They are also home to high conservation value species such as the grey rhebok, eland Tsessebe and the leopard all of which are near threatened. As a conservation area the Malolotja Nature Reserve is a significant sanctuary for a number of critically endangered species such as the blue swallow, bald ibis, blue crane and Stanleys bustard which nest inside the park. Mitigation measures such as minimising noise levels onsite will be implemented to prevent the species from migrating further away from the nature reserve.
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The vegetation on the project area has been extensively disturbed in the past during the previous mining operations. This was however restricted to the mining lease site. The site is generally disturbed and as such a high number of invasive species have invaded the area. The proposed rehabilitation plan by the project proponent will deal away with such challenges.
Mine surrounding Businesses
The surrounding businesses generally acknowledged the negative impact of the non-operation of the mine in relation to economic activity. There are however diverse sentiments that were expressed on some of the environmental impacts during the mine operation.
Vuka Lilanga Minerals Pty Ltd is aware of the challenges incurred by the surrounding businesses during the previous operations of the mine and is committed in implementing sustainable and comprehensive mitigation measures to their challenges.
Eswatini Economy impact by the project
Mining activity in Eswatini has generally been muted for the past decades. There was a welcome jolt in the activity in 2011 when the Ngwenya iron ore mine started operating. The Central Bank of Eswatini reports indicate that the Ngwenya Iron ore mine contributed significantly to minerals exports during its operations. As a result of the reopening of the iron ore mine, an average annual contribution of E50 million is projected in PAYE, taxes and royalties for the first five years of operation
Monitoring
Under the environmental monitoring programme, the conditions of Hydrological, vibrations, ecological, socio-public impacts and air quality are considered. This is to ensure that the mitigation measures proposed of the identified impacts are effectively implemented and the environment is not harmed in anyway.
Rehabilitation
After beneficiation of the material from the dumps, the rejects from the processing plants will be stacked at an earmarked area and shall not keep active for long period. Among the rejects of the current process, there is material having good quality Fe content i.e., up to 45% Fe which will not be discarded as waste but will be preserved as future ore for further process. Other rejects, which will be of no future use, will be dumped in a systematic but separate from the iron rich rejects. As the reprocessing of the dumps will be ongoing, progressive rehabilitation will be done in stages in the advancing manner.
It should be noted that the very reprocessing of the dumps itself is part of the mine site rehabilitation.
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Introduction
R3 Services was appointed by the liquidator for SG Iron Ore Mining Pty Ltd as an independent consultant to conduct an Environmental Audit for the resuscitation of Ngwenya Iron Ore Mine operations.
This undertaking was brought about by an achievement of the Liquidator who has met the objective of finding an investor for the iron ore mine. The liquidator approached Eswatini Environmental Authority (EEA) for guidance on the procedure to be followed when transferring the Environmental Compliance Certificate (ECC) from SG Iron Ore Mine to the new approved investor, Vuka Lilanga Minerals Pty Ltd to resume operations. EEA has advised the Liquidator to undertake an Environmental Audit on the abandoned operations of the mine (See Annexure 1).
Hence the Liquidator through R3 Services has embarked on the exercise of preparing an environmental Audit and Comprehensive Mitigation Plan in order to comply with national legislation (Environmental Audit, Assessment and Review Regulations 2000). In accordance with Environmental Legislation, an Environmental Impact Assessment in respect to the abandoned operations of the project was carried out and approved by EEA in September 2011. The ceased operations of the project were officially opened on 21 October 2011 and operated till October 2014
The Purpose of the Environmental Audit is to assess: • The effects of the abandoned iron ore mine activities on the environment regarding national environmental legislation, the conditions outlined in the Environmental Compliance Certificate (ECC) as well as the Comprehensive Mitigation Plan (CMP). • The Status quo of the mine environment. • The proposed mining operations and systems’ environmental impacts and propose relevant sustainable mitigation measures with responsibilities of implementation. The Objectives of the Environmental Audit are therefore to: • Provide an objective analysis of environmental impacts arising from the operations of resuscitating Ngwenya Iron ore mine processes. • Provide assessment of resuscitating Ngwenya Iron Ore mine operations and their conformity with relevant national environmental legislation and standards. • Provide objective information and use it in developing a pragmatic comprehensive mitigation plan for significant negative environmental impacts. • Make recommendations for improved environmental compliance. The Scope of the audit The audit will cover the abandoned Ngwenya Iron Ore Mine processes and the proposed operations of the Vuka Lilanga Minerals Pty Ltd, which will be taking place in the kingdom of Eswatini, exclusive of international operations, even though the iron ore will be transported through neighbouring countries. This is because the point of reference for this audit is relevant of environmental legislation within Eswatini borders.
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Part 1: Background and Project Status
This section illustrates the project background and status by describing the project location and historical development of the project through its various operators from its inception in 1960’s to present.
1.1. Project Background Ngwenya Iron Ore mine is situated in the North Western border of the Kingdom of Eswatini. The project area is in the Hhohho Region of Eswatini, on its north western border. It is found between latitude 26°11´30'’S and 26°12´00'’S and between longitude 31°01´30'’E and 31°02´30'’E in the uphill of the Ngwenya town next to MR-3. The mine area is mountainous, ranging in elevation from 1320 m to 1720 m above mean sea level.
Figure 1: Map Showing the Project Location
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1.2 The Swaziland Iron Ore Development Corporation The Swaziland Iron Ore Development Corporation (SIODC) was formed early in 1958 to continue prospecting activities and to study the economics of exploiting the deposits. In result of the above exploration, the mine was in operation by Anglo-American from 1964 – 1979; and continued to clear the stockpiles until 1980. When the mine was operational the records indicated that 28.37 million tons of high-grade hematite ore was produced and exported from Ngwenya. By then hematite ore greater than (>) 59.5% Fe was consider of high grade. From these records it estimated that the available potential ore reserves in situ is 26.50 million tones and in the year 1982 the available estimate dumps was 32.1 million tonnes.
1.3 SG Iron Ore Mining Pty Ltd SG Iron Ore Mining Pty Ltd formerly known as Salgaocar Swaziland Pty Ltd (SSPL) resumed the mining operations in the year 2011 with a mining grant for reprocessing the dumps for a period of 7 years. SSPL established a 500 t/h magnetic separation plant and 900 t/h jig plants to reprocess the dumps to upgrade the material to +60% Fe. In the year, 2014 the SSPL underwent name change to SG Iron Ore Mining Pty Ltd and later that year the operations were suspended due to market collapse and the company went under liquidation in early 2015. During Salgaocar operations, the mine produced and exported about 2.9 million tons of iron ore.
1.4 Project Status
Eswatini Government invited investors through the liquidator to take up this business opportunity, which has tangible economic benefits to the nation. The package for Vuka Lilanga Minerals included a mining lease together with all the necessary statutory permission transferred from SG Iron Ore Mining Pty Ltd to Vuka Lilanga Minerals Pty Ltd in order to resume the operations without any time delays. The liquidator will then clear all the debtors of the SG Iron Ore Mining Pty Ltd from the liquidation proceeds and Vuka Lilanga Minerals Pty Ltd will be free from any liabilities of the previous operator. The past operations liabilities inclusive of environmental liabilities lies with the Liquidator, however as an ongoing concern the site will be brought to a better workable environment consistently being improved during the resuscitating operations.
In line with the above, the Mineral Management Board has succeeded in getting Vuka Lilanga Minerals Pty Ltd as an investor to take over the operations and have submitted their recommendations to His Majesty, which has been approved for the grant of mining license to process these iron ore dumps (See Annexure 2 for Letter of Grant). Accordingly, the liquidator assigned R3 Services to conduct the Environmental Audit and submit the report in compliance with the Environmental Audit, Assessment and Review Regulations 2000.
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Part 2: Audit Information
This section of the report illustrates the scope of the work that is assigned to the consultant in accordance with the guidelines prescribed by the environmental authorities, audit methodology adopted, and consultations made.
2.1 Scope of the Work The scope of work entailed conducting a comprehensive audit to assess the mine environment in respect to the abandoned operations of the mine and the proposed resuscitating activities.
2.2 Audit Methodology Random interviews were conducted of residents inclusive of people who were employed during the previous operations of the mine, the surrounding businesses to the site, and relevant stakeholders. The audit was carried out through site observation, interviews of interested and affected parties and document reviews.
• Preliminary discussions were held with the Vuka Lilanga Minerals Pty Ltd to fully understand the abandoned mining operations and the overall purpose of the environmental audit. • A desktop study was done for the legislative review, historical aspects of the project, as well as other literature on the site and its surroundings.
• Environment audit data was collected using variety of standard methods including interviewing stakeholders and I&AP. • The significance of the identified impacts on the environment were determined and relevant mitigation plan evaluated for compliance. • EAR prepared using the data and information collected during consultations and observations. • CMP that addresses the issues identified from the above process was prepared.
• EAR, CMP reviewed by Vuka Lilanga Minerals Pty Ltd, comments, and further suggestions incorporated into this final report.
2.3 Consultations During the process of the EA, consultations were made, especially with Eswatini National Trust Commission and Ngwenya Town Board, which is the local authority under whose jurisdiction the project site lies. Consultations were also made with other government departments and parastatals. Table 1 below illustrates the list of consultations.
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Table 1: Consultations List
NAME DESIGNATION ORGANIZATION
Martin Misilela Investment Manager EIPA
Robert Biyela Chief Mining Engineer Mining Department
Vusie Mabuza Acting Chief Roads Engineer Roads Department
Temhlubi Nkambule National Monuments Officer ENTC
Sandle Gumedze Senior Ecologist ENTC
Seth Maphalala LTFCA PM ENTC
Ngwane Dlamini Senior Warden Malalotja Nature Reserve
Brenda Dlamini Inspector of works Ngwenya Town Board
Phumzile Tshabalala Town Clerk Ngwenya Town Board
Benjamin Msane Social & Community Dev. Officer Ngwenya Town Board
Richard Mdlovu Water Treatment PLant Attendant SWSC, Ngwenya Water Treatment Plant
Mavela Sigwane Managing Director Simav SHEQ Services
Gary Hayter General Manager Ngwenya Glass
Dukes Shongwe Managing Director Dukes Investment
Mphikeleli Ntshalintshali Hatchery Manager Africa Chicks
Dumsani Dlamini General Manager Metier Ready Mix Concrete
Sleby Shongwe Health and Safety Officer Poly Pack
Bhekani Motsa General Manager Swazi Medics & Emergency Services
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Part 3: Relevant Legislative Framework 18
Part 3: Relevant Legislative Framework
With biodiversity now on the sustainability agenda of leading multinational corporations, the conservation community is beginning to recognise the private sector as part of the solution and not just part of the problem. The Project appears also to be amongst the companies in the mining sector who have recognised that they can achieve sustainable business operations whilst being biodiversity positive in its operations. Vuka Lilanga Minerals Pty Ltd commits to conforming to all relevant legislation protecting the health and safety of the human population and built environment, the air, the water, the soil, the fauna and flora. Eswatini has a robust legislative framework. The Environmental Management Act, 2002 is the framework environmental law in the country. Eswatini Environmental Authority, a parastatal under the Ministry of Environmental Affairs and Tourism is the institution that has been given a mandate to ensure that environmental legislation is adhered to. There are various other laws that deal with specific sectors of the environment such as air, water, fauna, flora and land management, enforced by different government departments. Table 2 below shows an overview of the different laws governing environmental legislation in the country and the relevant legislations to the project
Table 2: Relevant Legislation
Legislation/ Summary Provisions Enforcing Relevance to the Policy Organization Project Constitution of The constitution affirms the Government of The constitution is binding Swaziland provision of the Johannesburg Eswatini to all Eswatini citizens 2005 Declaration and Agenda 21 as including implementation follows: of projects in the country,
as it is the supreme law of Chapter XII states that, “the State the country. should make rational use of its land, minerals and water resources as well as its biological diversity and should take appropriate measures to conserve, improve the environment and that all people should promote the protection of the environment for present and future generations and that industrialisation should be undertaken with due respect for the environment and that the government should ensure a comprehensive and holistic
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Part 3: Relevant Legislative Framework 19
Legislation/ Summary Provisions Enforcing Relevance to the Policy Organization Project approach to environmental preservation and management.”
The Swaziland The EEA was established by this EEA All actions taken by Vuka Environmental Act. It has powers to establish Lilanga Minerals Pty Ltd in Authority Act, standards and guidelines relative furtherance of its 1992 to pollution of the air, water and operations shall be guided land, to establish guidelines for the by the standards and
preparation of environmental regulations set by the EEA, impact assessment, audits, and under this Act. evaluations (Environmental Audit, Assessment and Review Regulations: Guidelines, 2000), and to control all forms of environmental pollution.
Environment The Environmental Management EEA This report is an effort to Management Act provides and promotes the achieve this end, Act, 2002 enhancement, protection and according to the principles conservation of the environment stated in section 5 of the
and the sustainable management act, Vuka Lilanga Minerals of natural resources. This is the Pty Ltd will ensure framework law for environmental protection of the management in the country. It environment during the outlines the principles that govern operations of the mine by environmental management and developing and institutional framework for implementing an national environmental Environmental Action Plan management. It outlines the tools and Waste Management and processes to be used for Plan. environmental management, pollution and waste management mechanism and public participation. It also outlines provisions for compliance and enforcement of the Act.
The Swaziland The Swaziland National Trust The Eswatini The proposed project is National Trust Commission Act gives powers to National Trust within the Malolotja Commission proclaim national parks, Commission Nature reserve, which is Act, 1971 monuments, geological, historical under the control of and archaeological artefact. Eswatini National Trust
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Part 3: Relevant Legislative Framework 20
Legislation/ Summary Provisions Enforcing Relevance to the Policy Organization Project commission (ENTC). This Act is relevance because it controls activities that take place in a nature reserve.
The Natural This Act established the Natural Ministry of Vuka Lilanga Minerals Pty Resources Act, Resources Board and identified its Natural Ltd will ensure that waste, 1975 responsibilities regarding the resources and conservation and improvement of Energy generated during
natural resources. Such duties operations is disposed of include soil conservation, river and in a proper and stream conservation (source, responsible manner to course and banks), control of water (including storm water) and control avoid pollution of the of grass burning. natural resources such as the land and water (Overland and ground water).
The Water This Act provides for the Ministry of Therefore, all works Act, 1967 management of water resources in Natural carried out within the Swaziland. It provides for water resources and project site, in relation to
management structures such as a Energy the use of water, will National Water Authority, Water observe this legislation Appointment Board, River Basin and the authority. During Authorities and Irrigation Districts. the operation phase of the It establishes a permit system for project, wastewater will the abstraction and use of water be produced, which has a resources. It also provides for the potential adverse impact issuance of effluent control on water resources. permits. The Water and Apportionment Board formed under this Act controls and registers the use of water and the use and safety of water retaining structures such as dams.
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Part 3: Relevant Legislative Framework 21
Legislation/ Summary Provisions Enforcing Relevance to the Policy Organization Project Factories, This Act provides for safe working Ministry of The act is concerned with Machinery conditions and the safe use of Public works protecting the health and and machinery at factories and and Transport. safety of workers from the Construction construction sites. This Act seeks to adverse effects of dust, Works Act, enforce the contractor to comply fumes, noise and other 1972 and ensure that safety and health impurities encountered are undertaken to protect workers. during the use of
machinery.
The Public The Act requires that local Ministry of It details what diseases Health Act, authorities deal with nuisances to Health are termed as 1969 the public health including communicable diseases, collections of water and sewage, the management
which could lead to diseases and procedures of any related infection, and wastewater flowing incident, and the from premises onto public areas. responsibilities of public The Public Health Act requires that individuals and officers. all public water for drinking and Vuka Lilanga Minerals Pty domestic use is pollution-free, Ltd will confirm to either through prevention or procedures relating to population. It also provides for the prevention of nuisances. control of unsanitary and unsafe buildings.
Occupational The Occupational Safety and Ministry of Having employees during Safety and Health Act, 2001 provides for the Labour and the operations of the Health Act, safety and health of persons in the social services mine means that all 2001 workplace and for the protection precautions outlined in of persons other than those in the the act for the protection workplace against hazards to safety of their health and safety and health arising from work needs to be adhered to activities. It requires that in a and Vuka Lilanga Minerals workplace with 20 or more Pty Ltd is committed into employees, at least one ensuring safety and health functioning safety and health of workers and the committee should exist. general public during the implementation of all works in relation to the resuscitating of the iron ore mine.
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Part 3: Relevant Legislative Framework 22
Legislation/ Summary Provisions Enforcing Relevance to the Policy Organization Project The Flora This act provides for more effective Ministry of In observation of this act Protection Act, protection of flora and provides for Tourism and only indigenous plants will 2001 matters incidental thereto. Such Environmental be used in the relevant protection also includes the Affairs stages of the project
eradication of alien invasive plants rehabilitation and any species within the country. alien invasive plants identified will be eradicated thus conforming to the legislation.
The Game Act, The act aims at the protection of King’s Office During the operations of 2001 birds and mammals against the Mine, Vuka Lilanga poaching and destruction. Minerals Pty Ltd will ensure compliance to all
measures designed for the protection of the animals under the protection of this act will not be harmed.
The Road This Act provides for the regulation Ministry of There will be Traffic Act, and control of traffic and transport Public works transportation of 2007 on public roads. This Act prohibits and Transport materials from Ngwenya the operation on a public road of a for loading at Sidvokodvo vehicles, which causes excessive rail and such operation noise, and also vehicles which should be done in emits excessive smoke or fumes. adherence to this act.
Mines and This act controls the Ministry of This activity deals with the Minerals Act, exploration, mining and Natural processing and 2011 exportation of minerals in the Resources and exportation of iron ore, country. It requires every Energy and as such is to be
person that deals with minerals controlled by this act. to get a mining license from the
Minerals Board. It outlines compensation procedures for mining/prospecting that is done on private land. It also outlines obligations for, prospecting/mining rights
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Part 3: Relevant Legislative Framework 23
Legislation/ Summary Provisions Enforcing Relevance to the Policy Organization Project holders and powers of INgwenyama.
Environmental These Regulations control the EEA The process for the Audit, environmental assessment process preparation of this report, Assessment and stipulate requirements on the including its structure and and Review structure of reports and reporting the Project compliance Regulation, procedures. It informs those reports to be submitted to 2000 involved in the operation, design the EEA during the cause and implementation of of the mine’s operations
development projects in Eswatini are all guided by these of their environmental obligations regulations. under the Regulations.
Air Pollution These Regulations provide for air EEA Vuka Lilanga Minerals Pty Control quality objectives, air quality Ltd will implement Regulations, monitoring, reporting of air measures to control air 2010 pollution incidents and the pollutants to the obligation to take corrective and atmosphere as per
preventive measures against harm required by this to air quality. The Regulations state regulation. that “any person who causes or permits an emission which is potentially hazardous to human health or the environment, and any operator whose business gives rise to such an emission, shall immediately take all reasonable measures to avoid and mitigate any damage which may be caused to the environment or to human or health as a result of the emission.”
Water The Regulations provide for the EEA During the operations of Pollution control and reporting of the the mine, water samples Control discharge of effluent. The will be collected in nearby Regulations, intentional or negligent discharge streams and taken to 2010 of polluting substances above the EWSC for analysis and stipulated limits is prohibited. It results will be compared regulates the discharge of effluent with water parameters’ exceeding effluent standards for standards in this acceptable river water quality, and regulation.
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Part 3: Relevant Legislative Framework 24
Legislation/ Summary Provisions Enforcing Relevance to the Policy Organization Project all regulatory mechanisms for the discharge of effluent into bodies, including sampling, testing, monitoring and abatement, reporting and other obligations such as to mitigate harm and taking remedial actions.
Workmen’s The Regulations control the Ministry of Vuka Lilanga Minerals Pty Compensation reporting of workplace accidents Labour and Ltd will ensure that Regulations, and work-related diseases, the social services workplace accidents are 1983 provision and payment of medical prevented at all cost, and treatment of injured employees in cases of accidents a and the compensation of such shall ensure employees employees. are well compensated.
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Part 4: Description of the Abandoned & Proposed Mine Operations 25
Part 4: Description of the Abandoned & Proposed Mine Operations
It is worth mentioning that an Environmental Audit is normally undertaken on an ongoing activity or development that is in operation. In this case abandoned mining operations and proposed resuscitating mining operations were audited. This activity is ongoing in the sense that there was no decommissioning of the activity and rehabilitation of the site.
4.1 Location The project area is in the Hhohho Region of Eswatini, on the north western border of Eswatini. It is found between latitude 26°11´30'’S and 26°12´00'’S and between longitude 31°01´30'’E and 31°02´30'’E. There is no change in the location of the project in the sense that the same project area, which was used by the previous mining company, will be utilised.
4.2 Size The physical size of the project is 401.85 ha which got split into these under parts: • ENTC land: 242.886 ha • Govt. land: 158.964 ha
4.3 Workforce The mining activity brought about job creation during its operations. When the mining operation ceased, all employees lost their jobs. After its closure, the mining site and assets are being protected by the liquidator. Eswatini Umbutfo Defence force are providing high level of security on site.
During the previous operations of the mine the employees were distributed according to their skills level as shown in the Table 3 below. Since the mine operations ceased the workforce lost their jobs. The previous level of employment and the matrix with respect to expatriates and local is as tabulated below:
Table 3: Employment Details (Direct employment)
Previous Operations Proposed Operations Employment Level Expatriates Swazi Total Expatriates Swazi Total Senior Management 3 0 3 3 1 4 Middle Management 4 2 6 4 2 6 Junior Management 1 7 8 1 7 8 Support Staff 6 66 72 6 66 72 Mining Personnel 1 369 370 1 369 370 GRAND TOTAL 15 444 459 15 445 460
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Part 4: Description of the Abandoned & Proposed Mine Operations 26
4.4 Inputs and outputs The project license was awarded to the liquidated company for a period of seven (7) years to reprocess the waste dumps to a quantum of 32 million tons generated by Anglo American. Out of 32 million tons the previous operations processed 4 895 309 tons between Oct 2011 to Sep 2014. The throughput details of the previous operations are illustrated in Table 4 below:
Table 4: Previous Operations Throughput Details
Operation Previous Throughput (MT) (2011-2014)
Excavation 4 895 309
Production 2 996 430
Rejection 1 898 878
Dispatch 2 946 430
Vuka Lilanga Minerals Pty Ltd is proposing a sealed down production of 1.2 million tons per annum for first three years of road transportation instead of full-scale operations of 2 million tons per annum. Full scale operations are anticipated to be implemented after construction of rail line. However, in the first year the production will be restricted to maximum of 600,000 tons. These proposed operations could achieve only low to medium grade product of 60 - 62% Fe. The ongoing activity of processing the dumps is producing new waste dumps of rejection material also consisting Fe content of 49% to 35%, which under mineral conservation cannot be rejected and stockpiled for future beneficiation. Table 5 below illustrates the proposed throughput of the resuscitating mine operations.
Table 5: Proposed Throughput per annum
Operation Proposed Throughput in MT/ year
Excavation 3 000 000
Production 1 200 000
Rejection 1 800 000
Dispatch 1 200 000
4.5 Manufacturing process The reclamation of iron ore dumps at Ngwenya Iron ore mines’ prime objective is to extract iron ore from the waste dumps created during the operations of Anglo-American Company between early 1960’s to 1978.
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Part 4: Description of the Abandoned & Proposed Mine Operations 27
During Anglo’s operations the fine form (0-5 mm) of iron ore and the low-grade ores i.e., <63% Fe are considered as waste due to lack of technology to extract iron from those categories. The material was dumped along with other waste rock and non-ferruginous material, which needs careful segregation and beneficiation techniques to extract the iron rich content to make it saleable. In view of this, Vuka Lilanga Minerals Pty Ltd has envisaged the flowing process methodologies to adopt and a high-level process flow is illustrated in the Figure 2: • Excavation & segregation at source • Dry Crushing and Screening • Wet Screening and Jigging for coarser sizes • Spiral Circuit for finer sizes • Dewatering and recycling of water
Figure 2: Proposed high level process flow
4.5.1 Excavation and Segregation at source As the waste dumps, which were created before 1978, most of them are covered with vegetative growth, which needs to be removed. This material was dumped so self-cutting with the excavators is possible hence no drilling and blasting techniques are envisaged.
The material is heterogeneous in sizes varying from 0 mm to boulders. The oversize material i.e., above 600 mm to be segregated with the excavator before loading to trucks/scalper screen. Once in a while depending on the accumulated quantity the oversized boulders will be broken down to feed size of <600 mm with the help of rock breakers.
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Part 4: Description of the Abandoned & Proposed Mine Operations 28
The Run of Mine (ROM) material is then screened with a scalping screen (Sandvik QE440) at face (excavation site) to separate <15 mm size to make a feed material for JIG Plant-1 circuit which doesn’t have any crushing facility. The >10 mm along with the ROM will be fed to JIG Plant 2 & 3 circuits.
4.5.2 Dry Crushing and Screening The ROM and the >15 mm materials obtained from the scalping screen is taken as input to the crushing and screening circuit. The material is very low grade (<42% Fe) due to unliberated silica and other gangue material, to liberate the silica the material is be crushed down to size of <10 mm. The crushing circuit is designed to recirculate the material through a triple deck screen with one jaw and two stage cone crushers. The final output from the crushing circuit is of <10 mm in size which will go to the next stage of beneficiation. This circuit is only for the JIG Plants 2 & 3.
4.5.3 Wet screening and jigging for coarser sizes Jigging is a physical (no chemical or thermal reactions) separation of material as a result of periodical influence of the upward and downward movement of water pulsations on the layer of separating material (the so-called jigging bed). Under action of pulsations the bed is alternately loosened and compacted, and the particles of different density mutually move on its height: with low density (gangue) into upper layers, with high density (iron ore) into bottom layers. The formed layers of different densities are separately removed as a concentrate, wastes and, sometimes, intermediate product.
The jigging technique cannot be applied to material of coarser size, that ranges 1 mm> material <15mm. As the density of the material is proportionally related to its products size and specific gravity, to obtain better results in the product the size of the feed material should be close to equal proportion. To achieve this the wet screening is envisaged. In Wet Screening & Jigging the feed material is screened in two stages. In the first stage the <1 mm and >6mm material will be separated in the presence of water. In the second stage >1mm and <6 mm material will be separated into >1mm to <3 mm and >3 mm to <6 mm size materials. These separated produces are feed into three jig plants named as fine jig (1-3mm), middle jig (3 - 6 mm) and coarse jig (>6mm) for beneficiation.
All the products (iron ore) are collected to a conveyor belt to make a stockpile and tailing will be collected to tailing stockpile.
4.5.4 Spiral Circuit for finer sizes (<1mm) The finer size material (0 – 1 mm) also rich in Fe content which couldn’t be lost as tailing. Hence the spiral circuit is envisaged to recover the iron content from this portion. The <1 mm material recovered from wet screening is put to spiral banks through hydro cyclones by concentrating the feed with >150- micron size. The concentrate obtained from the two-stage spiral circuit is dewatered with dewatering screens and mixed with the product obtained from the jigs.
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Part 4: Description of the Abandoned & Proposed Mine Operations 29
4.5.5 Water Requirement, Sources and Recycling 4.5.5.1 Water Requirement & Sources
The mineral beneficiation process (jigging) envisaged in the dump reclamation is a wet process, which requires about 3,000 cubic meters per hour. There are two catchment dams and one old mine pit (Lion Cavern pit) are identified as prime sources of water. The location of the water sources within the mining lease are illustrated in the bellow maps. All the water sources are naturally stored through rain water harvesting by making the check dams and refilling the old mine pit (Lion Pit).
Figure 3: Location of water sources
4.5.5.2 Water Balance
The water required in the process of all the jigs is 3000 m3/hr. Where 2857.85 m3/hr is recycled by the process equipment installed. The balance quantity of 142.15 m3/hr is the makeup water requirement from the water sources. The details of the water balance is illustrated in the below table:
Table 5: Water Balance Calculations
Sl No of Net in No Description Cu. m/hr Jigs Cu.m/hr I Consumption Requirement 1 Wash water for Screen 250.00 3 750.00 2 Process water for Jig Plant 750.00 3 2,250.00 Total Requirement 1,000.00 3,000.00
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Part 4: Description of the Abandoned & Proposed Mine Operations 30
II Water Losses 1 Moisture loss with product @ 10% @ 70 tph 7.00 3 21.00 2 Moisture loss with Tailing @ 10@ @70 tph 7.00 3 21.00 3 Moisture loss with Spiral product @ 18% @ 18 tph 3.40 3 10.20 4 Moisture loss with Spiral Tailing @ 18% @ 18 tph 3.40 3 10.20 5 Moisture loss with Filter cake @ 21% @ 24 tph 5.04 3 15.12 6 Other spillages diverted to settling ponds 25.00 3 75.00 Gross loss in operations 152.52 III Water Recycling 1 Feed to Thickener (30m dia) 2,862.60 2 Water Recovered from Thickener @ 98% 2,805.35 3 Recycled from the settling pond @ 70% pumping * 52.50 Net water loss to be compensated by make up with fresh water 142.15 * Note: The spillage water collected in the settling ponds will be pumped back to the system up to 70% and in the balance major portion will be drained to Catchment dam-1.
Figure 4: Location of the Plants
4.5.5.4 De-Water & Recycling Since the whole process after the crushing and screening is a wet process and the water will become turbid. This water then would require cleaning after which it will be recycled. The product material and tailings are properly dewatered with the dewatering screens for the coarser sizes. The finer size (<1mm) materials are in slurry form to dewater and cleaned through two thickeners (30m & 15m diameter) are envisaged. A schematic view of the water recycling is illustrated in the figure 5.
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Part 4: Description of the Abandoned & Proposed Mine Operations 31
Figure 5: Water circulation - schematic view
With the help of the thickeners the major portion (>~70%) of the process water is recycled and the thickener underflow is passed through the vacuumed ceramic disc filters to recover another ~15% water. The spillage water (~10%) in the plant site is collected through a series of cascading ponds and recycled.
Figure 6: 30 meter Thickener and Ceramic Disc Filters
There will only be a need to make up for natural water losses. The water, which will be required in the process of all the jigs at full capacity, is 3000 m3/hr. Where 2857 m3/hr will be recycled by the process equipment installed. The balance quantity of 142 m3/hr is the makeup water requirement from the water sources. The water sources are Catchment dam 1, Catchment dam 2 and the Lion Pit. The water recycling plant in not a standalone plant but part of the processing plant. For more details on the water recycling equipment, process and location see attached appendix 3.
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In the whole process, the mass recovery of the iron ore estimated around 40 – 45%, coarser rejections (Tailings) are about 45% and remaining is the fine size rejections. Among the rejections the coarser size is having good quality Fe content i.e., up to 45% Fe which could not be discarded as waste. Hence, that material is intended to be preserved as future ore for further process with different methods. The remaining finer rejections, which are coming as a cake (not sludge), from the ceramic vacuum disk filters will be used to refill the excavated areas. This is part of the progressive rehabilitation process as explained in section 1.1.
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Part 5: Physical Environment 33
Part 5: Physical Environment
5.1 Physical Landscape The Ngwenya Iron ore mine is located on the Bomvu Ridge, about 20 km northwest of Mbabane and near to the north-western border of Eswatini to South Africa. It is located in then Highveld of Eswatini along one of the highest peaks of the country, with an altitude ranging from 800 to 1,829 metres above sea level. Ngwenya Mountain, at 1,829 m, is Eswatini second highest mountain after Bulembu.
5.2 Climatology Information
5.2.1 Temperatures and Rain Fall Most rain falls are in summer, thunderstorms from December to April. Frost is common in June and July. The climatology is illustrated in the following Figures 7 -10 (sourced from Meteorology, 2019).
30 C)
o 25 ( 20 15 10 5 Tempereture 0 Jan Feb March April May June July Aug Sept Oct Nov Dec YEARS
2014 2015 2016 2017 2018
Figure 8: Showing Malolotja maximum temperatures for 2014 – 2018.
18 16
14 C) o 12 10 8 6
Temperature ( Temperature 4 2 0 Jan Feb March April May June July Aug Sept Oct Nov Dec YEARS
2014 2015 2016 2017 2018
Figure 7: Showing Malolotja minimum temperatures for 2014 – 2018.
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Part 5: Physical Environment 34
250
200
150
100
RainFall in (mm) 50
0 Jan Feb March April May June July Aug Sept Oct Nov Dec
YEARS 2014 2016 2017
Figure 9: Showing Malolotja rainfall averages.
5.2.2 Wind speed and wind directions For ascertaining the local weather conditions, the Meteorological Department was contacted to obtain the weather data, which includes wind speed and directions, min & max temperature, rain fall, and relative humidity, which has greater bearing on the dust migration. The department could not support, for the wind speed and direction due to technical problems with their instruments hence the data was obtained from the Lakes View Solutions Canada. With that data the wind rose diagrams (Figure 10) were prepared for the project area at Ngwenya. The wind speed was an average of about 5.0 m/s for the period between June 2018 to May 2019. It was noted that the wind direction was generally along the North West direction, which is not directly in the way of the closest homes to the mine. This suggests that even in days of high wind speeds and high PM values, the particulate matter would not be blown towards the direction of homesteads/human settlements. Even though particles may eventually reach these areas due to diffusion, the concentrations by this time would be very dilute and hence may be below the recommended limits of 50 m/m3.
It must also be noted that the area sources of activity are generally in the valley of a hilly area and surrounded by mountains in most directions hence the fast flow of particulate matter may also be restricted by the mountains surrounding the operations area.
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Figure 10: Wind Rose diagram for Ngwenya area (obtained from Data source: Lakes View, Canada)
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5.3 Biodiversity 5.3.1 Fauna Mammals In the past, the Afromontane grassland of this area supported numerous species of large mammalian herbivores and carnivores (Monadjem, 1998a). These species are now almost exclusively confined to protected areas and currently only a few smaller antelope species may persist in the Ngwenya area. There wasn’t any antelope or their tracks/droppings during the biodiversity survey done on the lease area; however, it is suspected that grey duikers, clipspringers and grey rheboks still occur on the project area. The only mammals that were found signs of on the project area were baboons and porcupines. There is also strong evidence of an existence of a leopard as a porcupine kill was found with quills scattered around. Other carnivores have been recorded in this area including a thriving black back jackal population. They are also home to high conservation value species such as the grey rhebok, eland Tsessebe and the leopard all of which are near threatened.
Birds More than two hundred and seventy bird species have been recorded in Malolotja. Important species recorded from the area include White stork, Bald ibis, Bat hawk, Martial eagle, African fin foot, Stanley’s bustard and Blue swallow. Of the approximately 92 endemic southern African bird species, 33 have been recorded from Malolotja.
As a conservation area the Malolotja Nature Reserve is a significant sanctuary for a number of critically endangered species such as the blue swallow, bald ibis, blue crane and Stanleys bustard which nest inside the park. Most of these are sensitive to disturbances such as the bald ibis, which are anticipated to have left the site area during the operations and have since returned after the mine activities have been abandoned. When the site area is disturbed again, most of the birds will migrate from the project area and lodge in the surroundings within the nature reserve. Mitigation measures such as minimising noise levels onsite will be implemented to prevent the species from migrating further away from the nature reserve. Blue swallows are known to nest in the Bomvu Ridge all the way towards Malolotja falls and the Mahulungwane gorge.
5.3.2 Flora About 20 species known as of conservation importance are known to exist within Malolotja Nature Reserve but during the biodiversity assessment only three of them were observed within the project area, which is the Cussonia spp, melanospermum italae and the brachystelma codii. The Bomvu Ride of Ngwenya is also home to a significantly rare Cineraria ngwenyensis, which is near endemic and classified as very rare by IUCN.
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Part 5: Physical Environment 37
The vegetation on the project area has been extensively disturbed in the past during the previous mining operations and the effect of this has resulted in some bush encroachment dominated by plant species such as pinus spp and Acacia spp with a fast-growing Solanum mauritianum population. The site is generally disturbed and as such a high number of invasive species have invaded the area.
5.4 Infrastructure From the records it was evident that SG Iron Ore Mining Pty Ltd has invested to a tune of E 301 583 589 towards building infrastructure, movable and immovable assets in carrying out the mining operations at Ngwenya Iron Ore Mine. The investment went into the following categories:
Table 6: Sink Investment into the Project
S. No Description of Investment Amount in Emalangeni
1 Land, Buildings & Infrastructure 3 763 384
2 Laboratory Equipment, Computer HW & SW 605 283
3 Utility Vehicles 4 009 600
4 Plant and Machinery 293 205 322
Total Investment 301 583 589
The above investment went into the project in establishing the following infrastructure to reprocess the waste dumps into saleable iron ore.
250 tph Magnetic Separation Plant to process <1 mm (fine) materials with • Double shaft attrition scrubber for slurry preparation feeding with grizzle feeder • 4 MIMS of 7000 Gz • 5 WIHMS of 1 Tesla • 2 Derrick stack sizers • 2 Derrick HiG dewatering screens • 3 Cone thickeners for water processing • PLC Based control room for entire plant 250 tph x 3 Jigging plants to process +1 mm to 15 mm coarse material (each jig plant is having 3 jigs to handle 1-3 mm; 3-6 mm and 6 -15 mm) 2 Jig Plants are integrated with set of static crushing plants with the following: • 1 Primary Jaw Crusher (input 600 mm; output 80 mm) • 1 Standard Cone crusher (input 80 mm; output 30 mm)
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Part 5: Physical Environment 38
• 2 Short Head cones crushes (input 30 mm; output 15 mm) • 1 Triple Deck Dry screens
A 30m & one 15m diameter high rate thickeners for handling water processing 3 Ceramic Disc filters to handle the Thickener underflow for tailing management To handle <1 mm material Wire Mineral Cavex 800 Hydro cyclones coupled with two stage spiral circuits integrated 2 x 90Kwa and 1 x 75 kw motors with 400 kw generator backup facility – sources of water pumping 2 x 630 kw generator back up facility for the plants and lighting
Since the operations were stopped abruptly and no further maintenance on either equipment/installation or site happened due to non-availability of technical know-how and financial support, the site conditions are deteriorating on a fast pace. The field evidences are illustrated with pictures as shown in Figures 11 – 22.
Figure 11: High rate thickeners Figure 12: 100 t weigh bridge
Figure 13: The condition of Magnetic Figure 14: Magnets in Magnetic Separation Plant Separation Plant
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Part 5: Physical Environment 39
Figure 15:Front-end Loader at Slimes Plant Figure 16: Crushing Plant at Jig-2
Figure 17: Pump House Figure 18: 400 kVA Generator
Figure 19: Jigging Plant Figure 20: Crushing Plant at Jig -3
Figure 21: Jig Plant 1 Figure 22: Thickener
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Part 5: Physical Environment 40
5.5 Transportation 5.5.1 Previous Operations During the previous operations of SG Iron Ore, the Iron ore was loaded from the mine site at Ngwenya into side tipper trucks to Mpaka for rail transportation to the harbour at Maputo.
5.5.2 Proposed Operations Vuka Lilanga Minerals Pty Ltd proposes to carry on with the logistics operations from mine to Sidvokodvo Rail by trucks and from then by rail to the ports. Also taking a serious note on the ‘REPORT OF THE COMMISSION OF ENQUIRY TO INVESTIGATE THE ROAD ACCIDENT OF THE 29TH APRIL 2014 ALONG THE MR3 FREE WAY AT MALAGWANE HILL PURSUANT TO LEGAL NOTICE NO 66 OF 2014’ Vuka Lilanga Minerals Pty Ltd submitted to the Government of Eswatini for effective planning and implementation in line with Vision 2022 in preparing its logistic plans.
• Vuka Lilanga Minerals Pty Ltd consulted with Eswatini Railway for exploring possibilities to rehabilitate the rail line from Kadake to Matsapha. Where Vuka Lilanga Minerals Pty Ltd obtained a positive response from Eswatini Railways that if the mine operations assured with more than 20 years the railway line will be resuscitated within 36 months. • To minimize the impact on the road traffic project Vuka Lilanga Minerals Pty Ltd proposed a sealed down production of 1.2 million tons in comparison with full scale operations of 2 million tons per annum which is anticipated after rehabilitating the railway line from Kadake to Matsapha (See Annexure 3 for LOI from Eswatini Railway). However, the first-year target of 1.2 million tons could not be achieved due to the refurbishment and recommissioning of the plants.
• To ensure road safety by taking precautionary measures to eliminate and minimize risks of accident, Vuka Lilanga Minerals Pty Ltd proposes the following measures in line with recommendations made by the “Report of the commission of enquiry to investigate the Road Accident of the 29th of April 2014 along the MR3 freeway at Malagwane Hill pursuant to Legal Notice No 66 of 2014(See Annexure 4) also in consultation with the Traffic Department of Royal Eswatini Police: o Not to engage any truck more than 5 years of age to ferry its product o Shall engage the trucks that are equipped with Advanced Breaking Systems. o Shall ensure a certified driver to operate these trucks o Can support Roads Department/Safety Council in establishing the Docking Bays along MR3 for testing the braking drum temperatures with latest laser technology.
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Part 5: Physical Environment 41
VUKA LILANGA MINERALS 19 Feb 2019: PTY LTD has made its own study for establishing the “No fatal accident at Malagwane in last 13 months” docking bays along the
MR3 and recommends: ‘SINCE the deployment of traffic police officers manning the Malagwane Cooling Station, there has been no fatal 1. Nkoyoyo: accident at the infamous Malagwane Figure 23: Laser based Hill in 2018.’ temperature sensor 2. Old Swazi Inn 3. Bahai center
o In co-ordination with Traffic department of Eswatini will develop and implement safe operating procedures for the truck operators ferrying its product. o Ensures the use of GPS Tracking for its fleet monitoring coupled with RFID technology for time stamping on the waybills with fixed travel time. o To reduce the traffic congestion during the peak hours (06:00 – 08:00 and 17:00 – 19:00) of traffic in the mornings & evenings, rescheduling at source point will be ensured in addition to the measures proposed by the Traffic Department (Annexure 5). o Ensure the carrying load of each truck as per the statutory permitted axle load. o Ensure the operators are working as per the statutory hours by imposing strict vigilance over the transport operators.
• Environmentally friendly logistic operations: To ensure environmental safety on road Vuka Lilanga Minerals Pty Ltd planned the following for strict implementation: o Ensure covering of all the trucks with proper tarpaulins to arrest any dust on move. o To control the fuel emissions, use of proper diesel and preventive maintenance was envisaged to supply diesel from the company sourced at mine head. In light of this Engen has already provided letter of support to Vuka Lilanga Minerals to supply fuel to the company in bulk (See Annexure 6 for Letter of Intent from Engen)
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Part 5: Physical Environment 42
o To keep the roads clean Vuka Lilanga Minerals Pty Ltd shall implement tire washing before trucks leave the stock yard by further improving the existing facility. (See Annexure 7 on detailed transportation plan).
Figure 24: Tire washing System
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Part 6: Audit Findings
In this section the audit illustrates its findings/observations along with comments for each environmental aspect. The observations and comments in a tabular format on the physical environment of the project site illustrated in the Table 6.
The project area is characterised by a long and diverse history of land use. When Anglo American stopped mining in 1977, the mine was donated to Eswatini National Trust Commission (ENTC). The mine was then incorporated into the Malolotja Nature reserve. However, the mine was not rehabilitated before being handed over to ENTC. Dumps were left without any rehabilitation, making them prone to erosion and visual intrusion. Most of the dumps to be processed are within the Malolotja nature reserve.
The remaining dumps of the project site are on either side of the MR3 road, in close proximity to the Ngwenya industrial site. These include some dumps below Etulu Cultural High grounds, which lies on the southern side of Malolotja Nature Reserve (Used as offices during the mining that stopped in 1977). In 2006, the SNTC applied to have the Lion’s Carven listed as one of the World Heritage sites. This saw the Lion Cavern listed in the tentative list of Heritage sites by UNESCO.
Before the operations of Salgaocar, the ENTC had established a museum and interpretation centre for the mine, which was a tourism attraction as well, an educational centre for researchers and students. The interpretation centre was functional during the previous operations of the mine, and a fence was installed to demarcate the mine area protecting tourists from the mine activities. Later in September 2018, after Salgaocar had long abandoned its mining operations, there was a wildfire, which burnt the interpretation Centre and resulting to massive destruction of artefacts inside the museum, even few installations of the processing plants belonging to the mine. The Ngwenya mine site is currently being maintained by the liquidator with the objective of securing the critical assets which were left behind after the non- critical assets were liquidated. Vuka Lilanga Minerals Pty Ltd proposes to reclaim the dumps which were left behind when Salgaocar abandoned its operations, and to rehabilitate the mine. The findings and observations on the land use and work environment are illustrated in Table 7.
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Part 6: Audit Findings 44
Table 6: Physical Environment - Audit Findings and Observations
Environment Observation /Finding Comment Picture
Hydrology-1 • The results from the status-quo indicate A copy of the hydrology results is attached in the Faecal Coliform Faecal Coliform count (/100 ml) some contamination in the streams. appendix. • This is a marked departure from the Limit for Effluent Date Malolotja Dam Ngwenya Ngwenya monitoring results during the past mine Discharge is 10/100 ml Stream Spring operation in 2014 where there was no The presence of Faecal Feb 2019 24 120 73 contamination. coliform bacteria in
aquatic environments Mar 2014 0 0 n/a indicates that the • Water samples collected at (Annex.11):
water has been SPA: Malolotja Dam
contaminated with the SPC. Ngwenya Stream faecal material of man SPD. Ndlotane Stream or other animals. • The levels are however within acceptable limits for body contact but not suitable for drinking.
Hydrology-2 COD (mg/l) • The results from the status-quo indicate a A copy of the hydrology results is attached in the very low chemical oxygen demand in the appendix. Date Malolotja Ngwenya Ngwenya water. Chemical Oxygen Dam Stream Spring • The Malolotja dam, which receives the Demand (COD) Feb 2019 <3 <3 <3 runoff from mine operation, indicates a Limit for effluent value less than 50% of the acceptable Mar 2014 30 33 n/a
discharge 75 mg/l. limit for effluent discharge during the
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Part 6: Audit Findings 45
Environment Observation /Finding Comment Picture
The Chemical oxygen mine operation. In fact, the results from demand (COD) is an the three years suggest that the COD was important gauge of the always below 40mg/l. presence of pollutant • This suggests that indeed the activities in chemical in water. the mine do not result in chemical pollution.
Hydrology-3 Heavy metal (Pb) (mg/L) • The results from the status-quo indicate A copy of the hydrology results is attached in the no heavy metals in the streams. appendix. Heavy Metals (Lead) Date Malolotja Ngwenya Ngwenya • Even from the monitoring during mine Limit for effluent Dam Stream Spring operation there were no traces of toxic discharge 0.1 mg/l. Feb 2019 0.0 0.0 0.0 heavy metals in the water. Lead in a toxic heavy Mar 2014 0.0 0.0 n/a
metal whose high levels leads to health problems.
Air Quality PM10 Dust levels (µg/m3) PARTIAL - COMPLIANT
Date Site 1 Site 2 Site 3 Site 4 Site 5 • According to the PCRs, dust control measures were implemented onsite but Oct because the previous operations were 7.7 5.3 7.7 7.3 7.3 2019 more of dry processes a lot of dust was produced and there were still ongoing Sep n/a 13.0 11.0 12.0 n/a concerns from the public. 2012
Site 1: Ngwenya town; Site 2: Mine Face; Site 3: Jig Plants
Site 4: Stock Yard; Site 5 Ngwenya Glass
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Environment Observation /Finding Comment Picture
• Sprinklers were installed in the stockyard area, increasing the frequency of spraying to at least 4 times a day. • Vacuum sweepers were brought to clean the tarred roads, reducing dust and further minimizing pollution to the air. • Stockyard 1 to highway was tarred to reduce dust emissions.
Noise Pollution • The crushing plant was noisy, ceramic filters, Jig PARTIAL - COMPLIANT plants and screens produced a lot of noise. • According to the PCRs the areas with • Noise from the trucks produced from a number operations above 85 decibels heard of different sources including silencer, brakes, employees wearing their hearing poor suspension and body slap. protection devices. • There is however an outcry from the surrounding businesses and public on the amount of noise which was produce by the trucks in relation to their fitness and speed.
Vibrations • No vibrations observed since mine operations COMPLIANT were long abandoned and evidence proof the • Evidence from PCRs illustrate that there were no high vibrations during the previous was no high vibrating equipment used. operations.
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Environment Observation /Finding Comment Picture
Aesthetics • Poor Aesthetics as a result of no maintenance of PARTIAL - COMPLIANT site and equipment lying idle. There is • According to the last PCR, it states that a overgrown vegetation crowding equipment and detailed rehabilitation plan was being site. finalised for the tailings dumps from • Waste dumps’ tips and fines of stockpiles are a which dumps had been cleared. visual intrusion on site. • Therefore, it can be concluded that if the • No rehabilitation done. mine operations were not abandoned the tailings dumps area would have been rehabilitated.
Soil Pollution • Evidence of soil pollution was found onsite. NON - COMPLIANT • According to the PCRs, Contractors did not comply with the proposed mitigations for prevention of soil pollution. • There were no areas strictly allocated for vehicle services, thus vehicle services were done anywhere.
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Table 7: Land Use & Working Conditions
Service Observation/Finding Comment Picture
• Consumption water tanks found onsite. Portable Water Consumption water was COMPLIANT supplied onsite by the use of • PCRs illustrate no evidence tanks. of shortage or contaminated drinking water supply for consumption during the previous mine operations.
• Electricity There is a connection supply COMPLIANT of electricity through Eswatini • Vuka Lilanga Minerals Pty Ltd Electricity Company. During proposes to utilize the same the abandoned operations, 8 amount of electricity as MvA of electricity was utilized before. monthly. • PCRs show no evidence of in efficient electricity supply on incidents on site resulting from mismanagement of electrical services.
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Service Observation/Finding Comment Picture
• Transport No observations since PARTIAL – COMPLIANT operations were abandoned. • Information provided during the audit from some former employees, suggest transportation of employees to site was obliged to be provided, but some contractors did not observe the obligation.
• Clinic Mobile clinic which was used COMPLIANT during the abandoned • The PCRs provide evidence of operations was found onsite a functional mobile clinic fully during the audit. equipped with equipment and • Information gathered was that a medication available on site. Doctor was made available • It also states that an onsite once a week. ambulance was made available onsite 24 hours each
day.
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Service Observation/Finding Comment Picture
• Sanitation Facilities Flush toilets were seen onsite. PARTIAL – COMPLIANT They were of a bad condition • The PCRs illustrate evidence since they were no longer of 10 flush toilets on site and maintained. provision of chemical toilets • There was no washroom during the previous during the previous operations. operations of the mine. • Vuka Lilanga Minerals Pty Ltd proposes to fix and maintain flush toilets and also provide chemical toilet if need arises. • An abandoned infrastructure has been identified by Vuka Lilanga Minerals Pty Ltd which will be utilized and properly fitted to be used as washrooms.
Building to be utilized as washroom.
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Service Observation/Finding Comment Picture
• Waste Management Evidence of waste PARTIAL – COMPLIANT management signage was • The PCRs show evidence of found onsite. proper management of solid • No visual evidence of littering waste, which was collected or improper solid waste by Ngwenya Town Board management onsite. twice a week for disposal. • Evidence of oil spills from • No Littering policy was drums was found onsite. present onsite and read and interpreted to all employees. • Workers were constantly Waste management sign found on site during audit. educated on proper waste management and good housekeeping onsite.
• Vuka Lilanga Minerals Pty Ltd • Emergency Services No fire emergency equipment proposes to install Fire was seen onsite. Assumption Hydrants and fire are they were removed when extinguishers at strategic the operations ceased. points. • Assembly points will be clearly demarcated and proper signage.
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Service Observation/Finding Comment Picture
• Lightning 10 in number of lightning COMPLIANT arrestors found onsite during • No evidence found on audit. records or PCRs reflecting on incidents or accidents of lightning strikes. Even though the site is at a high altitude, lightning strikes at least three times a year.
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Part 7: Socio Economic Environment
Ngwenya town in which the proposed mining operations is to be established is small but growing town in western Eswatini. In addition to the border post activities it has a few established manufacturing firms, which add to its economic activity. These firms include the world famous Ngwenya Glass, Africa Chicks and Polypack. Peterstow Aqua power a mining equipment manufacturing company closed down in 2014 with negative consequences for this small town. The Old Ngwenya mine’s economic contribution to the area was brought to a virtual standstill after the devastating wild fires September 2018. This fire destroyed not only the visitor’s centre building but also destroyed ancient artefacts.
Figure 26: Abandoned Peterstow Site Figure 25: Burnt Old Iron Ore mine visitors centre
7.1 Surrounding Businesses The surrounding businesses generally acknowledged the negative impact of the non-operation of the mine in relation to economic activity. There are however diverse sentiments that were expressed on some of the environmental impacts during the mine operation.
Vuka Lilanga Minerals Pty Ltd is aware of the challenges incurred by the surrounding businesses during the previous operations of the mine and is committed in implementing sustainable and comprehensive mitigation measures to their challenges. Table 8 illustrates the feedback from the surrounding businesses representatives and audit comments.
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Table 8: Business Community Feedback & Comments from Audit
Business Feedback from Business Representative Comments from the Audit • Comprehensive mitigation measures have been • Ngwenya Glass While increased human traffic could mean more patronage to the facilities food proposed to be implemented to reduce traffic outlets, the environmental impact may have a negative impact. congestion, dust emissions, and noise pollution. • There is anticipated impact of stained buildings as a result of dust from mining • Which when adequately implemented will activities. significantly reduce and to some extent eliminate • Complains that noise and air pollution will be a nuisance to their tourists. the impacts. • They anticipate their solar panels will be negatively impacted by dust. • See attached CMP • There is also a strong perception that they will lose revenue as a result of a decrease in tourists visiting the site due to traffic congestion stresses and dust pollution when the mine is in operation. • The Biodiversity Assessment undertaken during the • Malolotja Nature Reserve It has been suggested that due to land disturbances a number of invasive species course of the audit, evidence the presence of invaded the site area. invasive species (i.e. wattle trees) on the project area • Noise pollution scared animals away from the mining site and have returned after and surrounding areas. the abandoned operations of the mine. • The Biodiversity Assessment illustrate a return of • Some alien species of flora such as the American pampas, wattle trees and bug some fauna species, which had left the area during weed have indeed invaded the area of the abandoned operations. the mine operations. • Malolotja Nature reserve is reported to have spent a budget of about E100 000 to • Vuka Lilanga Minerals Pty Ltd is committed to an destroy the bug weed that had invaded the area, but still invasive species are adequate and sustainable rehabilitation programme present and feared to be spreading. to do away with invasive species and implementing • They anticipate that the large number of wattle trees that have invaded the area mitigations for the protection of Fauna and Flora on causes a large accumulation of debris on the ground making the area prone to a site. See attached CMP fire hazard.
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Business Feedback from Business Representative Comments from the Audit • The business closed down after the mine ceased its • Dukes Investment Managed to grow business and employed over 150 people who were involved in operations and over 150 people lost their jobs. the mine maintenance activities. • Eagerly waiting for resuscitation of mine operations, with the hope of getting a chance to provide maintenance services to the mine. • The previous operations of the mine developed and sustained many surrounding small businesses. • The were no records or evidence presented to the • Old Mine Visitor’s Centre It was anticipated that resuscitating the mine operations would reduce the auditor to show a decline in the number of tourists number of tourists to the Old Mine site. visiting the Old Mine Centre during the previous • Recommended mine operations resuscitate after finalizing process of listing the mine operations from either ENTC records or the Lion Cavern as a world Heritage site. To ensure the country has a listed site in the PCRs. World Heritage site list, which would attract more tourists. • There is also no suggested increase in tourist • ENTC would benefit from being listed by receiving funding for management of The numbers to the site after the mining operations Lion Cavern. ceased. • Media reports suggest ENTC is sourcing funds to rehabilitate the destroyed visitors centre. • Evidence from Liquidator suggests the ENTC was compensated for anticipated loss in the Old Mine Visitors Centre during the operations of the mine.
• During the visit to Africa Chicks business, evidence of • Africa Chicks They anticipate their process equipment will be corroded by water contaminated iron ore dust stained roof was seen by the auditor. with dust particles. • Vuka Lilanga Minerals Pty Ltd is committed to fully • Complained about dust particles accumulating in roof gutters contaminating their implement the proposed mitigation measures of rain harvested water used by the business in its operations. dust suppression. See attached CMP
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Business Feedback from Business Representative Comments from the Audit • During the visit to Poly pack business, evidence of • Poly pack They anticipate impact of reopening of mining operations as an increase communication between the business and its clients in defective product as a result of dust contamination. on default products as a result of dust contamination • The anticipation of their Health and Safety Officer was that if the was presented to the auditor. proposed mining activity doesn’t put in place quality control measures • Vuka Lilanga Minerals Pty Ltd is fully committed into to minimise the amount of dust emitted to the surrounding implementing the proposed mitigation measures of environment, the company will lose customers and has possibility of dust suppression. See attached CMP. closing down causing about 600 job losses.
• The business greatly benefited from the previous • Ready Mixed Concrete Providing service to the mine brought about a vast development in the operations of the mine. business. • Vuka Lilanga Minerals Pty Ltd has plans put in place • At first, they were challenged because of lack of experience in servicing to prevent unexpected closure of the mine. See such a huge activity but with the nature of the work environment they Appendix 1. were exposed to, allowed them to develop and mature in their service. • Vuka Lilanga Minerals Pty Ltd has learnt from the • Nevertheless, the sudden closure of the mine left them indebted. challenges and mistakes of the previous mine operator and has developed Strategies to conquer them.
• The Business greatly benefited economically and • Swazi Medics It brought about a gigantic growth in the business, and the business was experience wise from the previous operations of the able to access loans and equipment, and more clients as a benefit of mine. being associated with the mine operations. • Managed to employ more people than before servicing mine and also
took two of their staff to further their education. • The business is looking forward to a chance of renewing contract with the mine.
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Business Feedback from Business Representative Comments from the Audit • The business greatly benefited economically and • SIMAVSHERQ Socio-Economic impacts which included employment opportunities for experience wise from the previous operations of the about 15 employees from SIMAV SHEQ. mine. • Provision of indirect employment to about 150 people, ratio 1:10 • Skills transfer was observed to locals from the Indian Technicians. The closure of the mine bought negative effects to the business in the sense that they lost income, which came as an unexpected setback. • Complained drinking water was contaminated with dust from the mine. Main • Comprehensive mitigation measures have been Ngwenya Town Board reservoir from which water is stored is close by mine site. proposed to be implemented to reduce traffic • Investor should invest in road maintenance. congestion, dust emissions, and noise pollution. • Previous operations drivers were negligent causing a lot of road accidents. • Comprehensive Road Transportation Plan has been • Too much dust soiling nearby residents’ laundry on clothes lines. prepared which addresses measures to be • There is need to enhance strong monitoring on compliance, and implementation implemented to prevent road accidents. of mitigation measures during mine operations. • Vuka Lilanga Minerals commits to support for the maintenance of roads. • A CMP is developed which when adequately implemented will significantly reduce and to some extent eliminate the impacts. • The CMP includes a monitoring plan, which an independent third party uses to monitor implementation of mitigation measures. • EEA monitors the implementation of mitigation measures and enforce compliance during mine operations. • See attached CMP
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7.2 Eswatini Economy Impact by the Project Mining activity in Eswatini has generally been muted for the past decades. There was a welcome jolt in the activity in 2011 when the Ngwenya iron ore mine started operating in 2011. The Central Bank of Eswatini reports indicate that the Ngwenya Iron ore mi ne contributed significantly to minerals exports during its operations as displayed in Figure 21 below. At the height of its operation in 2012 it also almost single-handedly contributed one billion emalangeni to the Eswatini exports in this sector.
There unfortunately has been no activity to substitute this contribution as can be seen in the period following the mine’s closure in 2014. This gap in the economy is the prevailing status quo.
900 1400 800 1200
Millions 700
1000 Thousands 600 500 800
400 600 300 400 200 200
100 IRON ORE PRODUCTION (Tons)
TotalExport of Value Minerals (SZL) - 0 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 YEAR
Export Value (E) Iro ore production (Tons)
Figure 27: Iron Ore export from Eswatini in ten years and the Quantity
Iron ore production, which commenced in the last quarter of 2011, recorded a 22 percent increase to 1.26 million metric tonnes in 2013 from 1.03 million metric tons in 2012. The iron ore mining company invested a sum of E300 million in 2012 and 2013 commissioning a treatment plant and grinding plant that was aimed at improving its product quality. The completion of the two plants resulted in more iron (and less waste) extracted and transported compared to the previous year when the project was initiated. The improvement in quality significantly enhanced the value of sales of iron ore. Extracts worth E558.6 million were exported to Mainland China in 2013 compared to E393.7 million exported in 2012.
Weak global demand and oversupply kept minerals prices on a downward trend in 2015. Due to the drastic fall in minerals prices particularly iron ore prices, iron ore production was terminated in September 2014 and it remained closed. It is estimated that the closure of the iron ore mine resulted in an average loss of at least E400 million worth of revenue in 2016 alone and this figure is projected to have increased over the years.
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7.3 Economy Boost 7.3.1 Potential payments and levies The following income shown in Table 9 is potentially being lost to Eswatini economy as a result of non- operation of the iron ore mine. This was the contribution that was made during the mining operation.
Table 9: Actual paid out in Royalties and taxes during operating period
CATEGORY VALUE IN (E)
Eswatini Taxes (Personal & Corporate) 11,108,000
Royalties 6,373,429
Sub-Contractors & Service Providers 1,017,873,000
These figures do not include the potential contribution in corporate social investments that the company was reported to be involved in.
7.3.2 Proposed operations An average annual contribution of E50 million is projected in PAYE, taxes and royalties for the first five years of operation. Table 11 below shows projections through the years.
Table 10: Projected Royalties, PAYE and taxes in the first five years of operation
Year 1 Year 2 Year 3 Year 4 Year 5
SNPF & PAYE 1 794 000 1 973 400 2 170 740 2 387 814 2 626 595
Corporate Taxation - 3 750 357 8 498 893 16 608 163 24 067 459
Royalty 15 463 500 38 074 868 39 978 614 41 977 546 44 076 422
Grand Total 17 257 500 43 798 625 50 648 247 60 973 523 70 770 476
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Part 8: Environmental Impacts and Their Evaluation
In assessing the environmental impacts and their evaluation the following rating criteria has been followed:
Evaluation Description Rating Parameter
Low: Within the project site 1 Spatial Medium: Wide spread impact beyond site boundary: local 2 Influence High: Impact widespread far beyond site boundary: Regional/ National 3
Low: Quickly Reversible, Less than project life, short term (0-5 years) 1
Medium: Reversible overtime, medium to life of project (6- 15 years) 2 Duration High: Beyond closure: permanent, irreplaceable or irretrievable commitment 3 of resources
Low: Minor deterioration, nuisance or irritation, minor change in species / 1 habitat / biodiversity or resource or very little quality deterioration.
Medium: Moderate deterioration or discomfort, Partial loss of habitat/ 2 Intensity biodiversity, resources or slight or alterations
High: Substantial deterioration, death, illness or injury, loss of habitat/ diversity 3 or resources, severe alteration or disturbance important processes.
Low: Unlikely, low likelihood, no known risk or vulnerability from natural or 1 induced hazards.
Medium: Possible, distinct possibility, frequent low to medium risk or 2 Probability vulnerability to natural or induced hazards.
High: Definite (Regardless of prevention measures), highly likely, continuous 3 high risk or vulnerability to natural or induced hazards.
Will be deduced from summation of the ratings for spatial influence, duration, intensity and probability with the total defined as follows: Significance 4 -6 Low 7-9 Medium 10 – 12 High
As summarized, each impact will be evaluated according to its spatial influence, duration, intensity and probability. The numbers 1,2 and 3 are used to give a rating in relation to low, medium, and high, respectively.
The description used to arrive at each value is given in the Table above. The sum of the ratings given to each evaluation parameter is used to give significance of each impact evaluated. The significance is then colour coded with sum that ranges between 4 and 6, to
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communicate that the overall evaluation of the impact has a low significance, which is, then colour coded green. A significance sum, which ranges between 7 and 9, is rated as being of medium significance and thus colour coded yellow. A rating with a significance sum that ranges between 10 and 12 denotes a high significance and is colour coded red.
Table 11: Description of Impacts on Fauna & their Evaluation
Description of Impacts on Fauna & their Evaluation
Environmental Impact Activities Spatial Duration Intensity Probability Impact Influence of of of Impact Significance Impact Impact Occurrence
Soil erosion from disturbed Reduction of macro stockpile and other areas invertebrate population in being cleared for loading will 1 2 1 1 5 stream and other animals. cause accumulation of silt in Nearby Streams.
Loss of habitant. (Cats, Disturbed stockpiles and reptile spices). other areas being cleared for 1 1 2 2 6 loading will result in destruction of some fauna habitants. Noise pollution from Displacement of wildlife to crushing, excavation, outside of Malolotja Nature 2 2 2 2 8 transportation will scare the Reserve. animals.
Reduction in the number of Mining operations are most some species, such as likely to increase the amphibians. vulnerability of wild animals 1 2 1 2 6 such as Snakes, leopards,
monkeys.
Sediment deposition in nearby Sedimentation in nearby streams from soil erosion from streams to result in disturbed stockpile and other permanent habitat loss for 1 1 1 1 4 areas being cleared for fish, reptile, amphibian and loading. waterfowl.
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Table 12: Description of Impacts on Flora & their Evaluation
Description of Impacts on Flora & their Evaluation
Environmental Activities Spatial Duration Intensity Probability Impact Impact Influence of Impact of impact of Impact Significance Occurrence
Loss of Mining activities disturb the vegetation. grassland. Removal of vegetation covering waste 1 2 2 3 8 dumps and other areas being cleared for mining activities. Spread of alien Existing stockpiles are invasive laden with wattle seeds, 2 2 2 3 9 species. use as topsoil may lead to more invasion Increased Re-opening and invasion by transportation of stockpiles alien weeds 2 2 2 3 9 into adjoining areas.
Table 13: Description of Impacts on Water Quality & their Evaluation
Description of Impacts on Water Quality & their Evaluation
Environmental Activities Spatial Duration Intensity Probability Impact Impact Influence of Impact of impact of Impact Significance Occurrence
Increase in At the excavation site, metal during the segregation deposition on activity some of the finer the surface and materials containing metals 2 2 3 3 10 metal will be washed away and contamination deposited in nearby of water streams. sources. Loss of water The process requires a large source for volume of water usage. 2 1 3 2 8 downstream communities. Screened out The processes of the jig plants waste water may 2 2 2 2 8 seep onto riparian streams.
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High turbidity Rainy season causing runoffs may impair the from the mine activity site. passage of light, which is 2 1 3 2 7 necessary for photosynthetic activity of aquatic plants.
Table 14: Description of Impacts on Waste Management & their Evaluation
Description of Impacts on Waste Management & their Evaluation
Environmental Activities Spatial Duration Intensity Probability Impact Impact Influence of Impact of impact of Impact Significance Occurrence
Pollution of the New stock of rejected material soil and water will create new dumps and a sources by toxics source of heavy metals. inherently present in the 2 2 2 2 8 iron ore dumps, heavy metals such as mercury, arsenic, lead, zinc, cadmium. Poor aesthetics Improper management of around the site general wastes from canteen and offices. 1 2 1 2 6 Littering by site personnel.
Contamination of Improper management of water sources by hazardous waste. runoffs from 2 2 2 2 8 contaminated soil.
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Table 15: Description of Impacts on Air Quality & their Evaluation
Description of Impacts on Air Quality & their Evaluation
Environmental Impact Activities Spatial Duration Intensity Probability Impact Influence of Impact of impact of Impact Significance Occurrence
Particulate matter is Mechanical handling detrimental to local fish operations, including populations. Polluted crushing, segregation and 2 2 1 1 6 waters by particulate screening processes. matter will affect micro invertebrates in streams. Increase in nitrogen The burning of fuel from oxides, sulphur and machinery and vehicles may particulate matter release gases like oxides of emitted to the nitrogen and sulphur. This is atmosphere will cause air dependent on the quality of Pollution. This will affect fuel used. the neighbouring communities, especially the vulnerable population 3 2 3 2 10 of children, pregnant woman and the sick. Affects their respiratory and cardiovascular systems, causes asthma and other respiratory illness leading to mortality. Dust pollution on the Transportation for loading at natural and built Sidvokodvo. Haulage of environment will cause material by heavy earth moving stained buildings. Dust machines and over loading of will affect surrounding tippers. Wind blow on exposed 2 3 2 2 9 businesses and the surfaces. nearby landscape aesthetics.
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Table 16: Description of Impacts of Noise Pollution & their Evaluation
Description of Impacts of Noise Pollution & their Evaluation
Environmental Impact Activities Spatial Duration Intensity Probability Impact Influence of Impact of Impact of Impact Significance Occurrence
Impaired hearing of A number of large diesel workers, neighboring engine machines working environment and the on the excavation and public during dump trucks carrying transportation. material from the extraction area to the 3 2 3 2 10 processing/dispatch area will generate some noise. Audible reversing warning devices on trucks also generate noise. Scare off animals away The crushing plant can be from site, causing over noisy, Ceramic filters, Jig plants population on next and screens produce a lot of 1 2 3 2 8 area of destination in noise. Malolotja Nature Reserve. Noise will be a Noise from lorries has a nuisance to Tourists number of different sources including silencer, brakes, poor suspension and body slap. Empty trucks are worse than loaded ones; they tend to 2 1 1 2 6 travel faster and be noisier because they suffer from "body-slap" when going over potholes, bumps, or road humps.
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Table 17: Description of Impacts on Aesthetics of site & their Evaluation
Description of Impacts on Aesthetics of site & their Evaluation
Environmental Impact Activities Extent of Duration Intensity Probability Impact Impact of Impact of Impact of Impact Significance Occurrence
Revenues from Inefficient strategies of stock neighboring tourism piles management during 2 2 2 2 8 establishments may fall. project operations will cause poor aesthetics surroundings. Waste tips and fines Mismanagement of Un stockpiles can be a landscaped or vegetated 2 2 2 2 8 significant visual stockpiles. intrusion.
Table 18: Description of Impacts on Land Use & their Evaluation
Description of Impacts on Land Use & their Evaluation
Environmental Impact Activities Extent of Duration Intensity Probability Impact Impact of Impact of Impact of Impact Significance Occurrence
Reduction in size of Processing of dumps will land for Nature lead to loss of a portion of 2 2 2 3 9 Reserve. land for Malolotja Nature Reserve. Increase in soil Improper handling of erosion dumps. 2 2 2 2 8
Soil Contamination Mismanagement of hazardous waste such as 2 2 2 2 8 used oil.
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Table 19: Description of Impacts on Health and Safety & their Evaluation
Description of Impacts on Health and Safety & their Evaluation
Environmental Impact Activities Extent of Duration Intensity Probability Impact Impact of Impact of Impact of Impact Significance Occurrence
Workers on site will be Haulage of material by exposed to dust. (Fly- heavy earth moving rock, particulate machinery. matter). Inhalation of Over loading of dumpers. 1 2 3 2 8 dust may lead to Wind blow on unpaved respiratory diseases. roads and stockpiles of processed material. Dust inhalation will Offloading of iron ore from cause respiratory trucks to railway wagons at 1 2 3 2 8 illnesses. the railway station will produce dust. Occupational Health Improper training of use of and Safety diseases or machinery by employees. / and injuries. Negligence of machinery 1 2 3 2 8 operators and lack of communication between operators. Truck drivers and the Poor driving skills and public will be exposed negligence or/ and poor trucks to road accidents condition. 3 2 3 2 10 during the transportation of mine product. Road infrastructure Vibrations from machinery and damage haulage of trucks off site. 3 3 3 3 12
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Table 20: Description of Impacts on the Economy & their Evaluation
Description of Impacts on the Economy & their Evaluation
Environmental Impact Activities Extent of Duration Intensity Probability Impact Impact of Impact of Impact of Impact Significance Occurrence
Job Creation directly and Setting up (reconstruction) and indirectly through supply Operational phase of the 3 2 3 3 11 chain. project. Increase in income tax, Operational phase of the corporate tax and project. 3 2 3 3 11 royalties Revival of Ngwenya and Operational phase of the surrounding areas project. 2 2 3 3 10 businesses.
Increase in revenue of Operational phase of the the mining sector. project. 3 2 3 3 11
Increase in value of site Rehabilitation phase of the after rehabilitation. project.
Rehabilitation will lead to 1 3 3 3 10 a better-looking site, which is likely to attract more tourists to the Lion Carven.
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Part 9: Comprehensive Mitigation Plan
The Comprehensive Mitigation Plan (CMP) was developed as a document that accompanies the Environmental Audit Report (EAR) that was carried out for the reprocessing and rehabilitation of iron ore dumps at Ngwenya. It demonstrates how Vuka Lilanga Minerals Pty Ltd will ensure that project implementation has minimal negative effects and maximizes positive impacts to the environment. This CMP is a legal document, and Vuka Lilanga Minerals Pty Ltd is obligated by law to implement it.
The document ensures that appropriate mitigation measures are actually implemented and outlines the responsible personnel to implement and monitor. Vuka Lilanga Minerals Pty Ltd will appoint an Environmental Consultancy (EC) to monitor the implementation of this plan and will prepare and submit compliance reports to Eswatini Environmental Authority (EEA) at the times stipulated in the Environmental Compliance Certificate (ECC) for the project.
9.1 Commitment by the Project Proponent Vuka Lilanga Minerals Pty Ltd is committing 1 % of the cost of production as a budget to cater for the implementation of mitigation measures and all uprising environmental issues during the revival of the project.
9.2 Impacts and their mitigate measures Various environmental impacts due to the project activities, corresponding mitigation measures envisaged, responsibility and monitoring authorities are tabulated in tables 21 to 25.
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Table 21: IMPACTS on fauna & their mitigation measures
Impacts on Fauna
Environmental Activities Mitigation Measures Responsible Authority Monitoring Impact Authority • Vuka Lilanga Minerals • Environmental Reduction of macro Soil erosion from disturbed stockpile and other The existing coffer dams should be utilized as silt traps in Pty Ltd Consultant invertebrate areas being cleared for loading will cause order to remove sand/silt particles in suspension and • EEA population in accumulation of silt in Nearby Streams reduce sedimentation in the recipient streams. stream and other animals. • Vuka Lilanga Minerals • Environmental Disturbed stockpiles and other areas being Progressive rehabilitation will be implemented creating cleared for loading will result in destruction of Pty Ltd Consultant Loss of habitant. fauna habitants. some fauna habitants. • Malolotja Nature • EEA
Reserve • Vuka Lilanga Minerals • Environmental Displacement of Noise pollution from crushing, excavation, Rubber linings willl be used in chutes and dumpers to Pty Ltd Consultant birds from project transportation will cause the birds to migrate to reduce impact of noise. an undisturbed environment. • Malolotja Nature • EEA site to outside of Baffle mounds or noise fences will be used to provide Reserve lease area within screening since the area is a noise sensitive environment. Malolotja Nature A buying policy that includes consideration of noise for all Reserve (e.g. Bald new items of plant will be adopted. Ibis). It will be ensured that plant and vehicles are properly
maintained.
Enclosures will be used for noisy plant such as pumps or generators.
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Impacts on Fauna
Environmental Activities Mitigation Measures Responsible Authority Monitoring Impact Authority • Vuka Lilanga Minerals • Environmental Displacement of Mining operations are most likely to increase the Any animal that strays outside of the official nature reserve Pty Ltd Consultant wildlife to outside of vulnerability of wild animals such as Snakes, boundary; these should be captured by specialist game • Malolotja Nature • EEA Malolotja Nature leopards, monkeys. capture teams and relocated to suitable habitat within the Reserve Reserve, causing a Noise pollution from crushing, excavation, main reserve. reduction in the transportation will scare the animals. Strengthen gate security to the mine site. number of some Strengthening of Game patrols to detect early should any species, such as dangerous animals (such as leopard) escape to outside amphibians. communities.
Education and sensitisation of employees and visitors during induction on Game Act and the consequences of illegal actions.
Employees and visitors to be restricted to demarcated routes and working areas only. • • Sediment deposition in nearby streams from soil Vuka Lilanga Minerals Environmental Sedimentation in Periodical removal of silt in dams. Pty Ltd Consultant erosion from disturbed stockpile and other areas • nearby streams to EEA result in permanent being cleared for loading. habitat loss for fish, reptile, amphibian and waterfowl.
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Table 22: IMPACTS on flora & their mitigation measures
Impacts on Flora
Environmental Impact Activities Mitigation Measures Responsible Authority Monitoring Authority
Loss of vegetation. Mining activities disturb the Rehabilitation phase will make use • Vuka Lilanga Minerals Pty Ltd • Environmental Consultant grassland. Removal of vegetation of the indigenous species for re (Ecologist) covering waste dumps and other vegetation. • EEA areas being cleared for mining Employees will be educated and activities. notified on implications of unnecessary removal of vegetation on project site. Spread of alien invasive Existing stockpiles are laden New stockpiles to be kept free of • Vuka Lilanga Minerals Pty Ltd • Environmental Consultant species. with wattle seeds, use as invasive species. (Ecologist) topsoil may lead to more • EEA invasion
Increased invasion by alien Re-opening and transportation All soils and substrates from • Vuka Lilanga Minerals Pty Ltd • Environmental Consultant weeds into adjoining areas. of stockpiles existing stockpile should not be (Ecologist) disposed of in areas where it may • EEA spread seed and exacerbate the alien species invasion problem.
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Table 23: Impacts on Water Quality and mitigation measures
Impacts on Water Quality
Environmental Impact Activities Mitigation Measure Responsible Authority Monitoring Authority
Increase in metal At the excavation site, during the Two check dams have been created in the upstream of • Vuka Lilanga • Environmental deposition on the segregation activity some of the the Catchment Dam downstream of the jigging plant to Minerals Pty Ltd Consultant surface and metal finer materials containing metals will prevent soil erosion and allows the carrying solids to (Process contamination of be washed away and deposited in settle before reaching the downstream. Engineer) water sources. nearby streams. • EEA The accumulated silt in the check dams should be periodically removed by means of excavators and transported to the dump sites to dump along with the tailing material.
Gabion structures coupled with the filtering nets, will add a safer way of arresting any suspended particles. • Vuka Lilanga • Environmental Loss of water source for The process requires a large volume of A new intake point to be created to tap the water for the Minerals Pty Ltd Consultant • downstream communities. water usage. community at downstream of the Catchment dam-2 Community (Process Engineer) outside the lease area. • EEA
The fresh water coming from one of the springs joining the main stream after Catchment Dam-1 will be diverted away from the existing stream and piped to a new intake point, outside the lease area.
• Vuka Lilanga • Environmental Screened out waste water The processes of the jig plants Screened out wastewater will be recycled and re used in Minerals Pty Ltd Consultant may seep onto riparian the process. (Process Engineer) streams. • EEA
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Impacts on Water Quality
Environmental Impact Activities Mitigation Measure Responsible Authority Monitoring Authority
To ensure 99% removal of the solids from the process water, the below equipment is commissioned for the wastewater recycling:
3 de-sliming hydro cyclones with dewatering screens, 2 spirals circuits,30m & 15m thickener, 3 x 50 t/h capacity ceramic disc filters.
All the spillage water will be collected in to a pond and the overflow of that pond will be diverted to another small pond at the lower level (cascading ponds).
A pump has been installed at a bottom pond to pump the water back to the hydro cyclones from where the removal of the solids and recycling water will take place.
• Vuka Lilanga • Environmental High turbidity may impair Rainy season causing runoffs from the Storm water runoff will be collected to the check dams Minerals Pty Ltd Consultant the passage of light, which mine activity site. operating in series. (Process Engineer) is necessary for • Two sediment nets have been installed at the mouth of EEA photosynthetic activity of catchment dam-1 in order to prevent any escaped aquatic plants. sediment from the above check dams going into the catchment dam.
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Table 24: Impacts on Waste Management
Impacts on Waste Management
Environmental Impact Activities Mitigation Measure Responsible Authority Monitoring Authority • Vuka Lilanga • Environmental Pollution of the soil and New stock of rejected material will create Waste tips will be levelled and re-vegetated as soon as Minerals Pty Ltd Consultant water sources by toxics new dumps and a source of heavy metals. possible to prevent wind and water erosion and • EEA inherently present in the contamination of surface waters with suspended solids, iron ore dumps, heavy since non-vegetated waste tips are liable to erosion and metals such as mercury, collapse. arsenic, lead, zinc, cadmium.
• Vuka Lilanga • Environmental Poor aesthetics around the Improper management of general General waste will be separated from hazardous waste by Minerals Pty Ltd Consultant site wastes from canteen and offices. provision of separate bins that will be marked. • EEA
Littering by site personnel. There will be bins placed at strategic points within the project area. These bins will be emptied regularly by the Ngwenya Town Board.
Employees will be educated regularly on waste management.
• Vuka Lilanga • Environmental Contamination of water Improper management of hazardous Hazardous waste bins will be provided on site and workers Minerals Pty Ltd Consultant • sources by runoffs from waste. will be taught on the criteria for identifying hazardous EEA contaminated soil. wastes.
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Part 9: Comprehensive Mitigation Plan 76
Impacts on Waste Management
Environmental Impact Activities Mitigation Measure Responsible Authority Monitoring Authority
All oil and bituminous products such as hydraulic fluids, etc., will be removed from all service areas collected in sealable containers.
When servicing vehicles, drip trays will always be used to prevent oil spills from reaching the ground.
The mine will ensure that used oil will be stored in 210 L drums. The supplier of the oils and bituminous products will take responsibility for transportation of the used oil to designated recycling facilities.
Table 25: Impacts on Air Pollution
Impacts on Air Pollution
Environmental Impact Activities Mitigation Measure Responsible Authority Monitoring Authority
Particulate matter is Mechanical handling operations, Sleeves will also be attached to conveyor belts, wherever • Vuka Lilanga • Environmental detrimental to local fish including crushing, segregation and practicable to prevent the wind picking up dust as the Minerals Pty Ltd Consultant (Air populations. Polluted screening processes. material falls. pollution waters by particulate Regular sprinkling will be carried out to suppress dust Specialist) matter will affect micro within the site and on unpaved haul roads by water • EEA invertebrates in streams. sprinklers.
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Impacts on Air Pollution
Environmental Impact Activities Mitigation Measure Responsible Authority Monitoring Authority
The use of wetting agents to the possible extent at frequent intervals in order to reduce water consumption, to improve retention & reabsorption capacity of water and effective consolidation. Dust pollution on the Transport off site for loading at The trucks will not be overloaded so as to prevent spillage • Vuka Lilanga • Environmental natural and built Sidvokodvo of the ore on the haul roads during transportation. Minerals Pty Ltd Consultant (Air environment will cause All trucks leaving the site will have their tyres thoroughly pollution stained buildings. Dust will washed to remove any ore particles. Specialist) affect surrounding Provision of proper and adequate PPE such as dust masks • EEA businesses and the nearby to employees and visitors to prevent inhaling of polluted landscape aesthetics. air on site. Dust will also affect the All trucks leaving site will be properly covered to prevent neighbouring communities, dust escaping onto the public highways. especially the vulnerable These trucks will also be covered when empty to avoid population of children, the emission of dust from any leftover materials. pregnant woman and the Unpaved haul roads will be graded regularly to remove sick. accumulated loose material.
Increase in nitrogen oxides, The burning of fuel from machinery and Low sulphur fuels will be used in machinery and vehicles • Vuka Lilanga • Environmental sulphur and particulate vehicles may release gases like oxides of diesel engines; this will reduce the sulphur dioxide Minerals Pty Ltd • Consultant (Air matter emitted to the nitrogen and sulphur. This is dependent emissions from all sources. Pollution atmosphere will cause air on the quality of fuel used. Specialist) Pollution Fuel to all trucks will be supplied by the company to • EEA ensure quality of fuel. In light of this Engen has already to Affects their respiratory supply fuel in bulk to the company (See Annexure for and cardiovascular systems, Letter of Support from Engen). causes asthma and other
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Impacts on Air Pollution
Environmental Impact Activities Mitigation Measure Responsible Authority Monitoring Authority
respiratory illness leading The use of good quality trucks, not more than five years to mortality. old.
Ensure servicing of trucks and machinery.
Prevention of unnecessary idling of machinery.
Table 26: Impacts of Noise Pollution and Mitigation Measures
Impacts of Noise Pollution
Environmental Impact Activities Mitigation Measure Responsible Authority Monitoring Authority
Impaired hearing of A number of large diesel engine A buying policy that includes consideration of noise for all • Vuka Lilanga • Health and workers, neighbouring machines working on the excavation new items of plant will be adopted. Minerals Pty Ltd Safety environment and the and dump trucks carrying material Consultant public during from the extraction area to the It will be ensured that plant and vehicles are properly • Environmental transportation. processing/dispatch area will maintained. Consultant generate some noise. • EEA Audible reversing warning devices on Enclosures will be used for noisy plant such as pumps or trucks also generate noise. generators. Scare off animals away The crushing plant can be noisy, Ceramic Rubber linings willl be used in chutes and dumpers to • Vuka Lilanga • Health and from site, causing over filters, Jig plants and screens produce a lot reduce impact of noise. Minerals Pty Ltd safety population on next area of noise. Consultant of destination in Baffle mounds or noise fences will be used to provide • Environmental screening since the area is a noise sensitive environment. Consultant
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Part 9: Comprehensive Mitigation Plan 79
Impacts of Noise Pollution
Environmental Impact Activities Mitigation Measure Responsible Authority Monitoring Authority
Malolotja Nature • EEA Reserve. Noise will be a nuisance Noise from lorries has several different Proper maintenance of the heavy earth moving machinery • Vuka Lilanga • Health and to Tourists. sources including silencer, brakes, poor and vehicles will be practised. Minerals Pty Ltd safety suspension and body slap. Empty trucks Consultant are worse than loaded ones; they tend to Internal haul routes will be kept well maintained and steep • Environmental travel faster and be noisier because they gradients will be avoided. Consultant suffer from "body-slap" when going over • EEA potholes, bumps, or road humps. Speed of moving trucks and other vehicles running in the mine will be limited to moderate speed (20 km/hr) to prevent unnecessary noise.
Vehicles will be fitted with disc brakes which not only enhance braking efficiency but also minimize brake squeal.
Table 27: Impacts of Aesthetics of site area and surroundings
Impacts of Aesthetics of site area and surroundings
Environmental Impact Activities Mitigation Measure Responsible Authority Monitoring Authority
Revenues from Poor aesthetics as a result of inefficient Bringing added value to the site is one of the major • Vuka Lilanga • Environmental neighbouring tourism strategies during the implementation and objectives of the project. Minerals Pty Ltd Consultant establishments may fall. rehabilitation phases of the project. • EEA
Waste tips and fines stockpiles can be a
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Impacts of Aesthetics of site area and surroundings
Environmental Impact Activities Mitigation Measure Responsible Authority Monitoring Authority
significant visual intrusion, Progressive Rehabilitation will be done so that when work especially when it is not in an area is completed, that section is rehabilitated landscaped or vegetated. promptly.
New stockpiles will be sited away from the public and tourists.
Good Housekeeping and proper waste management strategies will be employed to ensure absence of nuisance on site and surroundings.
Table 28: Impacts of Land Use and Mitigation Measures
Impacts of Land Use and Mitigation Measures
Environmental Impact Activities Mitigation Measure Responsible Authority Monitoring Authority
Reduction in size of land Processing of dumps will lead to loss The percentage of land lost will not be significant. • Vuka Lilanga Minerals • ENTC for Nature Reserve. of a portion of land for Malolotja Pty Ltd • Environmental Nature Reserve. There will be sufficient land available, which will not lead Consultant to a significant increase in the animal density per square • EEA metre.
However, this will be monitored over the project period, so that precautions are taken to ensure no overcrowding of animals.
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Impacts of Land Use and Mitigation Measures
Environmental Impact Activities Mitigation Measure Responsible Authority Monitoring Authority
Increase in soil erosion Improper handling of dumps A Storm water management and soil erosion control plan • Vuka Lilanga Minerals • Environmental will be implemented to minimize erosion impacts. Pty Ltd Consultant • EEA Progressive rehabilitation will be practiced ensuring that disturbed areas are not left prone to erosion.
The project will ensure that the site is properly rehabilitated, with proper stabilization measures, and re- vegetation using indigenous flora as opposed to the alien species that have invaded the site.
Heavy machinery will only be used when necessary to minimize soils compaction that may reduce the soil permeability and water holding capacity. Soil Contamination Mismanagement of hazardous waste All oil and bituminous products such as hydraulic fluids, • Vuka Lilanga Minerals • Environmental such as used oil. etc., will be removed from all service areas collected in Pty Ltd Consultant sealable containers. • EEA
When servicing vehicles, drip trays will always be used to prevent oil spills from reaching the ground.
The mine will ensure that used oil will be stored in 210 L drums. The supplier of the oils and bituminous products will take responsibility for transportation of the used oil to designated recycling facilities.
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Table 29: Impacts on Health & Safety and Mitigation Measures
Impacts on Health & Safety and Mitigation Measures
Environmental Impact Activities Mitigation Measure Responsible Authority Monitoring Authority
Workers on site will be Haulage of material by heavy Proper personnel protective equipment (PPE) will be • Vuka Lilanga • Health and given to workers and they will always be educated on the exposed to dust (fly- machines on site. Minerals Pty Ltd Safety importance of using them. rock, particulate Consultant matter). Regularly sprinkling of unpaved roads. • EEA
Inhalation of dust will Offloading of iron ore from trucks to Provision of proper and adequate PPE such as dust masks cause respiratory railway wagons at the railway station to employees and visitors to prevent inhaling of dust diseases. will produce dust. particles. The proponent will comply to Safety, Health and Environment specifications of Eswatini Railway whilst conducting its operations at the railway site.
All machinery and equipment used must have certificate Occupational Health and Mechanical handling operations, of fitness. All personnel operating equipment will be properly trained before using it. Safety diseases or / and including crushing and segregation.
injuries. Improper training of use of Only competent employees will be recruited to perform machinery by employees. mine operations. All employees will undergo medical assessment prior to working in the mine.
Truck drivers and the Poor driving skills and negligence or/ and It will be ensured that the operators are working as per • Vuka Lilanga • Health and public will be exposed poor trucks condition. the statutory hours by imposing strict vigilance over the Minerals Pty Ltd Safety to road accidents during transport contractors. Consultant
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Impacts on Health & Safety and Mitigation Measures
Environmental Impact Activities Mitigation Measure Responsible Authority Monitoring Authority the transportation of Ensuring that traffic congestion during the peak hours of • Eswatini Royal mine product. traffic (morning & evening), is prevented by rescheduling Police trucks at source points itself. • EEA
Signs will be put up on the main roads to warn the public on vehicles moving in and out of site.
Development and implementation of safe operating procedures for the truck operators ferrying the product.
A trucks Service station at the mine will be established to ensure all trucks ferrying product are in good condition and maintained.
The use of GPS Tracking for fleet monitoring coupled with RFID technology for time stamping on the weigh bills with fixed travel time will be ensured. Road infrastructure Vibrations from machinery and haulage of It will be ensured that the carrying load of each truck is as • Vuka Lilanga • Health and damage trucks on site. per the statutory permitted axle load. Minerals Pty Ltd Safety Consultant • Roads Department • EEA
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Table 30: Impacts on the Economy and mitigation measures
Impacts on the Economy
Environmental Impact Activities Mitigation Measure Responsible Authority Monitoring Authority
Job Creation directly and Setting up (reconstruction) and The impact will be enhanced by ensuring that • Vuka Lilanga Minerals • Community indirectly through supply Operational phase of the project. the employment of locals at the different skill Pty Ltd • EIPA chain. levels is maximised. Increase in income tax, Operational phase of the project. Ensuring that taxes and royalties are paid timely • Vuka Lilanga Minerals • ERA corporate tax and royalties and loyally. Pty Ltd
Revival of Ngwenya and Operational phase of the project. Ensuring that first preference of services • Vuka Lilanga Minerals • Community surrounding areas businesses. provision to the mine is given to the surrounding Pty Ltd • EIPA areas businesses.
Increase in revenue of the Operational phase of the project. Ensuring efficiency in production to reduce cost • Vuka Lilanga Minerals • EIPA mining sector. of production and maximise revenue. Pty Ltd
Increase in value of site after Rehabilitation phase of the project. The Rehabilitation Plan will be adequately • Vuka Lilanga Minerals • Environmental Consultant rehabilitation. implemented. Pty Ltd • ENTC • EEA Rehabilitation will lead to a better-looking site, which is likely to attract more tourists to the Lion Carven.
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Part 10: Monitoring 85
Part 10: Monitoring
A monitoring and assessment program are defined as the establishment and operation of appropriate devices, methods, systems and procedures necessary to monitor, compile, and analyse data on the condition of mine environment. Monitoring is the systematic observation and recording of current and changing conditions, while assessment is the use of that data to evaluate or appraise site conditions to support decision-making and planning processes. Mine site can be characterized both by their condition and functions. Under the environmental monitoring programme, the conditions of Hydrological, vibrations, ecological, socio-public impacts and air quality are considered. 10.1 Hydrological Monitoring • Wastewater from process plant will be monitored to ascertain efficiency of Recycling Technique. • Water samples will be taken from surrounding streams and analysed its water quality will be monitored. • Monitoring data will be analysed and reviewed at regular intervals and compared with standards, necessary corrective action will be taken for cases of non-conformity. • Hydrological data collected will be presented in PCR and submitted to EEA quarterly.
10.2 Vibrations Monitoring In the present mining activity even though there is no drilling and blasting the vibrations will be monitored for the other possible activities. • A monitoring unit will be set up periodically and with a few machines movable to monitor any vibrations due to heavy transportation, crushing activities and rock breaking activities. Since the proposed activities will have no high vibrations.
10.3 Ecological Monitoring
Biodiversity Assessment Surveys will be carried out from time to time during the project implementation phase to ascertain the status of threatened and/or protected species as well as impacts on the aquatic species. A Biodiversity Assessment report will be submitted to EEA per annual.
10.4 Socio Economic Impacts Monitoring • A complaint register will be made available at the site offices and the community will be made aware of it. Concerned community members will be register complaints, which will be recorded and followed up on. • A socio-economic impact survey will be carried out every two years after commencement of project.
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10.5 Air Quality Monitoring • For the base line study 12-month weather data has been obtained from the internationally reputed organisation (Lakes Environmental Consultants Inc.) to assess the weather conditions. • A detailed baseline study of the air quality is annexed under Annexure 9. • For collecting the dust levels (PM10) and Aeroqual S500 series instrument has been used and base line data has been collected. • An automatic weather station will be set up on the mine site to monitor the weather conditions and for dust levels Aeroqual S500 will be used. Data from the set-up stations will be periodically collected and analysed, corrective action will be taken in cases where there are spikes in dust levels. • A compiled air quality report will be submitted to the EEA quarterly.
10.6 Independent third party consultation Proponent will engage an Environmental, Health and Safety Consultancy who will have a full-time officer on site to monitor the implementation of mitigation measures in cordination with company’s full-time Environmental Officer.
10.7 Budget allocations for the monitoring activity Vuka Lilanga has budgeted for the following expenditure under the environmental monitoring programme. Table 31: Budgetary allocations for Environmental Monitoring
Area Activity Frequency Budget (SZL) Hydrology Review and analysis of monitoring Monthly 8 000 data and determination of corrective actions. Determination of Water quality for Monthly 10 000 streams around area ( per analysis) Compilation and submission of reports Quarterly 3 500 to the SEA Vibrations Setting up, data collection and report Every six months 24 500 compilation Ecology Assessment, report compilation Annual 40 000 Socio economic Assessment, report compilation Biennial 39 000 Dust Monitoring Installation of dust station and Once off 90 000 weather station Data analysis and report compilation Quarterly 10 000
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Part 11: Rehabilitation 87
Part 11: Rehabilitation
Rehabilitation, from the mining industry perspective, means putting the land impacted by the mining activity back to a sustainable usable condition. Also refers to having the mine area restored to its natural or predetermined state but this is tempered by the qualification that rehabilitation must be practicable. It recognizes that the restoration of what was previously there is simply impossible with current best practice. This definition and implied intention includes the concepts of minimization of loss of land use capability and of net benefit to society. Rehabilitation should be effective, that is to say it must be sustainable in the long term, under normal land management practices. However, the mine closure or rehabilitation activities are to be taken up in compliance with the mineral conservation principles and regulations. Considering the mineral content prevailing in the mine and dumps the rehabilitation of the site is planned with following assumptions:
• Re-opening of the in-situ (main) mine before or after completion of the dumps clearing to avoid double handling of the material • Second stage beneficiation of the coarser tailing material
This project license is granted for reprocessing of the waste dumps that were generated during the previous mining operations and in that process to extract the mineral wealth which is economically feasible in the present terms. From the qualitative and quantitative information available dumps are of about 42% Fe on an average to a quantum of 28 million tons.
After beneficiation of the material from the dumps, the rejects from the processing plants will be stacked at an earmarked area and shall not keep active for long period. In the whole process, the mass recovery of the iron ore estimated is around 40 – 45%, the coarser rejections (Tailings) are about 45% and remaining is the fine size rejections. Among the rejections the coarser size material is having good quality Fe content i.e., up to 45% Fe which could not be discarded as waste. Hence, that material is intended to be preserved as future ore for further process.
11.1 Progressive Rehabilitation The reprocessing of the dumps itself is part of the site rehabilitation. Coarser rejections and fine size rejection will be stocked separately. Dumping will be done in a systematic way. As the reprocessing of the dumps will be ongoing, progressive rehabilitation will be done in stages in the advancing manner i.e., putting new dumps where earlier dumps are cleared, and each stage preferably of 10 meters. The overall slope of the dump will be maintained not exceeding 28° to give dump stability. Upon completion of each stage of dumping, vegetation will be planted on the area whilst processing of dumps in other areas is in progress.
Garland drains shall be constructed to collect silt and sediment flows from the reject dumps whilst preparing for re- vegetation. Garland drains will be connected to check dams to provide adequate retention time to allow proper settlement of silt material.
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Part 11: Rehabilitation 88
Figure 28: Typical Waste Dump Profile Plan
11.2 Re-Vegetation After finalising work on each stage, a topsoil layer will be applied followed by re-vegetation. Vegetation will be selected based on the endemic vegetation of the area. The mechanical method of sowing will be used. An adhesive will be included in the moisture to prevent the seed and fertilizer from blowing, washing or slipping. Mechanical Sowing: ▪ Fertilizer will be spread over the surface and then ploughed. ▪ The surface will then be harrowed until fine seed bed has been prepared. ▪ The seed will be broadcast and then rolled with an agriculture roller.
A mulch of grass cut from the surrounding veld, when the grass is in seed, will also be used. The mulch application rate should be 1 ton/ha.
11.3 Maintenance Monitoring of plant development in revegetated area. The frequency of monitoring required varies according to the phase of plant establishment. Monitoring will be conducted on a weekly basis during the initial phase and can be done on a monthly basis and then a seasonal basis as the plants become established. After planting, the planted areas will be irrigated until the seedling and / or runners have established. Irrigation of established vegetation will only be required if rainfall is poor (less than 300 mm/yr) and / or there is dieback of vegetation.
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Part 12: Conclusions 89
Part 12: Conclusions
The Ngwenya mine had not been fully rehabilitated after mining stopped in 1978. The dumps, including the slime dams left behind after decommissioning of the mine were left unappealing. The proposed project will provide an opportunity for the proper rehabilitation of these dumps.
During the process of reclaiming and rehabilitation of the dumps by the previous operator between 2011 - 2014, the country comprehended significant benefits. During that period significant investment was made to a tune of E300 million which is still lying idle. The proposed mine revival project will bring about employment, increase the national tax pool, provide entrepreneurship opportunities for local contractors, revive businesses around Ngwenya, contribute to the removal of alien invasive species and improve the environment around the mine pit after the rehabilitation is finalised. This will improve tourism in the long term.
There are negative impacts that may arise as the project is implemented. These will include increase human-wildlife conflicts and a disturbance to wild animals in the area. There is also the fear that there may be a decrease in tourism revenues for Eswatini National Trust Commission and neighbouring tourism establishments. There is also the possibility of pollution to water and land. The negative impacts identified will be mitigated and supplemented with effective environmental monitoring. The Vuka Lilanga Minerals Pty Ltd has already committed to spending 1% of the production costs towards environmental sustainability.
It is worth mentioning therefore that if the mitigation measures to the identified impacts are adequately implemented by the Vuka Lilanga Minerals Pty Ltd, the significance of impacts will be greatly reduced and socio economic investment benefits will be realised.
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Part 13: References 90
Part 13: References
1. Swaziland Government, Central Statistical Office, Swaziland Demographic and Health Survey, 2017. 2. Swaziland Environment Authority, Environmental Audit, Assessment and Review Guidelines (Draft), 1999. 3. Swaziland Government, Ministry of Agriculture, Soil Map of Swaziland, 1968. 4. Swaziland Government, Ministry of Agriculture, Geological Map of Swaziland, 1968. 5. Swaziland Government, Swaziland Environment Authority Act, Government Publisher, 1992 6. Swaziland Government, Environmental Management Act, Government Publisher, 2002. 7. Swaziland Government, Water Pollution Control Regulations, Government Publisher, 2010 8. Swaziland Government, Air Pollution Control Regulations, Government Publisher, 2010 9. Swaziland Government, Environmental Audit, Assessment and Review Regulations, Government Publisher, 2000. 10. Swaziland Environment Authority, Compendium of Environmental laws of Swaziland, Swaziland Government Publisher, 2005. 11. Swaziland Government, Occupational Health and safety Act, Government Publisher, 2001 12. Swaziland Government, Soil map of Swaziland, Ministry of Agriculture 13. Swaziland Government, Geological Map of Swaziland, ministry of Natural Resources and Energy 14. Manahan S. E., Environmental Chemistry (7th Ed), Florida, USA, Lewis Publishers, 2000. 15. Kotler P., Keller K. L., Marketing Management (13th Ed.), New Jersey, USA, Pearson Apprentice Hall, 2009. 16. Hansen Inc., Environmental Aspects & Impacts Procedure, downloaded from http://www.familienhansen.co.uk/green/EMS%2001%20Environmental%20Aspects%20Impacts%20P rocedure.pdf on June 15, 2019. 17. About Ngwenya Iron ore mine: http://whc.unesco.org/en/tentativelists/5421/UNESCO site, 31/12/2008 18. World Bank Group, Pollution Prevention and Abatement Handbook: Project Guidelines- Industry Sector Guidelines, July 1998 19. Government of Swaziland (1994): Characteristics and Correlation of the Soils of Swaziland, Land Use Planning for Rational Utilization of Land and Water Resources. Ministry of Agriculture and Cooperatives. Mbabane Swaziland. 20. Mining technology, May 14, 2009, downloaded from http://mining- technology.blogspot.com/2009/05/brief-review-of-iron-ore-beneficiation.html , on may18, 2019 21. Sharma V.M., Environmental Impacts of Iron Ore Mining, downloaded from http://knol.google.com/k/iron-ore-and-its-beneficiation , on May 10, 2019.
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine Annexures 91
Annexures
Annexure – 01: EEA Environment Audit Letter Annexure – 02: Letter of Mining license Grant to Vuka Lilanga Minerals (Pty)Ltd
Annexure – 03: Expression of Interest by Eswatini Railway Annexure – 04: Extract Malagwane Accident Commission Report Annexure – 05: Engen’s Expression of Interest
Annexure – 06: Comprehensive Road Transportation Plan Annexure – 07: Letter from Commissioner of Royal Eswatini Police Annexure – 08: Biodiversity Assessment Report
Annexure – 09: Ambient Air Quality Report Annexure – 10: Erosion & Strom Water Management Report Annexure – 11: Water Quality Baseline Reports
Annexure – 12: Society Involvement
ENVIRONMENTAL AUDIT REPORT - 2019 | Ngwenya Iron Ore Mine