The Reclamation and Reprocessing of the City Deep Dumps in Johannesburg, Gauteng Province

THE RECLAMATION AND REPROCESSING OF THE CITY DEEP DUMPS IN JOHANNESBURG, GAUTENG PROVINCE

DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT

April 2019 DMR Reference: GP 185 MR

DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT

FOR LISTED ACTIVITIES ASSOCIATED WITH THE RECLAMATION OF THE CITY DEEP DUMPS PROJECT IN JOHANNESBURG, GAUTENG PROVINCE

DMR Reference Number: GP 185 MR

APPLICATION FOR ENVIRONMENTAL AUTHORISATION (EA):

SUBMITTED FOR ENVIRONMENTAL AUTHORISATIONS IN TERMS OF THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998 AND THE NATIONAL ENVIRONMENTAL MANAGEMENT WASTE ACT, 2008 IN RESPECT OF LISTED ACTIVITIES THAT HAVE BEEN TRIGGERED BY APPLICATIONS IN TERMS OF THE MINERAL AND PETROLEUM RESOURCES DEVELOPMENT ACT, 2002 (MPRDA) (AS AMENDED).

Name of Applicant: Ergo Mining (Pty) Ltd Tel No: +27 11 742 1003 Postal Address: PO Box 12442, Selcourt, Springs, 1567 Physical Address: Ergo Plant 7th Road, Brakpan File Reference Number: GP 185 MR Document prepared by: Kongiwe Environmental (Pty) Ltd Document Date: April 2019

Draft Environmental Impact Assessment Information

Project: City Deep Dumps Reclamation and Reprocessing Project The reclamation and reprocessing of the City Deep Dumps in Johannesburg, Report Title: Gauteng Province DMR Reference No: GP 185 MR Client: Ergo Mining (Pty) Limited Project No: DRDG#003 Compilation Date: 29 March 2019

Status of Report: Draft Environmental Impact Assessment Report for Public Review

Verification Capacity Name Signature Date

By Author EAP Gerlinde Wilreker 26 February 2019

Project Reviewed by Ashleigh Blackwell 04 March 2019 Manager

Reviewed by: Legal Review Michael Hennessy 26 February 2019

Authorised by Director Bradly Thornton 05 March 2019

Approved By: Ergo Mining Greg Ovens March 2019

Authorised by Ergo Mining Louis Kleynhans March 2019

Copyright © 2019 Kongiwe Environmental (Pty) Ltd All rights reserved. Absolutely no part of this report may be reproduced, distributed, or transmitted in any form or by any means, including photocopying, recording, or other electronic or mechanical methods, without the prior written consent of Kongiwe Environmental (Pty) Ltd. All content and methodologies remain intellectual property of Kongiwe Environmental (Pty) Ltd. Where applicable, the contents of this document are confidential and protected by legal privilege, and must not be distributed to other parties without prior written permission. This report is to be used for the sole purpose intended, and should not be used for any other purpose without prior written permission.

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

SECTION 1:

ENVIRONMENTAL IMPACT ASSESSMENT REPORT OVERVIEW

Important Notice

In terms of the Mineral and Petroleum Resources Development Act, 2002 (Act 28 of 2002), as amended (MPRDA), the Minister must grant a prospecting or mining right if among others the mining “will not result in unacceptable pollution, ecological degradation or damage to the environment”.

Unless an Environmental Authorisation can be granted following the evaluation of an Environmental Impact Assessment and an Environmental Management Programme report in terms of the National Environmental Management Act, 1998 (Act 107 of 1998) (NEMA), it cannot be concluded that the said activities will not result in unacceptable pollution, ecological degradation or damage to the environment.

In terms of Regulation 16(3) (b) of the Environmental Impact Assessment Regulations 2017, any report submitted as part of an application must be prepared in a format that may be determined by the Competent Authority and in terms of Regulation 17 (1) (c) the Competent Authority must check whether the application has considered any minimum requirements applicable or instructions or guidance provided by the Competent Authority to the submission of applications.

It is therefore an instruction that the prescribed reports required in respect of applications for an Environmental Authorisation for listed activities triggered by an application for a right or permit are submitted in the exact format of, and provide all the information required in terms of, this template. Furthermore, please be advised that failure to submit the information required in the format provided in this template will be regarded as a failure to meet the requirements of the Regulations and will lead to the Environmental Authorisation being refused.

It is furthermore an instruction that the Environmental Assessment Practitioner (EAP) must process and interpret his/her research and analysis and use the findings thereof to compile the information required herein. (Unprocessed supporting information may be attached as appendices). The EAP must ensure that the information required is placed correctly in the relevant sections of the Report, in the order, and under the provided headings as set out below, and ensure that the report is not cluttered with un-interpreted information and that it unambiguously represents the interpretation of the applicant.

Objective of the Environmental Impact Assessment Process

1) The objective of the Environmental Impact Assessment process is to, through a consultative process —

(a) determine the policy and legislative context within which the activity is located and document how the proposed activity complies with and responds to the policy and legislative context; (b) describe the need and desirability of the proposed activity, including the need and desirability of the activity in the context of the preferred location; (c) identify the location of the development footprint within the preferred site based of an impact and risk assessment process inclusive of cumulative impacts and a ranking process of all the identified development footprint alternatives focusing on geographical, physical, biological, social, economic, heritage and cultural aspects of the environment; (d) determine the –

I. nature, significance, consequence, extent, duration and probability of the impacts occurring to inform identified preferred alternatives; and II. degree to which these impacts – ❖ can be reversed; ❖ may cause irreplaceable loss of resources; and ❖ can be avoided, managed or mitigated;

(e) identify the most ideal location for the activity within the preferred site based on the lowest level of environmental sensitivity identified during the assessment; (f) identify, assess, and rank the impacts the activity will impose on the preferred location through the life of the activity; (g) identify suitable measures to manage, avoid or mitigate identified impacts; and (h) identify residual risks that need to be managed and monitored.

Environmental Quality

Kongiwe Environmental (Pty) Ltd is committed to Environmental Quality. Environmental Quality refers to the total environment, not just the natural environment. It is a measure of the health of the environment (including the fauna and flora it supports), and of the effects it has on the health, comfort, and psychological state of the people that inhabit it.

Environmental Quality ensures that the value of South Africa’s land is preserved, protected and sustained, and not unacceptably exploited or degraded. All members of this project team, including the appointed specialist professionals, are committed to protecting the environment and encouraging its sustainability.

Kongiwe believes that with the co-operation of the Applicant and Interested and Affected Parties (I&APs) throughout the project process, Environmental Quality can be achieved in for each stage of the City Deep Project.

Public Review Period for the Draft EIA/EMPr Report

Members of the public, local communities, and stakeholders will be invited to comment on the Draft Environmental Impact Assessment and Environmental Management Programme Report (EIA/EMPr) which will be made available for public review and comment from Monday, 01 April 2019 to Monday, 06 May 2019. The Draft EIA/EMPr will also be submitted to the Department of Mineral Resources (DMR) and will be made available at the following locations.

Location Physical Address Contact Person Hard copies Mr Johannes Masenya, Manager Albertina Sisulu Rd & Pixley Ka Greater Johannesburg Library Cell: (061) 438 0153 or (011) 492 Isaka Seme Street, Johannesburg 7071 Electronic copies www.kongiwe.co.za/ public Sibongile Bambisa/ Vanessa Kongiwe Environmental website documents Viljoen), Tel: 010 140 6508 For a CD copy please contact the stakeholder engagement team (Sibongile Bambisa/ Vanessa Viljoen), Tel: 010 140 6508, Email: [email protected]

Policy, Legislation and Conditional Requirements

The Department of Environmental Affairs (DEA) in consultation with the DMR, identified the need for the alignment of Environmental Authorisations and promulgated a single environmental system under the NEMA whereby the DMR has become the Competent Authority for the authorisation of mining- related projects under the EIA Regulations of 2014, as amended in 2017. This has resulted in simultaneous decisions in terms of NEMA, the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) (NEM:WA) and other specific environmental management Acts.

As from 2 September 2014 the statutory dispensation regarding environmental management on mines changed with the implementation of the One Environmental System and the commencement of the National Environmental Management Laws Amendment Act (Act No. 25 of 2014) (NEMLAA). In line with the One Environmental System the EIA Regulations were promulgated and came into force on 8 December 2014, and then were amended in 2017.

This Draft EIA/EMPr is prepared in support of the Environmental Authorisation application and Mining Right Application (MRA) and complies with the requirements of the EIA 2014 Regulations (as amended in 2017) read with the Regulations published in terms of the MPRDA (GNR 527 of 23 April 2004). The proposed City Deep EA process therefore requires Environmental Authorisation in terms of the NEMA and will follow a Scoping and EIA (S&EIA) process in terms of the EIA 2014 Regulations (as amended in 2017). The aforesaid regulations enforce a strict timeframe and require a decision by the Competent Authority, the DMR, within 300 days from submission of the Environmental Authorisation application.

The nature and extent of the project, as well as the potential environmental impacts associated with the construction, operation and decommissioning of a facility of this nature is assessed and presented in this draft EIA/EMPr. This draft EIA/EMPr has been compiled in terms of the provisions of Appendix 2 of the EIA 2014 Regulations (as amended in 2017), and the Directive set out in the template prescribed by the DMR. Table A-1 cross-references the various sections in this report with these requirements.

Table A-1: Structure of the Final EIA Report in line with the Appendix 2 of the EIA 2014 Regulations DMR Report Page NEMA Regulation Requirement Section Number (a) Details of - (i) The EAP who prepared the report and; Section 1.1 1 Section 1.2 1 (ii) The expertise of the EAP, including a CV Appendix A (b) The location of the activity, including – (i) The 21-digit Surveyor General code of each cadastral land parcel Section 2.1 5 (ii) Where available, the physical address and farm name Table 2-1 5 Where the required information in terms of (i) and (ii) is not available, (iii) N/A the coordinates of the boundary of the property or properties

DMR Report Page NEMA Regulation Requirement Section Number an appropriate scale, or, if it is – (i) A linear activity, a description and coordinates of the corridor in which the proposed activity or activities is to be undertaken On land where the property has not been defined, the coordinates (ii) within which the activity is to be undertaken (d) A description of the scope of the proposed activity, including – (i) All listed and specified activities triggered Section 4.4 12 A description of the activities to be undertaken, including associated (ii) Section 4.1 8 structures and infrastructure A description of the policy and legislative context within which the development is located and an explanation of how the proposed (e) Section 5 16 development complies with and responds to the legislation and policy context a motivation for the need and desirability for the proposed development, including the need and desirability of the activity in (f) Section 6 31 the context of the preferred development footprint within the approved site as contemplated in the accepted scoping report A motivation for the preferred development footprint within the (g) Section 7.1 34 approved site as contemplated in the accepted scoping report A full description of the process followed to reach the proposed (h) Section 7 34 preferred activity, site and location within the site, including - (i) Details of the alternatives considered Section 7.1 34 (ii) Details of the public participation process undertaken in terms of Section 8 39 regulation 41 of the Regulations, including copies of the supporting Appendix C documents and inputs (iii) A summary of the issues raised by interested and affected parties, and an indication of the manner in which the issues were incorporated, or Appendix C.9 the reasons for not including them. (iv) The environmental attributes associated with the alternatives focusing on the geographical, physical, biological, social, economic, heritage Section 9 51 and cultural aspects (v) The impacts and risks identified for each alternative, including the nature, significance, consequence, extent, duration and probability of the impacts, including the degree to which these impacts – Section 10.2 158 (aa) can be reversed; (bb) may cause irreplaceable loss of resources; and (cc) can be avoided, managed or mitigated (vi) the methodology used in determining and ranking the nature, significance, consequences, extent, duration and probability of Section 10.1 156 potential environmental impacts and risks (vii) Positive and negative impacts that the proposed activity and alternatives will have on the environment and on the community, that Section 10.2 158 may be affected focusing on the geographical, physical, biological, social, economic, heritage and cultural aspects

DMR Report Page NEMA Regulation Requirement Section Number (viii The possible mitigation measures that could be applied and level of Section 10.2 158 ) residual risk (ix) If no alternative development footprints for the activity were Section 7.2 38 investigated, the motivation for not considering such (x) A concluding statement indicating the preferred alternatives, including Section 7.2.2 38 preferred locations of the activity A full description of the process undertaken to identify, assess and rank the impacts the activity and associated structures and (i) infrastructure will impose on the preferred development footprint Section 10.1 156 on the approved site as contemplated in the accepted scoping report through the life of the activity, including- a description of all environmental issues and risks that were identified (i) Section 10.2 159 during the environmental impact assessment process an assessment of the significance of each issue and risk and an (ii) indication of the extent to which the issue and risk could be avoided Section 10.2 159 or addressed by the adoption of mitigation measures An assessment of each identified potentially significant impact and (j) risk, including- (i) cumulative impacts; (ii) the nature, significance and consequences of the impact and risk; (iii) the extent and duration of the impact and risk; Section 10.2 159 (iv) the probability of the impact and risk occurring; (v) the degree to which the impact and risk can be reversed; (vi) the degree to which the impact and risk may cause irreplaceable loss of resources; and (vii) the degree to which the impact and risk can be mitigated; Where applicable, a summary of the findings and recommendations of any specialist report complying with Appendix 6 to these (k) Section 10.3 221 Regulations and an indication as to how these findings and recommendations have been included in the final assessment report (l) an environmental impact statement which contains- Section 10.5 225 a summary of the key findings of the environmental impact (i) Section 10.5 225 assessment: a map at an appropriate scale which superimposes the proposed activity and its associated structures and infrastructure on the (ii) environmental sensitivities of the preferred development footprint on Figure 7.2 40 the approved site as contemplated in the accepted scoping report indicating any areas that should be avoided, including buffers; and a summary of the positive and negative impacts and risks of the (iii) Table 10-77 230 proposed activity and identified alternatives; Based on the assessment, and where applicable, recommendations from specialist reports, the recording of proposed impact (m) Section 11.2 235 management outcomes for the development for inclusion in the EMPr as well as for inclusion as conditions of authorisation

DMR Report Page NEMA Regulation Requirement Section Number The final proposed alternatives which respond to the impact (n) management measures, avoidance, and mitigation measures Section 7.2.2 38 identified through the assessment; Any aspects which were conditional to the findings of the (o) assessment either by the EAP or specialist which are to be included Section 11.3 236 as conditions of authorisation A description of any assumptions, uncertainties and gaps in (p) knowledge which relate to the assessment and mitigation measures Section 11.1 232 proposed A reasoned opinion as to whether the proposed activity should or should not be authorised, and if the opinion is that it should be (q) Section 11.5 237 authorised, any conditions that should be made in respect of that authorisation Where the proposed activity does not include operational aspects, the period for which the environmental authorisation is required and (r) Section 11.6 237 the date on which the activity will be concluded, and the post construction monitoring requirements finalised

(s) an undertaking under oath or affirmation by the EAP in relation to- Section 11.8 2385

(i) the correctness of the information provided in the reports (ii) the inclusion of comments and inputs from stakeholders and I&APs the inclusion of inputs and recommendations from the specialist (iii) reports where relevant any information provided by the EAP to interested and affected (iv) parties and any responses by the EAP to comments or inputs made by interested or affected parties Where applicable, details of any financial provision for the (t) rehabilitation, closure, and ongoing post decommissioning Section 12 239 management of negative environmental impacts; an indication of any deviation from the approved scoping report, (u) Section 3 7 including the plan of study, including- any deviation from the methodology used in determining the (i) significance of potential environmental impacts and risks; and (ii) a motivation for the deviation; Any specific information that may be required by the competent (v) Section 11.7 238 authority Any other matters required in terms of section 24(4)(a) and (b) of the (w) Section 11.7 238 Act

At the time of printing this Draft EIA/EMPr, no comments had been received from the DMR on the Final Scoping Report. Should comments be received during the Public Participation phase, these will be included and addressed in the Final EIA/EMPr.

Executive Summary

Ergo Mining (Pty) Ltd (Ergo), a wholly owned subsidiary of DRDGOLD - within which the Group’s Eastern surface retreatment assets are consolidated, intends to reprocess and reclaim gold from the existing City Deep Dumps (slimes dams). Ergo holds various Mining Rights (MR) in respect of slimes dams and sand dumps extending 65 km from western Johannesburg to eastern Ekurhuleni, with most activities occurring on the central and eastern sections of the Witwatersrand mining belt.

Kongiwe, an independent and contemporary consulting company, has been appointed to conduct a Scoping and Environmental Impact Assessment (S&EIA) as part of the City Deep Dumps reclamation project. The S&EIA is aimed at critically evaluating the potential environmental, social and economic impacts of the proposed City Deep Dumps Reclamation Project (hereafter the Proposed Project).

Ergo intends to reclaim gold from the City Deep Dumps that currently cover approximately 150 ha in the City of Johannesburg Metropolitan Municipality (CoJMM), situated in central Johannesburg Gauteng Province. The City Deep Dumps are held under the MR 185MR. This EIA serves to authorise Listed Activities in terms of the National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA), which were not listed at the time 185MR and its associated EIA/EMPr were approved.

The dumps will be reprocessed through the approved Ergo Plant with ultimate deposition taking place on the approved Brakpan/Withok Tailings Storage Facility (TSF). They will be reclaimed by a method known as hydraulic monitoring, or, hydraulic mining. A pump station/reclamation station will be established on site and will pump the resultant slurry through new and existing pipelines to the Ergo Plant where it will be reprocessed. One pipeline will transport water to the reclamation site; while another pipeline will convey slurry to an existing pipeline network, where it will ultimately be transported to the Ergo Plant. Process residue from the Ergo Plant will then be disposed of at the Brakpan/Withok Tailings Storage Facility (TSF). This mining method is discussed in greater detail in Chapter 4.1.2.

Evaluation of the City Deep Project

The EIA process comprises of two phases, namely the Scoping Phase and EIA Phase.

❖ The Scoping Phase included the identification of potential issues associated with the City Deep Project through desktop studies, which consider existing information, and consultation with affected parties and key stakeholders. The completed Scoping Phase considered the broader site to identify any potential environmental fatal flaws, “no-go” areas or sensitive areas. Following the public review of the Draft Scoping Report, the Final Scoping Report (FSR), as well as a Plan of Study for EIA (PoSEIA) was submitted to the DMR. The FSR was submitted to the DMR on 11 January 2019, and was expected to be received by 25 February (Regulated 43 days response time as stated in the EIA Regulations, as amended). The acceptance letter had not yet been received at the time of printing of the draft EIA/EMPr.

❖ The EIA Phase involves a detailed assessment of potentially negative direct, indirect and cumulative impacts identified during the Scoping Phase. This phase considers the proposed development footprint and includes detailed specialist investigations, field work and public consultation. Following the review of the Draft EIA/EMPr, this phase culminated in the preparation and submission of the Final EIA/EMPr, including recommendations of practical and achievable mitigation and management measures, to the DMR for review and decision making.

Impacts Associated with the City Deep Project

The table overleaf represents a summary of the significance of impacts identified during the project lifetime for each environmental aspect. Impacts are expected to occur predominantly during the construction and operation phases, and to a lesser extent during decommissioning.

Rating Pre- Rating Post Impact Construction Operation Decommissioning Post closure Construction Operation Decommissioning Post closure Mitigation Mitigation ❖ Topography ❖ Visual (removal of ❖ Groundwater ❖ Water quality ❖ Visual (removal of dumps) Positive (+) Major (high) Major (high) quantity ❖ Groundwater dumps) ❖ Job security ❖ Visual quality ❖ Economic growth ❖ Land use ❖ Topography ❖ Groundwater quality ❖ Water quality ❖ Groundwater Moderate ❖ Job security ❖ Groundwater Moderate ❖ Job security Positive (+) ❖ Job security ❖ Groundwater ❖ AMD removal quality (medium) ❖ Economic growth quantity (medium) ❖ Economic growth quality ❖ Economic growth ❖ Visual ❖ Economic growth ❖ Land use Positive (+) Minor (low) ❖ Economic growth Minor (low) ❖ Topography ❖ Topography No Impact No Impact No Impact ❖ Soil ❖ Soil ❖ Topography ❖ Soil ❖ Biodiversity ❖ Wetlands ❖ Topography ❖ Water Quality ❖ Flora ❖ Soil ❖ Groundwater ❖ Wetlands ❖ Fauna ❖ Groundwater Quality ❖ Water Quality ❖ Wetlands quality ❖ Noise ❖ Air quality ❖ Noise ❖ Noise ❖ Water quality ❖ Noise ❖ Safety ❖ Noise ❖ Heritage ❖ Heritage ❖ Air quality Negative (-) Minor (low) ❖ Heritage ❖ Influx of Job ❖ Air quality Minor (low) ❖ Visual ❖ Air quality ❖ Influx of Job ❖ Health ❖ Noise ❖ Safety seekers ❖ Heritage seekers ❖ Sense of place ❖ Influx of Job ❖ Sense of place ❖ Radioactivity ❖ Heritage (dam ❖ Influx of Job seekers ❖ Influx of Job wall) seekers ❖ Safety seekers ❖ Safety ❖ radioactivity ❖ Radiation ❖ Health ❖ Sense of place ❖ Influx of Job seekers ❖ Radiation ❖ Impacts of AMD ❖ Alien vegetation on biodiversity spread ❖ Biodiversity ❖ Biodiversity ❖ Alien vegetation ❖ Loss of habitat ❖ Wetlands ❖ Flora spread ❖ Wetlands ❖ Water quality ❖ Fauna ❖ Loss of habitat ❖ Water quality Moderate ❖ Air Quality ❖ Wetlands Moderate ❖ Impacts of AMD ❖ Biodiversity Negative (-) ❖ Air quality (medium) ❖ Visual ❖ Water quality (medium) on groundwater ❖ Job security ❖ Visual (mining) ❖ Heritage (dam ❖ Air quality quality ❖ Safety wall) ❖ Job security ❖ Air quality ❖ Health ❖ Health ❖ ❖ Visual(mining) ❖ Sense of place ❖ Safety ❖ Radioactivity ❖ Radioactivity ❖ Nuisance to Biodiversity ❖ Impacts of AMD ❖ Nuisance to Negative (-) Major (high) Major (high) on biodiversity Biodiversity and groundwater quality

Conclusion

Based on the information contained in this report, it is the opinion of the EAP that the negative environmental impacts resulting from the City Deep Project can be mitigated to within acceptable limits and the positive impacts outweigh the negative impacts, thus the project should be authorised.

This opinion holds provided all the recommendations proposed in the specialist studies and the EIA and EMPr as well as legislative requirements are implemented and adhered to.

An impact assessment has been undertaken using qualified specialists, which has incorporated extensive consultation with and participation of interested and affected parties. Applying the hierarchical approach to impact management, alternatives were firstly considered to avoid negative impacts, but where avoidance was not possible, to mitigate and manage negative impacts. Where impacts were found to be potentially significant, various mitigation measures to manage and monitor the impacts of the project have been proposed.

The findings of the impact assessment have shown that the City Deep Project would conclusively result in certain medium negative impacts to the environment during the operational phase, however, none of the specialist studies objected to the project. Moreover, the scientific specialist mitigations measures have been included into this EIA and EMPr to reduce the significance of all the identified negative impacts. Most negative impacts can be reduced through the implementation of mitigation measures.

Furthermore, the removal of the dumps and the rehabilitation of the project area will result in the removal of sources of air, surface water and groundwater pollution, as well as making land available for industrial development.

Table of Contents

1 Details of the EAP ...... 1 1.1 Contact Person and Corresponding Address ...... 1 1.2 Expertise of the EAP ...... 1 1.3 Summary of the EAP’s Past Experience ...... 2 1.4 Additional Project Team Members ...... 2 2 Location and Properties Considered ...... 3 2.1 Description and Location of the Property ...... 3 2.1.1 Description of the Properties affected by the Project ...... 3 2.2 Description of the Current Land Uses Applicable ...... 5 2.3 Other Known Mining Rights Held in the Area ...... 6 3 Deviations from the Approved Scoping Report and Plan of Study ...... 7 4 Description of the Scope of the Overall Activity ...... 8 4.1 Mining and Associated Activities ...... 8 4.1.1 Infrastructure Intended for the Project ...... 9 4.1.2 Mining Method ...... 9 4.2 Rehabilitation ...... 11 4.3 Mine Work Schedule ...... 11 4.4 Listed and Specified Activities ...... 11 5 Policy and Legislative Context ...... 15 6 Need and Desirability of the Proposed Activities ...... 30 6.1 Environmental Pollution ...... 30 6.2 Safety and Security ...... 31 6.3 The Limitation of Spatial Development ...... 31 6.4 Need and Desirability ...... 31 7 Preferred Site Selection ...... 33 7.1 The Consideration of Alternatives ...... 33 7.1.1 The Property on which or Location where it is Proposed to Undertake the Activity ..... 33 7.1.2 The Type of Activity to be Undertaken ...... 33 7.1.3 The Design and Layout of the Activity ...... 36 7.1.4 The Technology to be Used in the Activity ...... 36 7.1.5 The Operational Aspects of the Activity ...... 37 7.1.6 The “No-Go” Option ...... 37 7.2 Project Motivations ...... 37 7.2.1 Motivation for the Alternative Development Location for the City Deep Project ...... 37 7.2.2 Motivation for the Final Proposed Facility Alternative ...... 38 7.3 Motivation where No Alternatives have been considered ...... 39 8 Public Participation ...... 40 8.1 Public Participation Process Objectives ...... 40

8.2 Summary of issues raised by I&AP’s ...... 41 8.3 Identification of Stakeholders ...... 41 8.4 Land Claims ...... 42 8.5 Public Participation Materials ...... 42 8.6 Scoping Phase Consultation ...... 44 8.6.1 Consultation During Draft Scoping Phase ...... 44 8.6.2 Consultation undertaken as part of the Final Scoping Phase ...... 47 8.7 EIA Phase Consultation ...... 48 8.7.1 Draft Document Availability ...... 48 8.7.2 Public Meeting ...... 49 8.7.3 Public Participation Materials ...... 49 8.7.4 Summary of the PPP Activities to be Undertaken during the EIA Phase ...... 50 8.8 Public Participation During the Decision-Making Phase ...... 51 9 The Baseline Environment and Specialist Findings ...... 52 9.1 Climate ...... 52 9.1.1 Rainfall ...... 52 9.1.2 Evaporation ...... 53 9.1.3 Temperature ...... 54 9.1.4 Wind Direction ...... 54 9.2 Topography ...... 57 9.3 Geology ...... 57 9.4 Soils, Land Use, and Land Capability ...... 59 9.4.1 Soils ...... 59 9.4.2 Land Capability ...... 59 9.4.3 Land Use ...... 59 9.5 Biodiversity...... 61 9.5.1 Gauteng Biodiversity Conservation Plan ...... 61 9.5.2 National Biodiversity Assessment ...... 61 9.5.3 Gauteng Ridges ...... 64 9.5.4 Project Area in relation to Protected Areas ...... 65 9.5.5 National Freshwater Ecosystem Priority Area (NFEPA) Status ...... 66 9.5.6 The Gauteng Freshwater Assessment ...... 66 9.5.7 Flora ...... 67 9.5.8 Fauna ...... 73 9.5.9 Sensitivity mapping ...... 76 9.5.10 Current Impacts ...... 77 9.6 Wetlands ...... 78 9.6.1 NRFPA Wetlands ...... 78 9.6.2 City of Johannesburg Wetland ...... 78 9.6.3 Wetland Delineation ...... 79 9.6.4 Wetland Unit Identification ...... 81 9.6.5 Wetland Ecological Functional Assessment ...... 82

9.6.6 The Ecological Health Assessment ...... 83 9.6.7 The EIS Assessment of the Remaining Wetland Areas ...... 83 9.6.8 Buffer Requirements ...... 84 9.7 Surface Water ...... 85 9.7.1 Regional Catchments and Drainage ...... 85 9.7.2 Surface Water Runoff ...... 87 9.7.3 Surface Water Quality ...... 87 9.7.4 Floodlines ...... 93 9.8 Groundwater ...... 95 9.8.1 Conceptual Hydrogeological Model ...... 95 9.8.2 Hydrocensus ...... 96 9.8.3 Groundwater Quality ...... 96 9.8.4 Aquifer Characterisation ...... 98 9.9 Air Quality ...... 98 9.9.1 Health Effects of Particle Pollutants ...... 98 9.9.2 Background PM Concentrations ...... 100 9.9.3 Dispersion Modelling ...... 101 9.9.4 Evaluation of the Status Quo Modelling Results ...... 104 9.9.5 Evaluation of the 4L3 North Cut Modelling Results ...... 106 9.9.6 Evaluation of the 4L3 West Cut Modelling Results ...... 109 9.9.7 Evaluation of the 4L4 South Cut Modelling Results ...... 112 9.9.8 Evaluation of the 4L6 South Cut Modelling Results ...... 115 9.10 Noise ...... 119 9.10.1 Potential Noise Sources ...... 119 9.10.2 Operational Noises – General ...... 123 9.10.3 Potential Noise Sources: Decommissioning Phase ...... 123 9.11 Traffic ...... 123 9.11.1 Surrounding Road Network ...... 123 9.11.2 Existing Traffic Demand ...... 124 9.11.3 Future Traffic Demand ...... 124 9.11.4 Trip Generation ...... 125 9.11.5 Proposed Access Position and Layout ...... 125 9.12 Visual ...... 126 9.12.1 Current Status ...... 126 9.12.2 Triggers and Categorisation ...... 127 9.12.3 Visual Analysis ...... 127 9.12.4 Magnitude of Visual Impact ...... 133 9.13 Heritage and Palaeontology ...... 133 9.13.1 Historical Background ...... 133 9.13.2 Heritage Resource Findings ...... 135 9.13.3 Palaeontological Sensitivity ...... 140 9.14 Social ...... 141

9.14.1 City of Johannesburg Metropolitan-Overview ...... 142 9.14.2 Household Ownership ...... 142 9.14.3 Educational Level ...... 142 9.14.4 Economy and Livelihoods ...... 143 9.14.5 Employment Status ...... 143 9.14.6 Infrastructure ...... 143 9.14.7 Key Challenges with CoJ ...... 145 9.14.8 Anticipated Social Impacts ...... 145 9.15 Radioactivity ...... 148 9.15.1 Radon Pathway ...... 148 9.15.2 Dust Inhalation ...... 149 9.15.3 Water Ingestion...... 149 9.15.4 Total Dose from Pathways ...... 149 10 Impact Assessment ...... 150 10.1 Methodology for Assessing the Significance of Environmental Impacts ...... 150 10.1.1 Part A: Defining Consequence in Terms of Magnitude, Duration and Spatial Scale ... 151 10.1.2 Part B: Determining Consequence Rating ...... 151 10.1.3 Part C: Determining Significance Rating ...... 152 10.2 Impacts and Cumulative Impacts Identified ...... 152 10.2.1 Construction Phase ...... 152 10.2.2 Operational Phase ...... 174 10.2.3 Closure and Decommissioning Phase ...... 194 10.2.4 Post closure Phase ...... 209 10.2.5 Residual Impacts ...... 211 10.2.6 Cumulative Impacts ...... 212 10.3 Summary of Specialist Reports ...... 215 10.3.1 Biodiversity ...... 215 10.3.2 Wetlands ...... 216 10.3.3 Surface Water ...... 217 10.3.4 Groundwater ...... 218 10.3.5 Air Quality ...... 218 10.3.6 Noise ...... 219 10.3.7 Visual ...... 219 10.3.8 Heritage and Palaeontology ...... 220 10.3.9 Socio-Economic ...... 220 10.3.10 Radioactivity ...... 220 10.4 Unplanned Events, Risks and Management Measures ...... 220 10.4.1 Surface Water ...... 220 10.5 Environmental Impact Statement ...... 221 11 Information for Consideration and Inclusion ...... 225 11.1 Assumptions, Uncertainties and Gaps in Knowledge ...... 225 11.1.1 Biodiversity ...... 225

11.1.2 Wetlands ...... 225 11.1.3 Surface Water ...... 225 11.1.4 Air Quality ...... 226 11.1.5 Visual ...... 227 11.1.6 Social ...... 227 11.2 Aspects for Inclusions as Considerations of the Environmental Authorisation ...... 228 11.3 Proposed Management Objectives and Outcomes for Inclusion in the EMPr ...... 228 11.4 Rehabilitation Requirements ...... 229 11.5 A Reasoned Opinion: Should the City Deep Project be Approved? ...... 230 11.6 Period for which Environmental Authorisation is required ...... 230 11.7 Other information requirements ...... 230 11.8 Oath Undertaking ...... 230 12 Financial Provision ...... 232 12.1 Closure Cost methodology ...... 232 12.2 Concurrent Annual Environmental Cost ...... 232 12.3 Closure Cost Year 1 ...... 232 12.4 Year 10 Closure Cost ...... 234 12.5 Total Closure Costs ...... 235 13 Referencing ...... 237

Figures

Figure 2-1: Locality map depicting the location of the Project area...... 4 Figure 4-1: Mobile tracked hydraulic monitor on a tailings facility in South Africa (Source: DRDGold)...... 10 Figure 4-2: Typical mining widths proposed for a gold reclamation project (Source: www.drdgold.com/investors-and-media/circulars/cpr-samrec-wrtrp-26022018.pdf)...... 10 Figure 4-3: Project infrastructure for City Deep Dumps reclamation...... 11 Figure 6-1: GDARD’s Mine Residue Areas decision making tree as illustrated in the Gauteng Mine Areas Strategy (Source: GDARD, 2012)...... 32 Figure 7-1: Mechanical dredging (Source: http://www.3rinc.com/dredging/mechanical-vs-hydraulic- dredging/) ...... 35 Figure 7-2: Sensitivity Mapping ...... 38 Figure 8-1: Public Meeting held at Brakpan Civic Centre ...... 44 Figure 9-1: Average monthly rainfall totals for the project (Rosherville weather station) ...... 52 Figure 9-2: Minimum, average and maximum monthly temperatures for the Project ...... 54 Figure 9-3: Wind rose of the average winds produced by the WRF model for the City Deep reclamation site, for the years 2015-2017...... 55 Figure 9-4: Diurnal wind roses predicted by the WRF model for the City Deep reclamation site, for the years 2015-2017...... 56

Figure 9-5: Seasonal wind roses of winds predicted by the WRF model for the City Deep reclamation site, for the years 2015-2017...... 56 Figure 9-6: Topography of City Deep dumps and surrounding areas (Source: Topographic-Map, 2018)...... 57 Figure 9-7: The geology of the Witwatersrand Basin stripped of younger cover and showing the position of the seven major goldfields (Source: Tucker et al., 2016)...... 58 Figure 9-8: Soil type around the Proposed Project area...... 60 Figure 9-9: Land uses of the Proposed Project site and surrounding areas...... 60 Figure 9-10: City Deep project area superimposed on the Gauteng C-plan...... 61 Figure 9-11: City Deep Dumps project area showing the ecosystem threat status of the associated terrestrial ecosystems (NBA, 2011)...... 63 Figure 9-12: City Deep project area showing the level of protection of terrestrial ecosystems (NBA, 2011) ...... 64 Figure 9-13:The project area in relation to the Gauteng ridge ...... 65 Figure 9-14: Mine dumps in the project area seen as possible ridges...... 65 Figure 9-15: The project area in relation to the National Freshwater Ecosystem Priority Areas ...... 66 Figure 9-16: The City Deep project area in relation to the Gauteng Freshwater Assessment ...... 67 Figure 9-17: The City Deep project area showing the vegetation type based on the Vegetation Map of South Africa, Lesotho & Swaziland (BGIS, 2017)...... 68 Figure 9-18: Map showing the grid drawn to compile an expected species list, while the red blocks indicate the areas where the highest densities were surveyed (BODATSA-POSA, 2016) ...... 69 Figure 9-19: Habitats identified in a general study area ...... 70 Figure 9-20: Habitat sensitivity map of the project area ...... 77 Figure 9-21:Some of the impacts observed in the project area...... 78 Figure 9-22:City of Johannesburg and NFEPA wetland layers within the 500 m regulated area ...... 79 Figure 9-23: Delineation of wetlands within project area ...... 80 Figure 9-24: Wetlands identified within the 500 m regulated area ...... 81 Figure 9-25: 30m buffer requirement ...... 85 Figure 9-26: Regional catchments around the project location...... 86 Figure 9-27: Location of the mines surface water quality monitoring points in the vicinity of the project...... 88 Figure 9-28: Floodline determination and 100 m stream buffer ...... 94 Figure 9-29: Daily average PM10 concentrations for Germiston (SAAQIS, 2018)...... 101 Figure 9-30: Position of the modelled cut areas and the position of modelled discrete receptors. .. 102

Figure 9-31: Modelled prediction of the status quo maximum 24-hour average PM2.5 concentrations, resulting from the City Deep dumps...... 105 Figure 9-32: Modelled prediction of the status quo annual average PM2.5 concentrations resulting from the City Deep dumps...... 105

Figure 9-33: Modelled prediction of the status quo maximum 24-hour average PM10 concentrations resulting from the City Deep dumps...... 105

Figure 9-34: Modelled prediction of the status quo annual average PM10 concentrations resulting from the City Deep dumps...... 105

Figure 9-35: Modelled prediction of the maximum 24-hour average PM2.5 concentrations, resulting from the mining of the north cut of City Deep 4L3...... 107 Figure 9-36: Modelled prediction of the maximum 24-hour average PM2.5 concentrations, resulting from the mining of the north cut of City Deep 4L3 with wet suppression of the graded 15-metre-wide band...... 107 Figure 9-37: Modelled prediction of the annual average PM2.5 concentrations resulting from the mining of the north cut of City Deep 4L3...... 107 Figure 9-38: : Modelled prediction of the annual average PM2.5 concentrations resulting from the mining of the north cut of City Deep 4L3 with wet suppression of the graded 15-metre-wide band...... 107 Figure 9-39: Modelled prediction of the maximum 24-hour average PM10 concentrations resulting from the mining of the north cut of City Deep 4L3...... 108 Figure 9-40: Modelled prediction of the maximum 24-hour average PM10 concentrations resulting from the mining of the north cut of City Deep 4L3 with wet suppression of the graded 15-metre-wide band...... 108 Figure 9-41: Modelled prediction of the annual average PM10 concentrations resulting from the mining of the north cut of City Deep 4L3...... 108 Figure 9-42: : Modelled prediction of the annual average PM10 concentrations resulting from the mining of the north cut of City Deep 4L3 with wet suppression of the graded 15-metre-wide band108 Figure 9-43: Modelled prediction of the maximum 24-hour average PM2.5 concentrations, resulting from the mining of the west cut of City Deep 4L3...... 110 Figure 9-44: Modelled prediction of the maximum 24-hour average PM2.5 concentrations, resulting from the mining of the west cut of City Deep 4L3 with wet suppression of the graded 15-metre-wide band...... 110 Figure 9-45: Modelled prediction of the annual average PM2.5 concentrations resulting from the mining of the west cut of City Deep 4L3...... 110 Figure 9-46: Modelled prediction of the annual average PM2.5 concentrations resulting from the mining of the west cut of City Deep 4L3 with wet suppression of the graded 15-metre-wide band. 110 Figure 9-47: Modelled prediction of the maximum 24-hour average PM10 concentrations resulting from the mining of the west cut of City Deep 4L3...... 111 Figure 9-48: Modelled prediction of the maximum 24-hour average PM10 concentrations resulting from the mining of the west cut of City Deep 4L3 with wet suppression of the graded 15-metre-wide band...... 111 Figure 9-49: Modelled prediction of the annual average PM10 concentrations resulting from the mining of the west cut of City Deep 4L3...... 111 Figure 9-50: Modelled prediction of the annual average PM10 concentrations resulting from the mining of the west cut of City Deep 4L3 with wet suppression of the graded 15-metre-wide band. 111 Figure 9-51: Modelled prediction of the maximum 24-hour average PM2.5 concentrations, resulting from the mining of the south cut of City Deep 4L4...... 113 Figure 9-52: Modelled prediction of the maximum 24-hour average PM2.5 concentrations, resulting from the mining of the south cut of City Deep 4L4 with wet suppression of the graded 15-metre-wide band...... 113

Figure 9-53: Modelled prediction of the annual average PM2.5 concentrations resulting from the mining of the south cut of City Deep 4L4...... 113 Figure 9-54: Modelled prediction of the annual average PM2.5 concentrations resulting from the mining of the south cut of City Deep 4L4 with wet suppression of the graded 15-metre-wide band...... 113 Figure 9-55: Modelled prediction of the maximum 24-hour average PM10 concentrations resulting from the mining of the south cut of City Deep 4L4...... 114 Figure 9-56: Modelled prediction of the maximum 24-hour average PM10 concentrations resulting from the mining of the south cut of City Deep 4L4 with wet suppression of the graded 15-metre-wide band...... 114 Figure 9-57: Modelled prediction of the annual average PM10 concentrations resulting from the mining of the south cut of City Deep 4L4...... 114 Figure 9-58: Modelled prediction of the annual average PM10 concentrations resulting from the mining of the south cut of City Deep 4L4 with wet suppression of the graded 15-metre-wide band...... 114 Figure 9-59: Modelled prediction of the maximum 24-hour average PM2.5 concentrations, resulting from the mining of the south cut of City Deep 4L6...... 116 Figure 9-60: Modelled prediction of the maximum 24-hour average PM2.5 concentrations, resulting from the mining of the south cut of City Deep 4L6 with wet suppression of the graded 15-metre-wide band...... 116 Figure 9-61: Modelled prediction of the annual average PM2.5 concentrations resulting from the mining of the south cut of City Deep 4L6...... 116 Figure 9-62: Modelled prediction of the annual average PM2.5 concentrations resulting from the mining of the south cut of City Deep 4L6 with wet suppression of the graded 15-metre-wide band...... 116 Figure 9-63: Modelled prediction of the maximum 24-hour average PM10 concentrations resulting from the mining of the south cut of City Deep 4L6...... 117 Figure 9-64: Modelled prediction of the maximum 24-hour average PM10 concentrations resulting from the mining of the south cut of City Deep 4L6 with wet suppression of the graded 15-metre-wide band...... 117 Figure 9-65: Modelled prediction of the annual average PM10 concentrations resulting from the mining of the south cut of City Deep 4L6...... 117 Figure 9-66: Modelled prediction of the annual average PM10 concentrations resulting from the mining of the south cut of City Deep 4L6 with wet suppression of the graded 15-metre-wide band...... 117

Figure 9-67: Modelled prediction of the maximum 24-hour average PM2.5 concentrations resulting after the removal of the City Deep dumps...... 118

Figure 9-68: Modelled prediction of the maximum 24-hour average PM10 concentrations resulting after the removal of the City Deep dumps...... 118 Figure 9-69: Aerial image indicating potentially noise-sensitive receptors in the vicinity of the City Deep Dumps reclamation project...... 119 Figure 9-70: Proposed access to site...... 125

Figure 9-71: City Deep Surface Infrastructure Viewshed ...... 128 Figure 9-72: Rosherville Power Station in the foreground and the Rosherville Dam in the Background ...... 135 Figure 9-73: Heritage sites identified during field survey...... 136 Figure 9-74: Regional geology of the proposed City Deep Dumps in Johannesburg, Gauteng Province...... 140 Figure 9-75: Population by highest educational level (Source: Community Survey 2016)...... 143 Figure 9-76: Population by electricity access (Source: Community survey 2016) ...... 144 Figure 9-77: Access to toilet facilities (Source: Community survey 2016) ...... 144 Figure 9-78: Refuse disposal (Source: Community survey 2016) ...... 145 Figure 10-1: Impact prediction model...... 150

Tables

Table 1-1: Details of EAP...... 1 Table 1-2: Kongiwe team members...... 2 Table 2-1: Farms included in the Project area...... 3 Table 2-2: Description of the property...... 4 Table 4-1: Project perspective and technical details...... 8 Table 4-2: Listed activities triggered by the proposed reclamation Project...... 13 Table 5-1: Applicable National Legislation and Guidelines...... 16 Table 5-2: Applicable Provincial and Local Policies, Guidelines and By-Laws ...... 27 Table 7-1: The advantages and disadvantages of Re-mining and reprocessing of gold dumps – Preferred...... 34 Table 7-2: The advantages and disadvantages of hydraulic mining...... 35 Table 7-3: The advantages and disadvantages of mechanical dredging...... 36 Table 8-1: Activities undertaken and to be undertaken during the public participation process ...... 40 Table 8-2: Land Claims on the City Deep Project Area...... 42 Table 8-3: Public places where the Draft Scoping Report could be accessed...... 45 Table 8-4: Summary of PPP activities during the Draft Scoping Phase ...... 46 Table 8-5: PPP activities undertaken during the final scoping phase...... 48 Table 8-6: Public places where the Draft EIA/EMPr and IWULA reports can be accessed ...... 48 Table 8-7: Details of the public meeting ...... 49 Table 8-8: Summary of the PPP activities that will be undertaken during the Draft EIA Phase ...... 50 Table 8-9: PPP activities to be undertaken during the Final Environmental Impact Assessment Phase ...... 51 Table 9-1: Six closest rainfall stations to the project ...... 53 Table 9-2: Storm rainfall depths for the project...... 53 Table 9-3: Symons Pan and open water evaporation for the project...... 54 Table 9-4:Plant Species of Conservation Concern (SCC) expected to occur in the project area (BODATSA-POSA, 2016) ...... 69 Table 9-5: Trees, shrubs and weeds recorded at the proposed project area ...... 71

Table 9-6: A list of avifaunal species recorded for the project area ...... 74 Table 9-7:The mammal species recorded in the project area...... 75 Table 9-8: Wetland classification as per SANBI guideline (Ollis et al. 2013) ...... 81 Table 9-9: The ecosystem services being provided by the HGM units ...... 82 Table 9-10: Ecosystem services scored "High” for the delineated wetland ...... 82 Table 9-11: Summary of the scores for the wetland PES ...... 83 Table 9-12: The EIS results for the delineated HGM types ...... 84 Table 9-13: Estimated peak runoff volumes from the dump areas...... 87 Table 9-14: Location of the mines surface water quality monitoring points in the vicinity of the project...... 87 Table 9-15: Surface water quality results for January and September 2018...... 90 Table 9-16: 2009 Borehole drilling data ...... 96 Table 9-17: Local groundwater qualities - 2011 ...... 97 Table 9-18: Short-term and long-term health effects associated with exposure to PM (WHO, 2004)...... 99 Table 9-23: Dustfall rates predicted by the modelling for discrete receptors...... 103 Table 9-20:Potential maximum noise levels generated by construction equipment ...... 121 Table 9-21: Potential equivalent noise levels generated by various equipment ...... 122 Table 9-22: Visual Impact Criteria results for City Deep ...... 127 Table 9-23: Viewshed evaluation for City Deep results ...... 128 Table 9-24: Viewing Distance of Receptors ...... 129 Table 9-25: Sensitive Viewers within 0-2km of proposed surface infrastructure ...... 129 Table-9-26: Sensitivity of the receptors for the proposed City Deep ...... 130 Table 9-27: Criteria to determine absorption capacity for City Deep...... 133 Table 9-28: Magnitude of Visual Impact results ...... 133 Table 9-29: Sites identified during heritage survey ...... 137 Table 9-30: Palaeontological Sensitivity of various geological supergroups, subgroups and groups (SAHRA, 2018) ...... 140 Table 9-31: Socio-economic baseline information: Gauteng at a glance ...... 141 Table 9-36: Household ownership ...... 142 Table 9-33: Average gold, uranium, sulphur and carbon analysis of typical dump samples (Mintek, 2016)...... 148 Table 10-1: Consequence rating definitions...... 151 Table 10-2: Consequence rating methodology...... 151 Table 10-3: Significance rating methodology...... 152 Table 10-4: Significance rating of construction impacts on topography...... 153 Table 10-5: Significance rating of construction impacts on soil, land use and land capability...... 154 Table 10-6: Significance rating of construction impacts on Biodiversity...... 156 Table 10-7: Significance rating of construction impacts on Flora...... 157 Table 10-8: Significance rating of construction impacts on Fauna...... 157 Table 10-9: Construction impacts on wetlands...... 159 Table 10-10: Summary of activities and impacts for the construction phase ...... 160

Table 10-11: Significance rating of construction impact 1 ...... 160 Table 10-12: Significance rating of construction impact 2 ...... 161 Table 10-13: Significance rating of construction impact 3 ...... 161 Table 10-14: Construction Phase water quality impacts ...... 162 Table 10-15: Construction Phase air quality impacts...... 163 Table 10-16: Impact Assessment: Construction Activities during the day ...... 164 Table 10-17: Significance rating of construction impact 1...... 165 Table 10-18: Significance rating of construction impact 2...... 165 Table 10-19: Significance rating of construction impact 3...... 166 Table 10-20: Impacts on heritage site CTY004 ...... 167 Table 10-21: Impacts on heritage site CTY003 ...... 167 Table 10-22: Impacts on job security and skills development ...... 168 Table 10-23: Impacts on economic growth ...... 169 Table 10-24: Impacts on municipal services ...... 170 Table 10-25: Impacts on safety ...... 171 Table 10-26: Impacts on health ...... 172 Table 10-27: Impacts on sense of place ...... 172 Table 10-28: Radioactivity impacts ...... 173 Table 10-29: Significance rating of operational impact...... 174 Table 10-30: Significance rating of operational impacts on Biodiversity...... 175 Table 10-31: Significance rating of operational impacts on Flora...... 176 Table 10-32: Significance rating of operational impacts on Fauna...... 176 Table 10-33: Construction Phase Impacts on Wetlands ...... 178 Table 10-34: Summary of activities and impacts for the operational phase ...... 179 Table 10-35: Significance rating of operational impact 1 ...... 179 Table 10-36: Significance rating of operational impact 2 ...... 180 Table 10-37: Operational Phase water quality impacts ...... 181 Table 10-38: Impact Assessment: Operational Activities ...... 182 Table 10-39: Impact Assessment: Operational Activities during the day ...... 183 Table 10-40: Impact Assessment: Operational Activities at night ...... 184 Table 10-41: Potential Visual operational Impacts ...... 185 Table 10-42: Significance rating of operational impact 1...... 185 Table 10-43: Significance rating of operational impact 2...... 186 Table 10-44: Significance rating of operational impact 3...... 186 Table 10-45: Impacts on heritage sites ...... 187 Table 10-46: Impacts on Job security...... 188 Table 10-47: Impacts on economic growth ...... 189 Table 10-48: Impacts on municipal services ...... 189 Table 10-49: Impacts on safety ...... 190 Table 10-50: Impacts on health ...... 191 Table 10-51: Impacts on sense of place ...... 192 Table 10-52: Radioactivity impacts ...... 193

Table 10-53: Significance rating of closure and decommissioning impacts on topography...... 194 Table 10-54: Significance rating of closure impacts on Biodiversity...... 195 Table 10-55: Significance rating of closure impacts on Flora...... 195 Table 10-56: Significance rating of closure impacts on Fauna...... 196 Table 10-57: Closure Phase Impacts on Wetlands ...... 197 Table 10-58: Summary of activities and impacts for the closure phase ...... 198 Table 10-59: Significance rating of closure impact 1 ...... 198 Table 10-60: Decommissioning Phase water quality impacts...... 199 Table 10-61: Closure and Decommissioning Phase air quality impacts...... 200 Table 10-62: Closure and Decommissioning Phase noise impacts...... 200 Table 10-63: Potential Visual Closure Impacts ...... 201 Table 10-64: Significance rating of closure and decommissioning impact 1...... 201 Table 10-65: Significance rating of closure and decommissioning impact 2...... 202 Table 10-66: Impacts on heritage site CTY004 ...... 203 Table 10-67: Impacts on Rosherville dam wall ...... 203 Table 10-68: Impact of closure and decommissioning on job security...... 204 Table 10-69: Impact of closure and decommissioning on economic growth...... 205 Table 10-70: Impact of closure and decommissioning on municipal services...... 205 Table 10-71: Impact of closure and decommissioning on land use...... 206 Table 10-72: Impact of closure and decommissioning on safety...... 207 Table 10-73: Radioactivity impacts ...... 208 Table 10-74: Post Closure Phase water quality impacts ...... 209 Table 10-75: Post Closure Phase water quality impacts ...... 210 Table 10-76: Post Closure Phase air quality impacts ...... 210 Table 10-77: Cumulative impact rating for surface water quality ...... 214 Table 10-78: Unplanned events, risks and management measures ...... 221 Table 10-81: Key Findings...... 222 Table 16-1: Rates associated with Closure Components 2018 ...... 233 Table 12-3: Year 1 Unplanned Closure Cost ...... 234 Table 16-3: Rates associated with Closure Components 2018 ...... 234 Table 12-4: Total Closure Provision ...... 235 Table 12-5: Total Closure Provision ...... 236

Appendices

Appendix A: EIA Project Team CV’s

Appendix B: Maps

❖ Locality Map ❖ Site Layout Plans

Appendix C: Public Participation Information

❖ Appendix C1 – I&AP Database ❖ Appendix C2 – Land Claims Letters ❖ Appendix C3 – Background Information Document ❖ Appendix C4 – Newspaper Advert ❖ Appendix C5 – Site Notice Report and Map ❖ Appendix C6 – Announcement Notifications ❖ Appendix C7 – Organs of State Correspondence ❖ Appendix C8 – Minutes of Meetings and Presentations ❖ Appendix C9 – Comments and Responses Report

Appendix D: Specialist Studies

❖ Appendix D1 – Biodiversity: Terrestrial Ecology ❖ Appendix D2 – Biodiversity: Wetlands ❖ Appendix D3 –Surface Water ❖ Appendix D4 – Groundwater ❖ Appendix D5 – Air Quality ❖ Appendix D6 – Noise ❖ Appendix D7 – Visual ❖ Appendix D8 – Heritage ❖ Appendix D10 – Traffic ❖ Appendix D11 – Social ❖ Appendix D12 – Closure and Rehabilitation

Abbreviations

Abbreviation/ Description Symbol ADU Animal Demography Unit AMD Acid Mine Drainage BAR Basic Assessment BID Background Information Document Bq/g Becquerel per gram (Bq/g) CA Competent Authority/Authorities CARA Conservation of Agricultural Resources Act, 1983 (No. 43 of 1983) CBA Critical Biodiversity area CE Critically Endangered City Deep Dumps Slime dumps 4L3, 4 and 6 CoJ City of Johannesburg CoJMM City Of Johannesburg Metropolitan Municipality CRG Central Rand Group CRR Comments and Response Report CSIR Council for Scientific and Industrial Research DAFF Department of Agriculture, Forestry and Fisheries dBA Decibels DEA Department of Environmental Affairs DEM Digital Elevation Model DMR Department of Mineral Resources DRDLR Department Rural Development and Land Reform DSR Draft Scoping Report DWS Department of Water and Sanitation EA Environmental Authorisation EAP Environmental Assessment Practitioner EIA Environmental Impact Assessment EIS Ecological Importance and Sensitivity EMPr Environmental Management Programme EN Endangered ESA Ecological Support Area FEPA Freshwater Ecosystem Priority Areas GDARD Gauteng Department of Agriculture and Rural Development GSDF Gauteng Spatial Development Framework ha Hectare HGM hydrogeomorphic HGM1 Channelled valley bottoms

Abbreviation/ Description Symbol HGM2 Hillslope seeps HMA Heavily Modified Areas I&AP Interested and Affected Party IBA Important Bird and Biodiversity Areas IDP Integrated Development Plan IWULA Integrated Water Use Licence Application IWWMP Integrated Water and Waste Management Plan JRA Johannesburg Roads Agency KBA Key Biodiversity Areas LOM Life of Mine LT Least Threatened µg/m3 Microgram per cubic metre µSv/a Micro Sievert per annum Mamsl Metres above mean sea level MAP Mean annual precipitation MAR Mean Annual Runoff Mbgl metres below ground level Mcm million cubic metres mg/m2/day Milligram per cubic metre per day Mg/L Milligrams per litre MMA Moderately Modified Areas MPRDA Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002) MRA Mining Right Area mSv/a Milli Sievert per annum NAAQS National Ambient Air Quality Standards NBA National Biodiversity Assessment NEMA National Environmental Management Act, 1998 (Act No. 107 of 1998) NEM:AQA National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004) NEM:BA National Environmental Management: Biodiversity Act, 2004 (Act No.10 of 2004) NEM:PAA National Environmental Management: Protected Areas Act (Act No. 57 of 2003) NEM:WA National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) NEMLAA National Environmental Laws Amendment Act, 2014 (Act No. 25 of 2014) NFA National Forest Act, 1998 (Act No 84 of 1998) NFPA National Freshwater Ecosystem Priority Area NGO Non-Governmental Organisations NHRA National Heritage Resources Act, 1999 (Act No. 25 of 1999) NNR National Nuclear Regulator NPAES National Protected Areas Expansion Strategy

Abbreviation/ Description Symbol NPi National Pollutant inventory NSD noise-sensitive developments NT Near Threatened NWA National Water Act, 1998 (Act No. 36 of 1998) ONA Other Natural Area PA Protected Area PES Present ecological status PM Particlulate Matter PoSEIA Plan of Study for EIA PPP Public participation process SAAQIS South African Air Quality Information System SABAP South African Bird Atlas Project SANParks South African National Parks SANS South African National Standards Scoping, Environmental Impact Assessment and Environmental Management S&EIA Programme SAHRA South African Heritage Resources Agency SANBI South African National Biodiversity Institute SCC Species of Conservation Concern SCS Soil Conservation Service SPLUMA Spatial Planning and Land Use Management Act, 2013 (Act No. 16 of 2013) SWMP Surface Water Management Plan TDS Total Dissolved Solids TLB Tip Load Bucket TIA Traffic Impact Assessment TSF Tailings storage facility VAC Visual Absorption Capacity vph Vehicles per hour VU Vulnerable WMA Water Management Area WML Waste Management Licence WRF Weather and Research Forecasting WRG West Rand Group ZOI Zone of Influence

SECTION 2:

ENVIRONMENTAL IMPACT ASSESSMENT REPORT

1 Details of the EAP

Kongiwe Environmental (Pty) Ltd (Kongiwe) is a contemporary, problem-solving consultancy specialising in solving real-world environmental challenges. We pride ourselves in using the latest technology available to realise pragmatic solutions for our clients. The company was created with the essential intent: ‘To solve environmental challenges for a world driven towards a sustainable future’.

Based in Johannesburg, South Africa, our team of professional Environmental Scientists are highly trained in various environmental disciplines and have significant, hands-on experience in an array of projects across various industries. The company has extensive environmental and project management experience in multiple sectors, with significant experience in South Africa, as well as internationally. Kongiwe focuses on the integration of environmental studies and processes into larger engineering and mining projects. Moreover, Kongiwe provides clients with strategic environmental assessments and compliance advice, the identification of environmental management solutions and mitigation / risk minimising measures throughout the Project lifecycle.

1.1 Contact Person and Corresponding Address

Details of the Environmental Assessment Practitioner (EAP) who prepared the report are presented in Table 1-1:

Table 1-1: Details of EAP. Name of Practitioner Gerlinde Wilreker

Address: 150 Bryanson Drive, Bryanston, Johannesburg

Tel No +27 (10) 140 6508

Fax No 086 476 6438

e-mail Address [email protected]

1.2 Expertise of the EAP

Gerlinde Wilreker has an M.Sc. in Environmental Management from the previous Rand Afrikaans University, now the University of Johannesburg, and is a registered Professional Natural Scientist (Environmental Management) (Registration No: 400261/09). She has over twelve years’ work experience, predominantly in the mining industry. Her qualifications are included in Appendix A.

1.3 Summary of the EAP’s Past Experience

Gerlinde Wilreker has over 12 years’ work experience as an environmental consultant, predominantly in the mining industry. Her practical experience in the mining and construction industry has given her a depth of knowledge regarding Project processes from pre-feasibility phase through to implementation. She is adept at working in different contexts, and problem-solving with her team to meet client needs. She has expertise in relation to Environmental Authorisation Processes in terms of the South African legal framework.

1.4 Additional Project Team Members

Team members that have been integral in the successful production of this Environmental Impact Assessment / Environmental Management Programme (EIA/EMPr) are represented in Table 1-2 below.

Table 1-2: Kongiwe team members. Team Member Position in the Company Role and Responsibilities High-Level Project management and report Bradly Thornton Director review.

Ashleigh Blackwell Environmental Consultant Project Manager.

Stakeholder Engagement and all other Public Stakeholder Engagement and Sibongile Bambisa Participation requirements. Social Impact Social Consultant Assessment. Nokuthula Ndala GIS and Environmental Consultant GIS Mapping, Visual Impact Assessment.

Michael Hennessy Associate Legal Consultant Legal review of report documentation.

Assistance with Stakeholder Engagement and Vanessa Viljoen Associate Social Consultant all other Public Participation requirements. Report writing and assistance with Siphesihle Dambuza Environmental Consultant Stakeholder Engagement and all other Public Participation requirements.

2 Location and Properties Considered

2.1 Description and Location of the Property

The City Deep dumps (slimes dumps) 4L3, 4L4 and 4L6 are situated approximately 7 km from the City of Johannesburg (CoJ) and located within the City of Johannesburg Metropolitan Municipality (CoJMM). The surrounding areas are predominantly industrial, commercial, residential and undeveloped land.

The following infrastructure is encountered in the area:

❖ National and provincial roads (N17, N3); ❖ Railways running through the CoJMM; ❖ Power lines; ❖ Water reticulation systems; and ❖ Mine Residue Areas.

2.1.1 Description of the Properties affected by the Project

Ergo holds the Mining Right GP 185 MR, over farms covering approximately 150 ha in the CoJMM, refer to Table 2-1. This Scoping and Environmental Impact Assessment (S&EIA) process is being conducted for an Environmental Authorisation (EA) that will be confined to portions of the farms listed in Table 2-1 and Table 2-2.

Table 2-1: Farms included in the Project area. City Deep Site ❖ Doornfontein 92IR ❖ Elandsfontein 107IR ❖ Rosherville 309IR

Figure 2-1 indicates the locality of the Proposed Project (municipality ward numbers are depicted in the black circles). A3 sized maps of the Project locality are included in Appendix B of this Report.

Figure 2-1: Locality map depicting the location of the Project area.

Table 2-2 below provides a summary of the affected properties under consideration for the City Deep Dumps reclamation and proposed pipeline.

Since this facility is existing, the Project is considered as “Brownfields”. The potential negative and positive impacts of the Proposed Project on the environmental, social (including cultural) and economic aspects will be objectively considered though studies undertaken by specialist professionals.

Table 2-2: Description of the property. Farm Names Farm Name: Portion Landowner The farm Doornfontein 92 IR 89 (RE) Transnet Ltd 1037 Not registered 430 (RE) Transnet Ltd 605 (RE) Transnet Ltd 946 Transnet Ltd 932 Transnet Ltd 86 (RE) Industrial Zone (Pty) Ltd 87 (RE) Industrial Zone (Pty) Ltd The farm Elandsfontein 107 IR 0 (RE) Industrial Zone (Pty) Ltd 35 (RE) Industrial Zone (Pty) Ltd

78 Mediterranean Shipping Co Prop Pty Ltd 39 Municipality Johannesburg 1 (RE) Industrial Zone (Pty) Ltd The farm Rosherville 309 IR 8 (RE) Eskom Rotek Industries Soc Ltd 0 (RE) Eskom Rotek Industries Soc Ltd 2 Eskom Holdings Ltd 19 Not registered

Application Area (ha) 149.9 ha Magisterial District City of Johannesburg Metropolitan Municipality Distance and Direction The Proposed Project is situated 7 km south-east of the City of Johannesburg, in the from Nearest Town Gauteng Province.

21-digit Surveyor General Farm Name: Portion SG Code Code for each Farm Portion The farm Doornfontein 92 IR 89 (RE) T0IR00000000009200089 1037 T0IR00000000009201037 430 (RE) T0IR00000000009200430 605 (RE) T0IR00000000009200605 946 T0IR00000000009200946 932 T0IR00000000009200932 86 (RE) T0IR00000000009200086 87 (RE) T0IR00000000009200087

The farm Elandsfontein 107 IR 0 (RE) T0IR00000000010700000 35 (RE) T0IR00000000010700035 78 T0IR00000000010700078 39 T0IR00000000010700039 1 (RE) T0IR00000000010700001 The farm Rosherville 309 IR 8 (RE) T0IR00000000030900008 0 (RE) T0IR00000000030900000 2 T0IR00000000030900002 19 T0IR00000000030900019

2.2 Description of the Current Land Uses Applicable

The dumps are situated in urban central Johannesburg. The area is surrounded by traditional centres of cities and towns that currently make up the Gauteng urban conurbation like Alberton, Edenvale, Brakpan, Boksburg, Germiston and Springs in Ekurhuleni. The predominant land uses in these areas include commercial, industrial and mining activities.

2.3 Other Known Mining Rights Held in the Area

The assessment of cumulative impacts is required under the EIA Regulations 2014 (as amended in 2017) promulgated in accordance with Section 44 of the National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA). In support of the above, Kongiwe will assess the impact of the Proposed Project in context of other similar activities in the local area. This has been undertaken during this EIA Phase of the Project.

There are several other Mining Rights held within the region. Known Mining Rights adjacent to the Proposed Project area include: The Crown Mining Right (GP184MR), CMR Mining Right (GP186MR), Knights Mining Right (GP187MR) and the Ergo Mining Right (GP158MR). There are also wind and solar developments with approved Environmental Authorisations or applications within 30 km of the proposed area, with EIA reference numbers 14/12/16/3/3/1/569, 12/12/20/2530 and 12/12/20/2551.

3 Deviations from the Approved Scoping Report and Plan of Study

The following deviations from the Scoping Report and Plan of Study have been undertaken:

❖ The representative from the Department of Economic Development of the CoJMM, and the representative of Transnet, requested that a Traffic Impact Assessment (TIA) be undertaken for the Proposed Project. A TIA was initially not included, due to the low number of vehicles anticipated doing construction and the Life of Mine. A TIA has been done and the findings of the TIA have been included in this EIA/EMPr. ❖ Following the findings from the specialists and as a result of the construction of the extension of the Transnet yard, the path of the pipelines from the dumps to the pump station had to be modified. The maps in the EIA/EMPr reflect the amended route.

4 Description of the Scope of the Overall Activity

4.1 Mining and Associated Activities

It is Ergo’s intention to reclaim the City Deep Dumps (Slime dumps 4L3, 4 and 6), utilising the hydraulic mining method, and to reprocess the resultant slurry through the Ergo beneficiation plant (Ergo plant) in Brakpan. A pump station/reclamation station will be established on site and will pump the slurry through existing pipelines to the Ergo Plant where it will be reprocessed. The ultimate disposition will take place on the Brakpan/Withok Tailings Storage Facility (TSF). A detailed description of the mining method is given in Section 4.1.2 which follows.

The City Deep Dumps are situated in City Deep, which is located within urban central Johannesburg. The Dumps may be reached via a network of metropolitan routes and street level tar roads, linked to the N17 and N3. For orientation purposes, the dumps are directly south of the PPC cement factory as one travels along the N3 Highway from Johannesburg to Germiston.

Power will be supplied from the existing Eskom grid, and potable water will be purchased from Rand Water, with a contingency for portable JoJo tanks or connection to an existing water pipeline infrastructure. Process water will be supplied from the existing central water storage facility located in Germiston, and will be transported through existing process water pipelines to City Deep for reuse. The water cycle operates as a closed circuit, with water being recovered from tailings at the Brakpan/Withok TSF.

The expected life of reclamation Project will be at least 15 years. Approximately 500 000 tons/month of dry material is expected to be pumped from City Deep to the Ergo Plant for beneficiation. Currently the Ergo Plant reclaims approximately 2.2 million tons of gold bearing material per month, or 60 000 tons of gold a day.

Information that provides perspective on the scale of the Proposed Project is presented in the table below.

Table 4-1: Project perspective and technical details. Group Specific Details Gold, uranium, nickel, silver, pyrites and all Target Mineral associated minerals in mine tailings dams and dumps. Minable Area MRA: 150 Ha Mining Depth of minerals Tailings material on surface Extent of area for infrastructure 5 ha Product Gold Process water in a closed circuit for hydraulic mining Water demand Resource use and mining activities. Power demand Eskom Staff allocation: construction Continual Development Employment Operating Times 24 hours, 7 days a week

4.1.1 Infrastructure Intended for the Project

As mentioned, the dumps are in existence. Consequently, some of the below mentioned infrastructure may already be established. The following infrastructure will be utilised on site:

❖ Mobile-tracked hydraulic monitors / High-pressure water cannons; ❖ Trenches, penstocks and various other stormwater systems; ❖ Collection sump; ❖ Reclamation station; ❖ Paddocks; ❖ Above-ground slurry pipeline (considered existing); ❖ Return water pipeline (considered existing); ❖ Access roads (some considered as existing); and ❖ Temporary offices, change houses and portable ablution facilities.

4.1.2 Mining Method

The proposed mining method is referred to a top-down hydraulic mining, which uses high-pressure water monitors (or mobile-tracked hydraulic monitors) to deliver a high-pressure water jet to hydraulically excavate consolidated tailings material within the City Deep Dumps. The water from the cannon mixes with the tailings and forms a slurry with a high solids content. The slurry will then flow under gravity, along trenches at the base of the dump to a collection sump at the lowest elevation of the bench being mined. At the sump, finger screens will be used to remove debris that may impact pumping operations, and a penstock will control water flow into the sump. The position of the collection sump will change as mining proceeds. Mining will take place in predetermined benches (or ‘cuts’) and will move unidirectionally until the entire dump has been reclaimed.

To control the volume of slurry reporting to the reclamation station, flapper valves are used that act to hold and release slurry contained in the collection sump. Prior to this slurry reaching the reclamation station, it is first pumped over a finger-screen and then a vibrating screen to remove organic material and debris. The finger-screen underflow slurry will report to a vibrating screen, while the finger-screen overflow will report to the trash bay. The oversized residue from the trash bay will be stockpiled adjacent to the reclamation station, whereas the underflow slurry from the vibrating screen will be pumped to a reception tank at the Ergo Plant.

At the Ergo Plant, the slurry will undergo further screening, via 1mm linear screens before gold extraction and beneficiation can take place.

Figure 4-1: Mobile tracked hydraulic monitor on a tailings facility in South Africa (Source: Ergo).

Figure 4-2: Typical mining widths proposed for a gold reclamation project (Source: www.drdgold.com/investors-and-media/circulars/cpr-samrec-wrtrp-26022018.pdf).

Figure 4-3: Project infrastructure for City Deep Dumps reclamation.

4.2 Rehabilitation

Once reclamation is completed, the area will then be assessed for contamination (particularly in terms of radiation). Contaminated soils will be removed, infrastructure will be removed, and the land will be levelled.

Following reclamation and rehabilitation, it is anticipated that the land will be made available for development according to the zoning of the site – which is industrial.

4.3 Mine Work Schedule

The anticipated life span of the Project is approximately 10 years. It is expected that there would be a 2 year construction and ramp-up period which would include the placement of infrastructure and site preparation, a 5 year Life of Mine (LOM) where active hydraulic mining would take place, a 1 year ramp- down period and 2 years to rehabilitate the reclaimed dumps to red earth.

4.4 Listed and Specified Activities

Listed activities are activities identified in terms of Section 24 of NEMA which are likely to have a detrimental effect on the environment, and which may not commence without an EA from the Competent

Authority (CA). An EA required for a listed activity is subject to the completion of an environmental process, either a Basic Assessment (BA) or a S&EIA.

The City Deep Dumps are held under the MR 185MR. This EIA serves to authorise Listed Activities in terms of the National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA), which were not listed at the time 185MR and its associated EIA/EMPr were approved.

Table 4-2 below contains all the listed activities identified in terms of NEMA, National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008)(NEM:WA), and the EIA Regulations of 2014 (GN R982 of December 2014, as amended by GNR 326 of April 2017) and Listing Notices 1, 2 and 3 (GN R983, GN R984 and GN R985 of December 2014, as amended by GNR 327, GNR 325, and GNR 324 of April 2017, respectively) which may be triggered by the Proposed Project, and for which an application for EA has been submitted. The table also includes a description of those Project activities which relate to the applicable listed activities. The Department of Mineral Resources (DMR) will act as the CA on the Project, while the Commenting Authorities are listed below.

List of Commenting Authorities for City Deep Reclamation Project:

❖ Gauteng Department of Agriculture and Rural Development; ❖ Department of Environmental Affairs; ❖ Department of Water and Sanitation; ❖ Department of Agriculture, Forestry and Fisheries; ❖ Department of Public Works, Roads and Transport; ❖ National Nuclear Regulator; ❖ Department of Health; ❖ South African Heritage Resource Agency and; ❖ City of Johannesburg Metropolitan Municipality.

Table 4-2: Listed activities triggered by the proposed reclamation Project. Waste Water Use Name of activity Aerial Extent of the Applicable Listing Notice as Amended Listed Activity Management Licence Mining Activity (ha/m2)1 GNR 327, GNR 325 or GNR 324 Authorisation Authorisation2 Access roads routed from existing GNR 327 – 24 X entry points. GNR 324 – 4 Temporary site infrastructure X (offices, change house, workshops). 21(c) & (i) The reclamation of slimes at the City Deep Reclamation of the dumps, including: 149.9 ha X GNR 921 – A (12) GN704 TSF is already authorized under GP 185 MR Exemption ❖ Satellite pump station / X GNR 325 – 6 GNR 921 -B (11) reclamation station GNR 327 – 12; 13 ❖ Slurry receiving facility X GNR 325 – 6 GNR 921 -B (1) 21(g) GNR 324 – 2; 14 ❖ Screening facility at the pump X GNR 325 – 6 GNR 921 -B (11) station ❖ Storage X GNR 325 – 6 GNR 921 -B (11)

❖ Transfer pumps in series X GNR 325 – 6 GNR 921 -B (11) Power supply (transformers and 11kV

powerlines) 21(c) & (i) Stormwater systems, including: GN704 Exemption

1 The total area of the mining and associated areas is approximately 149.9 hectares. 2 Water use licences in terms of Section 21 of that National Water Act, 1998, will be required for various of the Listed Activities. These have not been specifically listed in this Application, but the necessary application will be submitted to the Department of Water and Sanitation

Waste Water Use Name of activity Aerial Extent of the Applicable Listing Notice as Amended Listed Activity Management Licence Mining Activity (ha/m2)1 GNR 327, GNR 325 or GNR 324 Authorisation Authorisation2

Paddocks

Process water pipeline X GNR 327 – 9; 19 21(c) & (i)

GNR 327 – 10; 19 Overland slurry pipeline X 21(c) & (i) GNR 325 - 7

5 Policy and Legislative Context

This chapter provides an overview of the policy and legislative context relevant to the reclamation Project. It identifies all legislation, policies, plans, guidelines, spatial tools, municipal development planning frameworks and instruments that are applicable to the planned activities and are to be considered in the assessment process which may be applicable or have relevance to the reclamation Project.

The foundation for Environmental Preservation is entrenched in the Constitution of South Africa (Act No. 108 of 1996). Following the birth of Democracy in South Africa, legislative and environmental policies and regulations have undergone a large transformation, and various laws and policies have been promulgated with a strong emphasis on environmental concerns and the need for sustainable development. The Constitution provides environmental rights (contained in the Bill of Rights, Chapter 2 (Section 24)) and includes implications for environmental management. The environmental rights are guaranteed in Section 24 of the Constitution, and state that:

“Everyone has the right –

❖ To an environment that is not harmful to their health or well-being and ❖ To have the environment protected, for the benefit of present and future generations, through reasonable legislative and other measures that o Prevent pollution and ecological degradation; o Promote conservation and o Secure ecologically sustainable development and use of natural resources while promoting justifiable economic and social development.”

To ensure that the various spheres of the social and natural environmental resources are not over-looked, additional legislation and regulations have been promulgated in addition to those contained within the Constitution. The additional legislature and regulations ensure that there remains a key focus on various industries or components of the environment, and to ensure that the objectives of the Constitution are effectively implemented and upheld on an on-going basis. In terms of Section 7, a positive obligation is placed on the State to give effect to the environmental rights.

Table 5-1: Applicable National Legislation and Guidelines. Applicable Legislation and Guidelines used to Compile the Report Reference where Applied As per the Requirements of NEMA and the The Constitution of South Africa, 1996 (Act 108 of 1996) NEMA EIA Regulations, alternative activities that Section 24 of the Act states that everyone has the right to an environment that is not harmful to their health or well- are less taxing on the environment and being; to have the environment protected for the benefit of present and future generations, through reasonable resources must be investigated where possible. legislative and other measures that prevent pollution and ecological degradation; promote conservation; and secure The DSR & Draft EIA Report will be made ecological sustainable development and use of natural resources while promoting justifiable economic and social available for public review as per the PPP section development. of this report. The Appeal Process will be Section 32 of the Act states that every person has a right to information held by the State and to information held by described to all I&APs through the EA other people that is required in the exercise or protection of a right. notification described in the PPP section of this Lastly, Section 33 of the Act states that everyone has a right to just and procedurally fair administrative action. report. Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002) (MPRDA) Ergo proposes to reclaim the City Deep Dumps The MPRDA contains provisions relating to the reclamation and processing of residue deposits and residue stockpiles. in accordance with the provisions of the MPRDA. This must be read together with the EIA 2014 Regulations, as amended, and the assessment of impacts relating to pollution control, where appropriate, must form part of the EMPr. In terms of the One Environmental System established by the NEMLAA, an EA in respect of a reclamation operation must be issued within 300 days of the application being submitted. Mine Health and Safety Act (MHSA), Act 29 of 1996 (as amended): Although not strictly addressed in the Scoping The mine will operate in accordance to the MHSA and associated regulations. This includes creating a safe and healthy Report or EIA/EMPr, protecting the work environment and providing the necessary protection and training to staff to ensure their health and safety is not environment contributes to a safe working compromised. environment. MHSA regulations will be worked Hazardous substances will be adequately stored and labelled. All regulations pertaining to safe use, handling, processing, into the mine’s Code of Practice (COP) and storage, transport and disposal of hazardous substances; explosives and mixing substances to make explosives; Standard Operating Procedures (SOPs). protection of equipment, structures and water sources and the surface of land; the making safe of undermined ground and dangerous excavations, dumps and structures connected to reclamation operations; the monitoring and control of those environmental aspects which may affect the health and safety of persons will be applied on site. Regulations pertaining to provision of water, ablution facilities and staff health and safety will be applied on site. National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA) It is the objective of this application to align to The overarching principle of the NEMA is sustainable development. It defines sustainability as meaning the integration NEMA.

Applicable Legislation and Guidelines used to Compile the Report Reference where Applied of social, economic and environmental factors into planning, implementation and decision making to ensure the The NEMA is the overarching Act governing development serves present and future generations. Section 2 of NEMA provides for the NEMA principle which apply sustainable development and the NEMA throughout the Republic to the actions of all organs of state that may significantly affect the environment and in principles apply to all prospecting and mining conjunction with other appropriate and relevant considerations. The NEMA principles serve as the general framework operations and any matter or activity relating to within which environmental management and implementation plans must be formulated and serve as a guideline by such operation. reference to which any organ of state must exercise any function when taking any decision in terms of the NEMA or any statutory provision concerning the protection of the environment. In this regard the MPRDA specifically states that the Listed activities as per the EIA 2014 Regulations, NEMA principles apply to all prospecting and mining operations and any matter or activity relating to such operation as amended, have been identified (refer to and serve as guidelines for the interpretation, administration and implementation of the environmental requirements Chapter 4, subsection 4.4). of the MPRDA. NEMA authorises the Minister of the DEA to issue Regulations relating to the administration of the Act3, which has been An Environmental Authorisation was submitted done with the publication of the EIA 2014 Regulations, as amended. Section 24(2) allows the Minister to identify to the DMR as the Competent Authority. This activities which may not commence without environmental authorisation from the competent authority. This application was accompanied by an Integrated identification has been done in accordance with listing notices referred to as Listing Notice 1, Listing Notice 2 and Listing Water use Licence Application to be submitted Notice 3. The NEMA also allows the Minister to determine which authority will be the competent authority to receive to the DWS. and evaluate applications for EAs. Listing Notice 1 identifies activities of limited scale and effect, which need to be assessed by a fairly simple process referred to as a BA, where after a Basic Assessment Report (BAR) is submitted to the competent authority. Listing Notice 2 identifies activities of significantly greater magnitude, which require evaluation through an initial Scoping Phase followed by an EIA and an EMPr. This process is generally referred to as the S&EIR process. Listing Notice 3 relates to activities limited to specified geographical areas and matters of concern to the various provinces which require a BAR process to be dealt with by the provincial authority concerned. Activity 17 of Listing Notice 2 relates to any activity including the operation of that activity which requires a mining right as contemplated in Section 22 of the MPRDA, including associated infrastructure, structures and earthworks, directly related to the extraction of a mineral resource or the primary processing of a mineral resource including winning, extraction, classifying, concentrating, crushing, screening or washing. Accordingly, the application for EA will require the undertaking of a full S&EIR process. All other identified activities will need to be dealt with in accordance with the S&EIR

3 Sections 24(5) and Section 44.

Applicable Legislation and Guidelines used to Compile the Report Reference where Applied process. Regulation 16(1) prescribes the general application requirements and states that an application for an EA must be made on the official application form obtainable from the DMR (the competent authority) and must, amongst others, include proof of payment of the prescribed application fee. Regulation 21 provides for the submission of the Scoping Report to the DMR (the CA) for consideration and states that the scoping report must contain all the information set out in Appendix 2 to the EIA 2014 Regulations, as amended. In terms of regulation 22, the DMR must, after considering the Scoping Report, either accept the report, with or without conditions and advise the applicant to proceed with the plan of study for EIA or refuse the EA. Once the Scoping Report is accepted by the DMR, the applicant must submit the EIA Report inclusive of specialist reports and an EMPr which have been subjected to a PPP. The timeframes for submission of the Scoping Report and the EIA Report inclusive of the timeframes within which the DMR must consider the reports and approve the EA are prescribed in regulations 21 to 24 of the EIA 2014 Regulations. Once a decision on the EA application has been reached, the DMR (the competent authority) must notify the applicant in writing of the decision and give reasons for the decision. National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) (NEM: WA) Listed activities as per the NEM: WA regulations As part of the waste management matters dealt with in the NEM: WA, waste activities have been identified in GN 921 have been identified (refer to Chapter 4, of 29 November 20134: List of Waste Management Activities that have, or are likely to have, a Detrimental Effect on the subsection 4.4). Environment. GN R921 provides that the waste management activities listed in Category A and B thereof may not commence, be undertaken or conducted without a Waste Management Licence (WML). Activities listed in Category C of GN 921 may only be commenced with, undertaken or conducted in accordance with the National Norms and Standards published in terms of the NEM: WA.5 Accordingly, the reclamation of the City Deep Dumps requires a Waste Management License (WML) authorising activity 4(11) in Category B of GN 921.In addition to the requirement for a WML for the TSF reclamation, Category A activities require a BAR process while Category B Activities require a S&EIR process. It should be noted that previously, residue deposits and residue stockpiles were regulated in terms of the MPRDA Regulations6 and in particular Regulation 73.

4 Published in Government Gazette 37083 5 The following National Norms and Standards have been published: Norms and Standards for Storage of Waste, 2013 (GN 926 of 29 November 2013); Standards for Extraction, Flaring or Recovery of Landfill Gas, 2013 (GN 924 of 29 November 2013); and Standards for Scrapping or Recovery of Motor Vehicles, 2013 (GN 925 of 29 November 2013 6 GN R527 of 2004

Applicable Legislation and Guidelines used to Compile the Report Reference where Applied However, with the commencement of the NEMLAA section 4(b) of the NEM: WA has been deleted and as such the NEM: WA now regulates residue stockpiles and residue deposits. In line with the aforesaid amendment, GN 921 was amended by GN 632 of 24 July 2015 by including Activity B 4(11) which provides for “the establishment or reclamation of a residue stockpile or residue deposit resulting from activities which require a mining right, exploration right or production right in terms of the MPRDA”. Accordingly, the establishment of a residue stockpile (as defined in Schedule 3 of the NEM: WA) requires a WML authorising activity 4(11) in Category B of GN 921. The Proposed Project will also need to comply with GN R632 of 24 July 2015, as amended by GN R990 of 21 September 2018, must be adhered to. These regulations regulate the assessment of impacts and analyses of risks relating to the management of residue stockpiles and residue deposits, the characterisation of residue stockpiles and residue deposits, the classification of residue stockpiles and residue deposits, the investigation and selection of site for residue stockpiling, the design of the residue stockpiles and residue deposits, impact management, the duties of the holder of right/ permit, the monitoring and reporting system for residue stockpiles and residue deposits, dust management and control, decommissioning, closure and post closure management of residue stockpiles and residue deposits. The EA and WML are being dealt with as integrated application. National Water Act, 1998 (Act No. 36 of 1998) (NWA) An IWULA and IWWMP are required for the In terms of the NWA, the national government, acting through the Minister of Water and Sanitation, is the public trustee Proposed Project and will be submitted to the of South Africa’s water resources, and must ensure that water is protected, used, development, conserved, managed DWS. and controlled in a sustainable and equitable manner for the benefit of all persons (section 3(1)). In terms of the NWA a person may only use water without a license if such water use is permissible under Schedule 1 (generally domestic type use) if that water use constitutes a continuation of an existing lawful water use (water uses being undertaken prior to the commencement of the NWA, generally in terms of the Water Act of 1956), or if that water use is permissible in terms of a general authorisation issued under section 39 (general authorisations allow for the use of certain section 21 uses provided that the criteria and thresholds described in the general authorisation is met). Permissible water use furthermore includes water use authorised by a license issued in terms of the NWA. Section 21 of the NWA defines water uses which are governed in terms of the Act and for which a WUL is required. In terms of section 40 (1) of the NWA “a person who is required or wishes to obtain a licence to use water must apply to the relevant responsible authority for a licence.” These water uses, in terms of Section 21, are as follows: (a) taking water from a water resource; (b) storing water;

Applicable Legislation and Guidelines used to Compile the Report Reference where Applied (c) impeding or diverting the flow of water in a watercourse; (d) engaging in a stream flow reduction activity contemplated in Section 36; (e) engaging in a controlled activity identified as such in Section 37(1) or declared under Section 38(1); (f) discharging waste or water containing waste into a water resource through a pipe, canal, sewer, sea outfall or other conduit; (g) disposing of waste in a manner which may detrimentally impact on a water resource; (h) disposing in any manner of water which contains waste from, or which has been heated in, any industrial or power generation process; (i) altering the bed, banks, course or characteristic of a watercourse; (j) removing, discharging or disposing of water found underground if it is necessary for the efficient continuation of an activity or for the safety of people; and (k) using water for recreational purposes. It is not likely that sub-sections (a), (d), (e), (f), (h), (j) or (k) will apply to the Proposed Project. Water uses associated with the reclamation activities, may include the development of emergency control dams, dust suppression and the storage and use of process and potable water. These water uses will require an IWUL and will be reassessed once final placement and conceptual designs have been completed. The IWULA must be prepared and submitted in accordance with the Water Use Licence Application and Appeals Regulations 2017 published in GNR 267 on 24 March 2017 and must generally be supported by a Technical Report and Integrated Water and Waste Management Plan (IWWMP) with conceptual design drawing of all water related infrastructure including infrastructures that could potentially contaminate the receiving environment. National Environmental Management: Biodiversity Act, 2004 (Act No.10 of 2004) (NEM:BA) NEM:BA was used to inform the activities The NEM:BA provides for the management and conservation of South Africa’s biodiversity within the framework of triggered by Listing Notice 3 (refer to Chapter 4, NEMA, as well as the protection of species and ecosystems that warrant national protection and the sustainable use of subsection 4.4). indigenous biological resources. SANBI website and GIS tools were utilised to determine whether any nationally protected and threatened ecosystems occur on site. Therefore, NEMA Listing Notice 3 activities have been included in the EA application. National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004) (NEM: AQA) An Air Quality Impact Assessment (AQIA) was The NEM: AQA came into effect in April 2010 and is applied in accordance with the principals stipulated in NEMA. The completed as part of the EIA Phase to Act outlines norms and standards with regards to air quality management planning, monitoring, compliance and investigate, assess and evaluate the impact of

Applicable Legislation and Guidelines used to Compile the Report Reference where Applied management measures to protect and enhance the quality of air and reduce risks to human health. NEM: AQA also particulate matter on the environment. promotes sustainable development. The National Ambient Air Quality Standards were published on 24 December 2009 and provide inter alia for national ambient air quality standards for PM10. In addition to these standards, the National Ambient Air Quality Standards for

PM2.5 came into effect on 29 June 2012. The Standards do not provide for the reporting of exceedances. The National Dust Control Regulations, 2013 (GNR 827 of 1 November 2013) provide acceptable dust fall rates at and beyond the boundary of the premises where dust originates. The dust fall-out rates are measured using the American Standard for Testing Materials method D1739 (ASTM D1739:1970) which provides that dust fall out at the boundary or beyond the boundary of the premises where it originates cannot exceed - 600 mg/m2/day averaged over 30 days in residential areas; or 1200 mg/m2/day averaged over 30 days in non-residential areas. Permitted exceedances are provided for. National Environmental Management: Protected Areas Act (NEM:PAA), Act 57 of 2003 as amended SANBI website and GIS tools were utilised to The National Environmental Management Protected Areas Act (No. 57 of 2003) (NEM:PAA) concerns the protection and determine if the Project area overlaps with conservation of ecologically viable areas representative of South Africa’s diversity and its natural landscapes and CBAs. Some sections of the Project were rated seascapes, and includes inter alia: as critically Endangered to Vulnerable. ❖ The establishment of a national register of all national, provincial and local protected areas; The Regulations were utilised to determine the ❖ The management of those areas in accordance with national standards; and need for any additional listed scheduled ❖ Inter-governmental co-operation and public consultation in matters concerning protected areas. activities under GNR 985. Sections 48 to 53 of the NEM:PAA lists restricted activities that may not be conducted in a protected area. Section 48 states that no person may conduct commercial prospecting or mining activities in a: ❖ Special nature reserve or nature reserve; ❖ Protected environment without the written permission of the Minister and the Cabinet member responsible for minerals and energy affairs; and Protected area referred to in Section 9: ❖ (b) world heritage sites; and ❖ (d) specially protected forest areas, forest nature reserves and forest wilderness areas declared in terms of the National Forests Act (No. 84 of 1998); National Heritage Resources Act, 1999 (Act No. 25 of 1999) (NHRA) A Heritage Impact Assessment was undertaken The NHRA aims to promote good management of cultural heritage resources and encourages the nurturing and as part of the EIA Phase and the assessment will

Applicable Legislation and Guidelines used to Compile the Report Reference where Applied conservation of cultural legacy so that it may be bestowed to future generations. be uploaded on the SAHRA web site along with The Act requires all developers (including mines) to undertake cultural heritage studies for any development exceeding the EIA Report. 0.5 ha. It also provides guidelines for impact assessment studies to be undertaken where cultural resources may be disturbed by development activities. The South African Heritage Resources Agency (SAHRA) will need to approve the heritage assessment undertaken as part of the impact assessment process. Conservation of Agricultural Resources Act (No. 43 of 1983) The protection of land, soil, wetlands and The Conservation of Agricultural Resources Act (No. 43 of 1983) (CARA) includes the use and protection of land, soil, vegetation and the control of weeds and invader wetlands and vegetation and the control of weeds and invader plants. This is the only legislation that is directly aimed plants are contained within the EIA Report and at conservation of wetlands in agriculture. The Act contains a comprehensive list of species that are declared weeds and well as in the Rehabilitation and Closure Plan. invader plants dividing them into three categories. These categories are as follows: ❖ Category 1: Declared weeds that are prohibited on any land or water surface in South Africa. These species must be controlled, or eradicated where possible; ❖ Category 2: Declared invader species that are only allowed in demarcated areas under controlled conditions and prohibited within 30m of the 1:50 year floodline of any watercourse or wetland; and ❖ Category 3: Declared invader species that may remain but must be prevented from spreading. No further planting of these species is allowed. In terms of the Act, landowners are legally responsible for the control of alien species on their properties. Failure to comply with the Act may result in various infringement consequences and in some instances imprisonment and other penalties for contravening the law. The South African National Roads Agency Limited and National Roads Act, 1998 (Act No. 7 of 1998) The requirements of the Act and Regulations The National Road Traffic Regulations, 2000 places specific duties on the consignor and consignee of dangerous goods. were considered when assessing the Project A consignor means the person who offers dangerous goods for transport (i.e. hazardous waste) and a consignee is the impacts and developing the associated person who accepts dangerous goods, which have been transported in a vehicle. Both consignor and consignee must mitigation measures in the EIA Phase. comply with the requirements of several SANS standard specifications and codes of practice relevant to dangerous goods which have been incorporated into the regulations. The mine owner is responsible for: ❖ Offloading of the dangerous goods; ❖ Providing the dangerous goods offloading supervisor; and

Applicable Legislation and Guidelines used to Compile the Report Reference where Applied ❖ Ensuring that the loading and offloading are carried out by qualified employees trained in the relevant procedures. Ergo must, in line with Section 54 of the Act and GN R225, provide evidence that the company has appointed responsible personnel to oversee the off-loading of dangerous goods at its operations. A driver of a vehicle transporting dangerous goods is required to undergo training at an approved training body. Spatial Planning and Land Use Management Act, 2013 (Act No. 16 of 2013) (SPLUMA) The City Deep Dumps are already in existence The SPLUMA was promulgated in May 2015. SPLUMA is a framework act for all spatial planning and land use and falls within an Urban Development Zone as management legislation in South Africa. It seeks to promote consistency and uniformity in procedures and decision- defined in the Gauteng Spatial Development making in this field. SPLUMA will also assist municipalities to address historical spatial imbalances and the integration of Framework. the principles of sustainable development into land use and planning regulatory tools and legislative instruments. Hazardous Substances Act, 1973 (Act No. 15 of 1973) The Regulations for Hazardous Chemical Substances apply to an employer or a self-employed person who carries out The requirements of the Act and Regulations work at a workplace which may expose any person to the intake of hazardous chemical substances at that workplace. were considered when assessing the Project Regulations 14 and 15 provide for the labelling, packaging, transportation and storage and the disposal of hazardous impacts and developing the associated chemical substances respectively. These regulations set out specific requirements which form part of an employer’s mitigation measures in the EIA Phase. duty to provide and maintain, as far as reasonably practicable, a working environment that is safe and without risk to the health of his or her employees. Nuclear Energy Act 1999, (Act 46 of 1999) (NEA), the National Nuclear Regulator Act 1999, (Act No. 47 of 1999) (NNRA) and the Regulations on Safety Standards and Regulatory Practices (SSRP) (GN R388 of 28 April 2006). The NEA established the South African Nuclear Energy Corporation Limited. In addition to its international and institutional obligations, the NEA set up a framework for the possession of nuclear material and restricted material. A radiation public hazard assessment was Although Section 34 provides that no person may possess source material (that is, any substance containing uranium or undertaken to determine the impact of thorium with concentration and mass limits higher than those specified in the Regulations) without written radiation due to the naturally occurring authorisation, this does not apply to material which has resulted from prospecting, reclamation or mining operations radioactive materials on the population living lawfully undertaken by the person concerned. However, Section 47 goes on to provide that “Any person who, by virtue around the Crown Gold Recoveries (Crown). The of information obtained in the course of any prospecting or mining operations has reason to believe that any source assessment was performed in accordance with material is present at any place, must submit to the Minister a written report on the matter, containing full particulars NNR License Guide LG-1032. of the place where the material may be present”. This provision appears to be applicable in particular to greenfields developments where no prior knowledge exists. The NNRA was enacted to provide for the establishment of the National Nuclear Regulator to regulate nuclear activities

Applicable Legislation and Guidelines used to Compile the Report Reference where Applied and to provide for safety standards and regulatory practices for protection of persons, property and the environment against nuclear damage. Section 20 of the Act provides that no person may site, construct, operate, decontaminate or decommission a nuclear installation, except under the authority of a nuclear installation licence. It should be noted in this regard that “nuclear installation” is defined as “a facility, installation, plant or structure designed or adapted for or which may involve the carrying out of any process, other than the mining and processing of ore”. Nonetheless, Section 2(1)(c) applies to “any action which is capable of causing nuclear damage” and Section 20(3) provides that “No person may engage in any action described in section 2(1)(c), except under the authority of a certificate of registration or a certificate of exemption”. To assess whether any action may result in nuclear damage, as defined, requires a consideration of the SSRP. The SSRP provides firstly, for general exclusions and exemptions from the operation of the NNRA. Section 2.1.1 provides that the NNRA does not apply where the level of radioactivity concentration of each radioactive nuclide in materials is below 0.2 Becquerels (Bq) per gram for artificial radioactive nuclides or 0.5 Bq per gram for naturally occurring radioactive nuclides, or where the level of total radioactivity content is below 1000 Bq. Section 2.2.1 sets out general principles for the issue of a certificate of exemption, that is, the radiation risk to individuals caused by the action concerned must be sufficiently low not to be of regulatory concern; the collective radiological impact of the action concerned must be sufficiently low not to warrant regulatory control in the prevailing circumstances; and the action concerned must be inherently safe, with no appreciable likelihood of scenarios that could lead to a failure to meet the criteria above. Whether or not any action exceeds these measures is a highly technical question requiring specialist assessment. It is only if these thresholds are exceeded and no certificate of exemption is issued, that a certificate of registration is terms of Section 22 of the NNRA will be required. Applicable International and National Guidelines and Standards Action Plan of the Environmental Initiative of the New Partnership of Africa’s Development, 2003. As the Proposed Project may affect the local This Action Plan (AP) was established with the aim of encouraging sustainable development, conservation and biodiversity, this action plan was considered. acceptable use of biodiversity in Africa. It has been recognised that a healthy and productive environment is a prerequisite for the success of New Partnership of Africa’s Development (NEPAD), together with the need to systematically address and sustain ecosystems, biodiversity and wildlife. Six areas have been identified: ❖ Combating land degradation, drought and desertification; ❖ Conserving Africa’s wetlands; ❖ Preventing and controlling invasive alien species;

Applicable Legislation and Guidelines used to Compile the Report Reference where Applied ❖ Conservation and sustainable use of coastal and marine resources; ❖ Combating climate change in Africa; and ❖ Cross-border conservation and management of natural resources. Mining and Biodiversity Guideline, 2013 As the Proposed Project may affect the local This guideline is founded on six fundamental principles: biodiversity, this guideline document informed ❖ Apply the law; the impact assess process completed as part of ❖ Use the best available biodiversity information; the EIA Phase. ❖ Engage relevant stakeholders thoroughly; ❖ Use best practice in EIA to identify, assess and evaluate impacts on biodiversity; ❖ Apply the mitigation hierarchy when planning any mining-related activities and develop robust EMPrs; and ❖ Ensure effective implementation of EMPrs, including adaptive management. The guideline stipulates the requirements for both utilising and integrating biodiversity information and informants into the assessment of impacts (i.e. this S&EIA process) of mining on biodiversity and ecosystem services and recommends good practice throughout the project’s life cycle. South Africa’s National Biodiversity Strategy and Action Plan The Proposed Project is cognisant of the The National Biodiversity Strategy and Action Plan (NBSAP) sets out a framework and a plan of action for the obligation to protect and preserve the integrity conservation and sustainable use of South Africa’s biological diversity and the equitable sharing of benefits derived from of the environment as well as its biodiversity. this use. The NBSAP was prepared by the former Department of Environmental Affairs and Tourism (DEAT), during the Principles of this plan was taken into period May 2003 to May 2005. The goal of the NBSAP is to conserve and manage terrestrial and aquatic biodiversity to consideration during the EIA Phase. ensure sustainable and equitable benefits to the people of South Africa, now and in the future. In support of this goal, five key strategic objectives (SOs) have been identified, each with a number of outcomes and activities. The schematic below represents the objectives and their interconnection in achieving the NBSAP “Goal”:

Applicable Legislation and Guidelines used to Compile the Report Reference where Applied

Through the NSBA, it is recognised that biodiversity cannot be conserved through protected area networks only. All stakeholders, from private landowners and communities to business and industry must get involved in biodiversity management. The strategy therefore promotes the inclusion of biodiversity considerations in mining regulations, guidelines and best practice codes to mitigate negative impacts and encourage sustainable mining practices through partnerships Best Practice Guideline Series The guidelines define and document best The Department of Water and Sanitation has developed a number of best practice guidelines for water resource practices for water and waste management protection in the South African mining industry. The best practice guidelines include international principles and associated with the reclamation Project and approaches towards sustainability. There best practice guidelines include viz.: were considered throughout the S&EIA process ❖ A water management hierarchy; and reporting. ❖ General water management strategies, techniques and tools; and

Applicable Legislation and Guidelines used to Compile the Report Reference where Applied ❖ Guidelines for mining related activities and aspects.

Table 5-2: Applicable Provincial and Local Policies, Guidelines and By-Laws Policies, Guidelines and By-Laws Gauteng Mine Residue Areas Strategy, 2012 The Proposed Project is in line with the The aim of the Project as a whole is to make more land available from the Mine Residue Areas in Gauteng to be used for objectives of the Strategy. The guidelines of other purposes, in line with government priorities. The objectives for the Project are as follows: the Strategy were considered throughout the ❖ To evaluate current pollution problems caused by mining activities and suggest how they should be addressed; S&EIA process and reporting ❖ To quantify the amount of land under mining activities and classify them in terms of impacts and potential for reclamation; ❖ To investigate which mining areas could be made available to be used for other purposes; and ❖ To provide preliminary and conceptual recommendations on the short-term priorities for the reclamation of the mining sites which could be economically sustainable. Gauteng Nature Conservation Bill, 2014 Aspects of this Act are applicable to the The Bill was established in 2014, and contains the following objectives: Proposed Project. Where applicable, these ❖ To provide for the sustainable utilization and protection of biodiversity within Gauteng; were considered throughout the S&EIA ❖ To provide for the protection of wild and the management of alien animals; protected plants; aquatic biota and process and will be included within the aquatic systems; reporting documents. ❖ To provide for the protection of invertebrates and the management of alien invertebrates; ❖ To provide for professional hunters, hunting outfitters and trainers; ❖ To provide for the preservation of caves, cave formations, cave biota and karst systems; ❖ To provide for the establishment of zoos ❖ To provide for the powers and establishment of Nature Conservators; ❖ To provide for administrative matters and general powers; and to provide for matters connected therewith. Gauteng Conservation Plan Version 3.3 Aspects of this Plan are applicable to the The main purposes of C-Plan 3.3 are: Proposed Project. Where applicable, these ❖ To serve as the primary decision support tool for the biodiversity component of the Environmental Impact were considered throughout the S&EIA Assessment (EIA) process; process and will be included within the ❖ To inform protected area expansion and biodiversity stewardship programmes in the province; reporting documents.

Policies, Guidelines and By-Laws ❖ To serve as a basis for development of Bioregional Plans in municipalities within the province. C-Plan 3.3 is a valuable tool to ensure adequate, timely and fair service delivery to clients of GDARD, and is critical in ensuring adequate protection of biodiversity and the environment in Gauteng Province. Gauteng Environmental Implementation Plan, 2016 Aspects of this Act are applicable to the The purpose of the EIP is to: Proposed Project. Where applicable, these ❖ Coordinate and harmonise environmental policies, plans and programmes and decisions to (i) minimise the were considered throughout the S&EIA duplication of procedures and functions; and (ii) promote consistency in the exercise of functions that may affect process and will be included within the the environment; reporting documents. ❖ Give effect to the principle of cooperative governance in Chapter 3 of the Constitution; ❖ Secure the protection of the environment across the country as a whole; ❖ Prevent unreasonable actions in respect of the environment that is prejudicial to the economic or health interests of other provinces or the country as a whole; and ❖ Enable monitoring of the achievement, promotion and protection of a sustainable environment. Gauteng Growth and Development Agency Strategic Plan 2014-2019 Aspects of this Act are applicable to the The main purpose of the GGDA Strategic Plan is: Proposed Project will contribute towards ❖ Addressing the persistent racial imbalances regarding ownership and general configuration of Gauteng’s employment creation within the Province and economy; will also contribute positively towards ❖ Addressing the spatially distorted economic development legacy of apartheid rule; economic growth within the region through ❖ Broadening the base of economic development beyond the Province’s dominant metropolitan municipal areas; both its development and operation. ❖ The socio-economic transformation envisaged for the second phase of transition to a national democratic society; and ❖ Achieving the outcomes of creating decent work, economic inclusion and equality. The Spatial Development Framework thus seeks to address five major issues in Johannesburg’s spatial and social Aspects of this SDF are applicable to the landscape Proposed Project. Where applicable, these ❖ Increasing pressure on the natural environment and green infrastructure. were considered throughout the S&EIA process and were included within the ❖ Urban sprawl and fragmentation. reporting documents. ❖ Spatial inequalities and the job-housing mismatch. ❖ Exclusion and disconnection emanating from: • high potential underused areas (the mining belt and the Modderfontein area);

Policies, Guidelines and By-Laws • securitisation and gated developments, and disconnected street networks (high cul-de-sac ratios and low • intersection densities). ❖ Inefficient residential densities and land use diversity. This Draft EIA incorporates the The Centre for Environmental Rights - Mining and your Community: Know your Environmental Rights recommendations and guidelines listed in the To exploit a mineral, mining companies must get permission to mine from the government. This is known as EA. To get guide when undertaking PPP. All PPP is permission, the mining company is required to assess the environment and learn about the community and consult with implemented according to the requirements everyone who will be affected by the proposed mining. The Guide published in 2014 by the CER discusses what rights listed in the NEMA EIA Regulations of 2017. communities and individuals who are affected by mining have, and what laws and processes must be followed by a mining Refer to Chapter 8 for an overview of Public company before it can start mining. Participation to be undertaken.

6 Need and Desirability of the Proposed Activities

Historical underground mining operations on the Witwatersrand have left the area littered with Mine Residue Areas such as slimes dams, sand stockpiles and other accumulations of slimes. These Mine Residue Areas are pollution sources, safety risks to surrounding communities and a limitation to spatial development.

6.1 Environmental Pollution

Mine Residue Areas are known to cause air and water pollution, as well as soil contamination. The impacts on soil are typically localised to the confines of the Mine Residue Areas. However, the particulate matter associated with these areas can travel for kilometres, and pollution caused by Acid Mine Drainage (AMD) can also be far reaching.

Dust is a human health risk for several reasons. The dust usually contains fine particulate matter, which can be inhaled, causing damage to lung tissues. The dust also potentially contains numerous hazardous substances that can result in chemical toxicity. Tailings with high level of radioactive material can cause radiological pollution. Collectively, the dust problem poses a significant health risk and reduces the quality of life for many citizens. Furthermore, this undermines the credibility of the mining industry as a responsible corporate citizen (GDARD, 2012, p16). The approval of this Project would eliminate the City Deep Dumps as a source of air and water pollution upon rehabilitation.

According to the Gauteng Department of Agriculture and Rural Development (GDARD, 2011), water pollution from abandoned mines is commonly associated with the problem of AMD, which usually refers to the ‘point source’ of pollution produced by the decant of contaminated water from shafts or inclines connecting the mine void to the surface. Some Mine Residue Areas, especially tailing dams, are closely associated with these underground mine voids, thus the issue of water ingress into those voids, via fissures arising from the geotechnically unstable surface, is of great importance. Unfortunately, many older tailing dams were placed in river beds or over dolomites which allowed seepage directly into groundwater. The decanting of AMD is a high-profile media issue, which is now driving investment decisions by a range of local and international investors, and which has been raised to the level of a national priority by the recently released AMD report. Possibly more important, however, is the broader issue of ‘diffuse sources’ of pollution represented by the dumps and slimes dams and their possible interactions with precipitation, seepage, surface-water runoff and shallow groundwater. The long-term sustainable solution is needed for both, AMD and Mine Residue Areas problems. This Project would contribute in finding a solution to these problems.

Soil contamination, including the mere presence of dumps, tailings and slimes dams in the surface environment, constitutes a pollution hazard through the direct access pathway. This occurs where people are contaminated by, or externally exposed to elevated levels of pollution after unauthorised entry to a mine site, by living in settlements directly adjacent to mines or in some cases, living in settlements on the

contaminated Mine Residue Areas of abandoned mines. Direct access to mine sites may also expose the public to risk due to direct external gamma radiation, radon exposure, inhalation and ingestion of radionuclides and chemotoxic metals, as well as the physical dangers inherent to mining sites (GDARD, 2012, pg16).

6.2 Safety and Security

According to GDARD (2012), most Mine Residue Areas have an element of lawlessness to them and should be considered as ‘bad-lands’ where state penetration is minimal. The absence of security results in theft of equipment and the damage of infrastructure required to mitigate the negative impacts of Mine Residue Areas. Dust control equipment such as sprayers and pumps are often stolen, which reverts back to environmental issues; while copper theft in the Mine Residue Areas has also been known to create, amongst other outcomes, the surge of voltage across the electric reticulation system, causing substantial damage to refrigerators, air conditioners, microwave ovens, TV sets, computers and other electronic equipment to surrounding communities.

Apart from theft, other issues that are commonly associated with Mine Residue Areas include illegal mining and illegal settlements near the unsupervised properties. These issues pose safety risks for law enforcement, affected land owners and adjacent communities.

6.3 The Limitation of Spatial Development

Gauteng is South Africa’s smallest but most densely populated province, housing 24% of the country’s population. 97% of the province’s population is urbanised, which has resulted in an increased requirement for land in urban spaces (GSDF, 2016).

Significant areas of land in Gauteng are devoted to and/or impacted upon by current and historical mining activities. The main ‘gold mining belt’ stretches from east to west across the centre of the province. However, gold mining has declined over the past few decades, leaving behind a legacy of TSF’s. According to the Gauteng Strategic Development Framework (GSDF) (2016), one of the solutions to an ever-growing demand for spaces in the province is by unlocking the mining belt and using these areas for their development potential.

6.4 Need and Desirability

The overall objective of this Project is to recover residual gold from tailings within the existing City Deep dumps. The resultant slurry from the reprocessing plant will be deposited at the Brakpan/Withok TSF. This will allow for the rehabilitation and clearance of land currently occupied by the City Deep Dumps.

The land being cleared could be viewed as a secondary or consequential product. The clearing of land is an extremely important and positive benefit, as the removal of the slime dam would result in the removal

of a water, land and dust pollution source, as well as costs associated with tailings dam maintenance. The land would be cleared to ground level.

Overall, the proposed Project is in line with the objectives of the Gauteng Mine Residue Area Strategy (2012), which are to “remove all remaining gold in residue dumps on the East Rand, thereby removing potential future environmental problems, making land available for urban development as well as providing ongoing employment for many people in a depressed labour market “(GDARD,2012). See Figure 6-1 below for the GDARD Mine Residue Areas Decision Tree.

Figure 6-1: GDARD’s Mine Residue Areas decision making tree as illustrated in the Gauteng Mine Areas Strategy (Source: GDARD, 2012).

7 Preferred Site Selection

The City Deep Dumps is an already existing site and for the pipeline, the route was evaluated as part of the EIA process and a site sensitivity assessment was carried out.

7.1 The Consideration of Alternatives

In accordance with the requirements outlined in Appendix 2 of the EIA 2014 Regulations, as amended, a consideration of reasonable and feasible alternatives, including site and technology alternatives and the “do-nothing” alternative must be undertaken. Each alternative is to be accompanied by a description and comparative assessment of the advantages and disadvantages that such development and activities will pose on the environment and socio-economy. When no feasible and/or reasonable alternatives can be identified and investigated in terms of a comparative assessment during the Scoping Phase, the EIA Report does not contain a section with alternatives.

The EIA 2014 Regulations, as amended, define alternatives as the different means of meeting the general purpose and requirements of the activity, which may include alternatives to:

❖ The property on which or location where it is proposed to undertake the activity; ❖ The type of activity to be undertaken; ❖ The design or layout of the activity; ❖ The technology to be used in the activity; ❖ The operational aspects of the activity; and ❖ The option of not implementing the activity.

Although a collection of alternatives may exist for the Proposed Project, only feasible alternatives were considered for this Draft EIA and are discussed in greater detail below. Kongiwe strove to seek alternatives that maximise efficient and sustainable resource utilisation and minimise environmental impacts.

7.1.1 The Property on which or Location where it is Proposed to Undertake the Activity

No alternatives have been investigated in terms of location of the Proposed Project. The City Deep Dumps are an existing site with the surface right owned by Ergo.

The location of the pipeline is restricted to a servitude owned by Ergo and therefore there is no alternative route considered.

7.1.2 The Type of Activity to be Undertaken

The only optional activity for Ergo is to reclaim and reprocess the existing City Deep Dumps. Gold reclamation and processing is the recovery and treatment of gold surface tailings generated from historical underground mining operations. According to DRDGold (2016), the retreatment business is high-volume

and low-risk. Vast quantities of material are processed monthly through their plants to recover gold from old mine dumps at a recovery rate that varies depending on the material being treated

7.1.2.1 Reclamation and Processing of Gold Dumps- Preferred Option

The depleting quantity and quality of gold recovered from underground mining operations in the province versus the extensive safety and environmental risks, as well as the labour and electricity costs associated with the activity has seen an underlining increase in the attractiveness of gold tailings reclamation. This, together with the incentive to find a solution to Gauteng’s Mining Residue Areas problem, has led to the ‘Preferred Activity’.

Table 7-1: The advantages and disadvantages of Re-mining and reprocessing of gold dumps – Preferred. Option Advantage Disadvantage ❖ Low-technical-risk nature of tailings ❖ Potential profits rely on substantial retreatment projects sets them apart volumes of material being processed. from traditional underground ❖ Potential negative environmental operations effects during construction and Re mining and ❖ Easy access to surface tailings, as well operational phase of the Project. reprocessing of gold as lower labour and operating costs. dumps (Preferred) ❖ Boost to local economy. ❖ Removal of pollution source after rehabilitation and cessation of Project.

Reclamation and reprocessing is the “Preferred Activity”, however there are two different methods of reclamation that should also be considered. The reclamation alternative methods that exist are:

❖ Hydraulic Mining: Preferred ❖ Mechanical Dredging: Not Preferred

Hydraulic Mining: Preferred

The preferred reclamation method for the Proposed Project is hydraulic mining. Hydraulic mining creates slurries from the combination of solids and water, pumps the slurries to the surface of lagoons, ponds, lakes, waterways, and canals, and then pumps the slurries through floating and land-based pipe to disposal sites (Memhard, 2011).

Ergo believes that it has implemented the best available technology, that is cost effective for this specific Project. Best practices as utilised in the industry have been selected and, where applicable, South African National Standards (SANS) and legislative requirements will be followed in design, construction and management of infrastructure and activities on site.

Table 7-2: The advantages and disadvantages of hydraulic mining. Option Advantage Disadvantage Hydraulic Mining ❖ Cost effective. ❖ May cause environmental impacts if (Preferred) ❖ Easier to transport slurry for not done responsibly. processing. ❖ Compatible with existing infrastructure. ❖ Recycling of water.

Mechanical Dredging: Alternative 1

Mechanical dredges work by mechanically digging or gathering sediment from the bottom surface of a body of water, typically through use of a bucket (SIS, 2016). The most common mechanical dredger is the bucket dredger, which is stationary, fixed by anchoring and moves while it dredges by winches. It features a number of buckets that fill as it scrapes the bottom. The material that is dredged is loaded in a barge and hauled away. This type of dredge rental is the most common in many industries (Figure 7-1).

Figure 7-1: Mechanical dredging (Source: http://www.3rinc.com/dredging/mechanical-vs-hydraulic- dredging/)

Table 7-3: The advantages and disadvantages of mechanical dredging. Option Advantage Disadvantage Mechanical Dredging ❖ High processing capacity. ❖ Time consuming. (Not Preferred) ❖ Cleans to bare rock. ❖ Generates dust. ❖ Requires a low amount of water. ❖ Difficult to transport silt for processing. ❖ The method is not compatible with existing infrastructure in the operation. ❖ Production yields are less than yields from Hydraulic Monitoring.

7.1.3 The Design and Layout of the Activity

The current layout plan for the Proposed Project is considered as the preferred layout plan. The layout plan is dictated by the existing location of the Dumps and its associated infrastructure. The routes of the various pipelines required for conveying the slimes and water reticulation are limited to existing servitude routes registered to Ergo. Therefore, any additional infrastructure will be established in compatibility with these servitudes.

The position of the paddocks will be established in relation to the availability of land and topography. The paddocks will capture water overflow from the dumps in the even that there is a severe rainstorm event. The paddocks will be positioned in a manner that will allow for water decanting from the Dumps to gravitate, via the penstock, into the paddocks and from there to the reclamation station. This water is anticipated to be used in closed circulation in emergency situations.

7.1.4 The Technology to be Used in the Activity

Process alternatives imply the investigation of alternative processes or technologies that can be used to achieve the same goal. This includes using environmentally friendly designs or materials and re-using scarce resources like water and non-renewable energy sources. The preferred options, in terms of recycling, water and energy have been described below.

7.1.4.1 Recycling

The mining Project will, in its operational phase, implement recycling policies and measures for optimal utilisation of resources and minimisation of waste generation.

7.1.4.2 Water

Water utilisation will be maximised through recycling of dirty water within the process operations.

7.1.4.3 Electricity

Fuel types will be investigated as well as energy conserving measures will be implemented.

7.1.5 The Operational Aspects of the Activity

7.1.5.1 Processing Plant Options

There are no alternatives to the processing plant as all reclaimed slurry will be processed at the existing Ergo Plant.

7.1.5.2 Transport Options

The were no alternative to the transportation of the slurry to the plant. Pipelines from the Dumps will be joining the already existing pipeline network to the Ergo plant in Brakpan.

7.1.6 The “No-Go” Option

The Option of the Project not proceeding would mean that the environmental impact and social status would remain the same as current. This implies that both negative and positive impacts would not take place. As such, negative impacts on biodiversity, water resources, air quality land use etc. would continue and that the positive impacts such as mine residue removals, land rehabilitation, skills development and poverty alleviation would not occur.

The ‘No Project’ alternative is not considered due to the anticipated benefits of the proposed reclamation Project. The expected indirect benefits of the Proposed Project include:

❖ Removal of the mine dumps as a source of pollution in the area; ❖ Removal of the dumps and rehabilitation of the area liberates the land for industrial use; and ❖ Continued supply of gold to the local and national markets, and therefore contribution to local, provincial and national economy.

It must be noted that the reclamation of the City Deep Dumps is already approved in terms of the MPRDA, under the 185MR.

7.2 Project Motivations 7.2.1 Motivation for the Alternative Development Location for the City Deep Project

No alternatives have been investigated in terms of location of the City Deep Reclamation Project. The dumps are in existence and Ergo currently holds the surface rights. There are therefore no alternative mining areas evaluated.

7.2.2 Motivation for the Final Proposed Facility Alternative

The factors below have been used to determine the final preferred alternatives for the City Deep Project:

❖ Financial feasibility; ❖ Logistical feasibility – raw material supply, market proximity and utilities; ❖ Environmental impacts; ❖ Socio‐economic impacts including comments received from I&AP’s; ❖ Land use planning and future spatial development considerations; ❖ Proximity to sources of human resource; and, ❖ Proximity to other mining related projects (cumulative impacts).

The mining of the City Deep dumps will remove a source of air, surface and groundwater pollution, and will liberate the land to be used for agricultural purposes. The layout of the surface infrastructure and pipelines has been planned to avoid sensitive areas as far as feasible (Figure 7-2).

Ergo will have to follow the rehabilitation, monitoring programmes and EMPr strictly to ensure that environmental impacts are minimised and mitigated appropriately.

Figure 7-2: Sensitivity Mapping

7.2.3 Motivation where No Alternatives have been considered

Motivations where no alternatives have been assessed have been addressed throughout Chapter 7. This project is already approved in terms of the MPRDA, under 185MR.

8 Public Participation

The public participation process (PPP) has been developed to ensure compliance with the Integrated Environmental Authorisation, Waste Management Licence Application and the Integrated Water Use Licence Application process. The public participation process offers stakeholders a fair opportunity to be informed about the Proposed Project, to raise issues of concern and to make suggestions for enhanced Project benefits. The Project team will consider relevant issues and suggestions during the EIA/IWULA process.

This chapter will discuss the following 9 aspects with regards to undertaking the necessary PPP:

1. The objective of the PPP; 2. The process of identifying Stakeholders and capturing them on the Project database; 3. The status of identifying land claims relevant to the Proposed Project; 4. Materials for undertaking the PPP; 5. The Draft Scoping consultation process; 6. The Final Scoping consultation process; 7. A summary of activities, which have been undertaken as part of the FSR; 8. A summary of activities to be undertaken as part of the EIA Phase; and 9. PPP during the decision-making phase.

8.1 Public Participation Process Objectives

The PPP objectives are to:

❖ Comply with the legal requirements; ❖ Ensure that stakeholders are informed about the Proposed Project; ❖ Provide stakeholders with the opportunity to participate in the process and provide comment; ❖ Draw on local knowledge by identifying environmental and social concerns associated with the Proposed Project; ❖ Involve stakeholders in identifying ways in which concerns can be addressed; and ❖ Verify that stakeholder comments have been recorded.

The PPP has four phases of consultation with Interested and Affected Parties (I&APs) during the environmental regulatory process. These are presented in Table 8-1 below:

Table 8-1: Activities undertaken and to be undertaken during the public participation process Project Phase Activities Undertaken Pre-scoping Phase ❖ Identification of stakeholders; ❖ Providing Project information to I&APs; ❖ Consultation with I&APs; and ❖ Obtaining comments, suggestions and concerns from I&APs.

Project Phase Activities Undertaken Scoping Phase ❖ Consultation with directly affected landowners; ❖ Distribution and placement of Project announcement materials; ❖ Updating of the stakeholder database; ❖ Availability of the Scoping Report for public review and comment; ❖ Provide stakeholders with further details of the Proposed Project and associated specialist studies; ❖ Consultations with stakeholders; ❖ Public meeting; ❖ Obtain further comments, suggestions and concerns from stakeholders; and ❖ Inform specialists and the applicant about comments received from stakeholders. EIA Phase ❖ Provide feedback about the specialist studies conducted and mitigation measures (WE ARE HERE) proposed by means of consultation with I&APs; ❖ Make the relevant environmental reports available for public comment; ❖ Consult with I&APs; ❖ Provide opportunity for I&APs to comment on specialist findings, impacts assessments and recommendations; ❖ Public Meeting; ❖ Verify that comments raised by I&APs have been accurately recorded; and ❖ Inform specialists and the proponent of I&AP comments. Decision Making ❖ Once the competent authority has come to a decision regarding the authorisation Phase of the Project, all registered I&APs will be notified of the decision made and the appeal process will be explained.

8.2 Summary of issues raised by I&AP’s

For a comprehensive recording of comments and responses, please refer to Comments and Responses Report (CRR) (Appendix C9).

8.3 Identification of Stakeholders

To ensure representation of stakeholders, the methods below were utilised to develop a comprehensive stakeholder database.

❖ WinDeed searches were undertaken for farm portions in and around the Project site to verify land ownership and obtain contact details; ❖ Desktop and online research; ❖ Stakeholder networking and discussions to source additional stakeholder details: o This entailed telephonic consultations and meetings with landowners, National, Provincial and Local Government, key Non-Governmental Organisations (NGOs) and other representatives; o A site visit was undertaken to identify I&APs for which no contact details could be obtained; and

o Queries to the Surveyor General and Deeds office.

Stakeholders identified who are affected by or interested in the Proposed Project are grouped into the following broad categories:

❖ Government: National, Provincial, District and Local Authorities; ❖ Parastatals: Various semi-Government entities, Organs of State; ❖ Landowners: Directly or indirectly affected and adjacent; ❖ Land occupiers: Directly or indirectly affected and adjacent; ❖ Surrounding communities; ❖ NGOs: Environmental organisations, community-based organisations; and ❖ Business and industry: small to medium enterprises, mines, industrial and large business organisations.

A stakeholder database has been compiled and will be updated throughout the environmental regulatory process (refer to Appendix C1 for a copy of the stakeholder database).

8.4 Land Claims

A formal enquiry, which contained a list of all the directly affected land portions for the Project, was submitted to the office of the Regional Land Claims Commissioner (Gauteng Regional Office) from the Gauteng Department Rural Development and Land Reform (DRDLR), Land Claims Commission, on Monday, 5 October 2018 (refer to Appendix C2). Feedback was received by means of letters dated Friday, 9 November 2018 (refer to Appendix C2) indicating that there are land claims on some of the farms, these are listed below:

Table 8-2: Land Claims on the City Deep Project Area. Farm name Portion number/s Elandsfontein 107 IR 78; 39; RE/1; RE/35; R/E Doornfontein 92 IR 86 (RE), 87 (RE), 89 (RE), 430 (RE), 605 (RE), 932, 946 & 1037

Important note: The office of the Regional Land claims Commissioner has confirmed that the land claims lodged against the abovementioned properties have not yet been published in the government gazette (please refer to Appendix C2 for proof of correspondence).

8.5 Public Participation Materials

Following the legislative requirements and good practice, it is important to develop documentation, which will be easily accessible to all stakeholders who would be affected or interested in the Project. The following documents have been developed and distributed to all stakeholders listed in the stakeholder database. The various PPP materials which were used as part of the Environmental Impact Assessment (EIA) process are included as appendices to this report.

Background Information Document: The BID (Appendix C3) aims to provide important information regarding the following:

❖ Project description of the proposed reclamation of the City Deep dumps; ❖ The Environmental Impact Assessment and the Public Participation Process to be undertaken in support of the reclamation process and relevant contact details; ❖ An Integrated Water Use Licence Application process; ❖ Details about how stakeholders can register as an Interested and Affected Party (I&AP) and be kept informed about the Project developments; ❖ The public review and comment period for the Draft Scoping Report (DSR); and ❖ An invitation to attend the public meeting.

The BIDs were emailed, and hand delivered to the affected and surrounding landowners. The BID was also published on Kongiwe ’s website (under public documents).

Newspaper advertisements: A newspaper advert (Appendix C4) was placed in the Inner-City Gazette, a local newspaper for the City Deep Project area (on Thursday, 8 November 2018). The newspaper advertisement provided the following details:

❖ Brief Project description; ❖ Applicable listed activities; ❖ Information about availability of the DSR; ❖ Invitation to the public meeting; ❖ Registration as I&APs; and ❖ Contact details of the public participation team.

Site notice: Site notices were developed to announce the Proposed Project and were placed in various public places. The information included in the site notice was like the information provided in the newspaper advertisement. A locality map of the Project site was included in the site notice. Pictures and Co-ordinates of where the site notices were placed were recorded in the site notice report. (Please refer to Appendix C5 for a copy of the site notice and the site notice report).

Notification Letter with a Comment and Registration Form: A notification letter was sent to stakeholders on Thursday, 18 October to inform them about the Proposed Project, availability of the draft Scoping Report (DSR) and formally invited them to attend the public meeting. A Comment and Registration form was also provided for stakeholders to use for formal registration as I&APs or to submit comments. (See Appendix C6). A second notification letter was emailed on Monday, 12 November 2018 and then a reminder email was sent on Friday, 23 November to all stakeholders to inform them of the availability of the Draft Scoping Report public review period and the public meeting (Appendix C6).

Telephonic discussions: Stakeholders will be consulted by means of telephonic discussions. Furthermore, these discussions will aid with the process of invitation to the Public Meeting.

Pre-scoping consultation: Pre-scoping consultation with key stakeholders was aimed at providing stakeholders with an overview of the proposed Ergo Mining Project and to obtain initial comments which informed specialist studies and project planning. This was done by means of a PowerPoint Presentation and a map showing the properties. Pre-consultation meetings were held with the Competent and Commenting Authorities and Environmental NGOs. Meetings were also held with the directly affected landowners on a one-on-one basis. Minutes from these meetings were compiled and distributed to stakeholders (Appendix 8). All comments raised by stakeholders during these meetings have been captured in the CRR (Appendix C9).

8.6 Scoping Phase Consultation 8.6.1 Consultation During Draft Scoping Phase

The aim of consultation during the Scoping Phase was focused on the formal EIA process, the terms of reference for the specialist studies and addressing stakeholder comments. A public meeting was held on Tuesday, 27 November 2018 at 10H00 at the Brakpan Civic Centre, 3rd Floor, Legal & Admin Block, Cnr Escombe and Elliott, Brakpan. The purpose of the meeting was to discuss the Proposed Project, contents of the Draft Scoping Report and also to provide I&APs with an opportunity to raise their concerns/comments. Minutes from the public meeting have been compiled and distributed to those to all stakeholders (See Appendix C8).

Figure 8-1: Public Meeting held at Brakpan Civic Centre

All comments raised by stakeholders have been captured into the CRR (Appendix C9). Stakeholder comments have been closely considered and addressed, where applicable, by the Project team to ensure

that the scope for specialist studies to be undertaken is well defined. Responses have been provided to the comments raised by stakeholders and included in the CRR throughout the PPP.

Presentations: PowerPoint presentation was used at the public meeting to present the proposed Project. At the public meeting, CDs containing the DSR and comment sheets were made available. The minutes of the meeting and the presentation have been included in (Appendix C8).

The presentation at the public meeting covered the following aspects:

❖ Project Description; ❖ Project Infrastructure; ❖ Baseline Information and Site photographs; ❖ Legislative Framework; ❖ Environmental Authorisations; and ❖ Specialist Studies.

Availability of the Draft Scoping Report for public review and comment: The DSR was made available to stakeholders at various public places and also on the Kongiwe’s website for a 30-day comment period from Monday, 12 November 2018 – Tuesday, 11 December 2018. Notification of the availability of the documentation for review was distributed initially on Thursday, 18 October 2018, a second notification letter was sent to the full database on Monday, 12 November 2018. A reminder email was sent on Friday, 23 November 2018 to all stakeholders on the database. The report was made available at the locations indicated in Table 8-3:

Table 8-3: Public places where the Draft Scoping Report could be accessed. Location Physical Address Contact Person Hard copies Mr Johannes Masenya, Manager Albertina Sisulu Rd & Pixley Ka Greater Johannesburg Library Cell: (061) 438 0153 or (011) 492 Isaka Seme Street, Johannesburg 7071 Electronic copies www.kongiwe.co.za/ public Kongiwe Environmental website documents For a CD copy stakeholders were requested to contact the stakeholder engagement team (Sibongile Bambisa/ Vanessa Viljoen), Tel: 010 140 6508, Email: [email protected]

The DSR was distributed to the Competent Authority (DMR) and key Commenting Authorities, please refer to (Appendix C7) for proof of delivery. Key Commenting Authorities that received copies of the DSR are as follows:

❖ Department of Water and Sanitation (DWS); ❖ National Nuclear Regulator (NNR); ❖ Department of Environmental Affairs;

❖ Gauteng Department of Agriculture and Rural Development (GDARD); ❖ City of Johannesburg Metropolitan Municipality (CoJMM); ❖ South African Heritage Resources Agency (SAHRA); ❖ National Department of Health; ❖ Department of Public Works, Roads and Transport; and ❖ Department of Agriculture, Forestry and Fisheries (DAFF)

Table 8-4 below provides a summary of the activities that formed part of the Draft Scoping Phase.

Table 8-4: Summary of PPP activities during the Draft Scoping Phase Reference in Draft EIA Activity Details report Pre-scoping Phase Stakeholders, were identified by means of WinDeed Identification of Appendix C1 searches, stakeholder networking and research for the stakeholders Stakeholder database compilation of a stakeholder database. A formal enquiry, which contained a list of all the directly affected land portions for the Project, was submitted to the Gauteng Department of Rural development and Appendix C2 Identification of land claims Land Reform (DRDLR), Land Claims Commission, Land claims letters Monday, 5 October 2018 (refer to Appendix C2). Feedback was received by means of separate letters dated 9 November 2018 (refer to Appendix C2). Development of the The BIDs were developed and distributed to all Appendix C3 Background Information stakeholders on Thursday, 18 October 2018. BIDs Document A media advertisement was placed in the Inner-City Placing of media Appendix C4 Gazette, a local newspaper (on Thursday 8 November advertisements Newspaper Advertisement 2018). Site notices were put up at publicly accessible places within the proximity of the Project area from 08 November 2018. A copy of a Site Notice was also Appendix C5 placed at the Greater Johannesburg Library, Albertina Placing of site notices Site notice report and Sisulu Rd & Pixley Ka Isaka Seme Street, Johannesburg. placement map A site notice placement report and map have been developed, indicating the exact locations where site notices were placed, with photos and GPS co-ordinates.

Site Visit to deliver A site visit was undertaken in an effort to identify Appendix C7 Background Information I&APs for which no contact details could be obtained. Stakeholder correspondence Documents

Reference in Draft EIA Activity Details report An announcement letter was emailed to the full stakeholder database on Monday, 12 November 2018 to: ❖ Announce availability of the Scoping Report; ❖ Share information of the public meeting; Appendix C6 ❖ Indicate where the Scoping Report will be available Announcement of the Announcement Letter for public review and comment; and Project and Draft Scoping Appendix C3 ❖ Provide details about the public review and Report BID comment period.

A reminder email was sent in addition to the full database on Friday, 23 November 2018, to remind the stakeholders of the Public meeting. The Draft Scoping Report was made available on Kongiwe’s website www.kongiwe.co.za/ One-on-one consultation meetings and focus group meetings were held with Authorities, NGOs and Appendix C8 Directly Affected landowners. Minutes from these List of meetings & Meeting meetings have been compiled and distributed to all Minutes Stakeholder meetings stakeholders on the database. A high-level overview of Appendix C9 the Proposed Project was discussed, and stakeholder Comment and Response comments were captured into and responded to in the Report CRR. A public meeting was held with stakeholders on Appendix C8 Tuesday, 27 November 2018from 10:00 – 12:00 at the Minutes of the public Brakpan Civic Centre, 3rd Floor, Legal & Admin Block, meeting Public Meeting Cnr Escombe and Elliott, Brakpan. Minutes from the Appendix C9 public meeting have been distributed to all Comment and Response stakeholders. Comments raised from the meeting have Report been included in the Comment and Response Report.

8.6.2 Consultation undertaken as part of the Final Scoping Phase

The aim of consultation during the Final Scoping Phase was focused on the formal EIA process, specialist impact studies, terms of reference and addressing stakeholder comments already submitted. Stakeholders have been notified of the availability of the Final Scoping Report for review on Thursday, 13 December 2018 (Appendix C6). Stakeholders were provided with an opportunity to verify that their comments were captured during the Draft Scoping Phase, and to review responses provided by the Project team. All comments received on the Final Scoping Report were incorporated into the Comment and Response Report.

Table 8-5: PPP activities undertaken during the final scoping phase. Reference in the EIA Activity Details Report The stakeholder database has been updated with new Update of stakeholder Appendix C1 I&APs who formally registered, attended stakeholder information Stakeholder database meetings or submitted comments. The Final Scoping Report for the Proposed Project was made available on the Kongiwe’s website www.kongiwe.co.za/ from Thursday, 13 December Placement of Final Scoping 2018. - Reports Copies of the Final Scoping Report were submitted to the Competent authority and relevant Commenting Authorities for their review and comment. Notification letter announcing the availability of the Announcement of the Final Final Scoping Report for comment was emailed to the Appendix C6 Scoping Report full stakeholder database on Thursday, 13 December Announcement Letters 2018.

8.7 EIA Phase Consultation

Consultation with stakeholders during the Impact Assessment phase will be undertaken to provide feedback on findings from specialist studies, impacts and proposed mitigation measures provided and to obtain additional comments from stakeholders.

8.7.1 Draft Document Availability

The DEIR/EMPr will be available for a 30-day public review period from Monday, 01 April 2019 to Monday, 06 May 2019. A technical report in support of the IWULA process will be made available for public review and comment for a period of 60 days, the Draft IWULA report will be available from Monday, 01 April 2019 to Monday, 03 June 2019. Notification of the availability of the documentation for public review and comment will be distributed to all stakeholders on the database to notify them of the availability of the DEIR/EMPr and the /Draft IWULA report and the public meeting. The reports will be made available at the locations indicated in Table 8-6 below:

Table 8-6: Public places where the Draft EIA/EMPr and IWULA reports can be accessed Location Physical Address Contact Person Hard copies Mr Johannes Masenya, Manager Albertina Sisulu Rd & Pixley Ka Greater Johannesburg Library Cell: (061) 438 0153 or (011) 492 Isaka Seme Street, Johannesburg 7071 Electronic copies www.kongiwe.co.za/ public Sibongile Bambisa/ Vanessa Kongiwe Environmental website documents Viljoen), Tel: 010 140 6508

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

The DEIR/EMPr and the Draft IWULA reports will be distributed to the Competent Authorities (Department of Mineral Resources and Department of Water and Sanitation) and key Commenting Authorities, please refer to (Appendix C8) for proof of delivery. Key Commenting Authorities who will receive copies of the reports are as follows:

❖ Department of Water and Sanitation; ❖ National Nuclear Regulator; ❖ Department of Environmental Affairs; ❖ Gauteng Department of Agriculture and Rural Development (GDARD); ❖ City of Johannesburg Metropolitan Municipality; ❖ South African Heritage Resources Agency (SAHRA); ❖ National Department of Health; ❖ Department of Public Works, Roads and Transport; and ❖ Department of Agriculture, Forestry and Fisheries (DAFF)

8.7.2 Public Meeting

A public meeting will be held on Monday 08 April 2019, details of the public meeting are indicated below (Table 8-7). Stakeholders will be invited to the meeting by means of a notification letter which will be sent by email. A Short Message Service (SMS) will be sent to stakeholders who do not have email access. The purpose of this meeting is to provide feedback on the findings from the specialist studies undertaken and to obtain comments. The minutes of the public meeting will be distributed to all stakeholders. All comments raised will be captured into the Comment and Response Report and will be responded to.

Table 8-7: Details of the public meeting Date Venue Time Observatory Golf Club, Steyn Street, Observatory, Monday, 08 April 2019 10H00 Johannesburg.

8.7.3 Public Participation Materials

Notification Letter: a letter (Appendix C6) which provides details about the availability of the Draft EIR/EMPr and the IWULA Reports for public comment and an invitation to the public meeting will be sent to the full stakeholder database.

Newspaper advertisements: A newspaper advert (Appendix C4) will be placed in Inner-City Gazette on 22 March 2019. The advertisement will provide details about the public review period for the Draft EIR/EMPr and the IWULA and how the public can access the draft reports for their review and comment. The advert will also provide information about the public meeting details.

Telephonic Discussions: Stakeholders will be invited to the stakeholder meetings by means of telephonic discussions, to confirm their attendance.

Maps: Various maps of the EIA will be on display throughout the stakeholder meetings. These will include maps of the various specialist study findings and the landownership maps.

PowerPoint Presentation: A presentation will be compiled and used at the Public Meeting and the Landowners meetings. The following aspects will be covered in the presentation below:

❖ Project overview will be given; ❖ EIA process and legislation timeframes; ❖ Specialist study findings, impacts and proposed mitigations; and ❖ PPP to date and next steps.

8.7.4 Summary of the PPP Activities to be Undertaken during the EIA Phase

Table 8-8: Summary of the PPP activities that will be undertaken during the Draft EIA Phase Impact Assessment Phase Activity Details Reference in DEIR/EMPr A Notification letter announcing the availability of the DEIR/EMPr and IWULA for public review and comment Announcement of the will be emailed to the full database. Appendix C6 availability of the Draft (Public comment period for DEIR/EMPr (30 days): Announcement of the EIA/EMP and IWULA Reports Monday, 01 April 2019 to Monday, 06 May 2019. DEIR/EMPr and IWULA (Public comment period for IWULA (60 days): Monday, 01 April 201 to Monday, 03 June 2019. The Draft EIR/EMPr and the Draft IWULA will be made available to stakeholders at the following public places: o Greater Johannesburg Library Albertina Sisulu Rd & Pixley Ka Isaka Seme Street, Johannesburg. An electronic copy of the Draft EIR/EMPr and IWULA Placement of Draft EIA/EMP will be made available on Kongiwe’s website and IWULA Report for public - www.kongiwe.co.za/ review and comment A copy of the Draft EIR/EMPr and IWULA will also be made available at the public meeting. Copies of the Draft EIR/EMPr and IWULA will be sent to the DMR and various Commenting Authorities for review and comment. A public meeting will be held with all stakeholders on Monday, 08 April 2019 at the Observatory Golf Club, Appendix C9 Public Meeting Steyn Street, Observatory. All comments provided at Comment and Response this meeting will be captured into the Comment and Report Response Report

Table 8-9: PPP activities to be undertaken during the Final Environmental Impact Assessment Phase Activity Details A notification letter announcing the availability of the Final EIA/ EMPr will be emailed to Announcement of the the full database. Final EIA/EMPr The Final EIA/ EMPr will be made available on Kongiwe’s website. Submission to the The Final EIA/EMPr will be submitted to the DMR, who is the competent authority for Authorities the Proposed Project

8.8 Public Participation During the Decision-Making Phase

Once the CA has come to a decision regarding the authorisation of the Project, all registered I&APs will be notified of the decision made and the appeal process will be explained.

9 The Baseline Environment and Specialist Findings

9.1 Climate 9.1.1 Rainfall

Daily rainfall depths were extracted from the Lynch (2003) database for the most reliable (most complete rainfall record) weather station near the Project. This was the Rosherville weather station (0476163 W), located approximately 2.5 km north-west of the Project. The Daily Rainfall Extraction Utility software programme was used to extract the rainfall depths for the period 1920/1/1 to 2000/8/31 (80 years and 8 months of rainfall data).

The site has a Mean Annual Precipitation (MAP) of 741 mm. The average monthly rainfall is indicated in Figure 9-1. The wettest months occur from October through to March, with the driest months occurring over the period of June to August. Rainfall is mostly in the form of convective thunderstorms, which are often brief, but regularly high in intensity. Tropical and frontal rainfall systems also occur in the region, but are not as common.

Figure 9-1: Average monthly rainfall totals for the project (Rosherville weather station)

9.1.1.1 Storm Rainfall Depths

The storm rainfall depths for the centre position of the project area were extracted from the Design Rainfall Estimation in South Africa software programme (Smithers and Schulze, 2002). The programme uses the six closest rainfall stations to a user specified coordinate, to calculate the storm rainfall depths for that area. The six closest rainfall stations to the project area are indicated in Table 9-1.

Table 9-1: Six closest rainfall stations to the project Distance Record MAP Altitude Station Name Station No. from Site Latitude Longitude (Years) (mm) (mamsl) (km) Rosherville 0476163 W 2.5 94 26°13S 28°6E 731 1 685 Germiston-Simmer Jack - 0476252 W 2.5 61 26°13S 28°8E 761 1 645 gm Germiston-Simmer Pan 0476283 A W 4 83 26°13S 28°9E 738 1 663 Jhb-City Deep 0476103 W 5.1 74 26°12S 28°5E 794 1 677 New Market 0476227 W 5.4 67 26°17S 28°7E 696 1 575 Germiston-FJ Payne Park 0476283 W 5.7 91 26°13S 28°10E 729 1 663

The extracted storm rainfall depths for the Project are indicated in Table 9-2.

Table 9-2: Storm rainfall depths for the project. Storm Duration Return Period / Storm Rainfall Depth (mm) min / hr / day 1:2 yr 1:5 yr 1:10 yr 1:20 yr 1:50 yr 1:100 yr 1:200 yr 5 min 8.8 12.2 14.7 17.5 21.4 24.7 28.4 10 min 12.7 17.5 21.2 25.1 30.8 35.6 40.8 15 min 15.7 21.7 26.2 31.1 38.1 44 50.5 30 min 20.2 27.8 33.7 39.8 48.9 56.4 64.7 45 min 23.3 32.2 38.9 46.1 56.5 65.3 74.9 1 hr 25.9 35.7 43.2 51.1 62.7 72.4 83 1.5 hr 29.9 41.3 49.9 59.1 72.5 83.7 96.1 2 hr 33.2 45.8 55.4 65.6 80.4 92.8 106.5 4 hr 39.8 55 66.5 78.7 96.5 111.4 127.8 6 hr 44.3 61.2 73.9 87.5 107.3 123.9 142.2 8 hr 47.8 66 79.8 94.4 115.7 133.7 153.4 10 hr 50.7 69.9 84.6 100.1 122.7 141.7 162.7 12 hr 53.2 73.4 88.7 105 128.8 148.7 170.6 16 hr 57.3 79.2 95.7 113.3 138.9 160.4 184.1 20 hr 60.8 83.9 101.5 120.1 147.3 170.1 195.2 24 hr 63.8 88.1 106.5 126 154.5 178.5 204.8 1 day 55.3 76.3 92.3 109.2 133.9 154.6 177.4 2 day 68.1 94 113.6 134.5 164.9 190.5 218.6 3 day 76.9 106.2 128.4 152 186.3 215.2 246.9 4 day 83.8 115.7 139.9 165.6 203 234.4 269 5 day 89.6 123.7 149.5 177 217 250.6 287.5 6 day 94.6 130.6 157.9 186.9 229.1 264.6 303.6 7 day 99 136.7 165.3 195.6 239.9 277 317.9

9.1.2 Evaporation

The adopted monthly evaporation for the Project is indicated in Table 9-3. Evaporation is highest over the summer months, with December and January being the highest, and lowest over the winter months.

Table 9-3: Symons Pan and open water evaporation for the project. Symons Pan Evaporation Open Water Evaporation Open Water Evaporation Month (mm) Factor (mm) January 199 0.84 167 February 161 0.88 141 March 146 0.88 129 April 107 0.88 94 May 81 0.87 70 June 62 0.85 52 July 69 0.83 57 August 100 0.81 81 September 140 0.81 114 October 179 0.81 145 November 186 0.82 152 December 202 0.83 167 Total 1 630 N/A 1 370

9.1.3 Temperature

The average monthly temperatures for the project were extracted using the LocClim Local Climate Estimator software programme (FAO, 2005), using the nearest neighbour method from weather stations in the region. Figure 9-2 indicates the minimum, average and maximum temperatures for the Project. The warmest months occur from October through to March. The coolest months occur over the period of May to August.

Figure 9-2: Minimum, average and maximum monthly temperatures for the Project

9.1.4 Wind Direction

Wind roses graphically present wind conditions over a period at a specific location. Wind roses for the project are presented in Figure 9-3 to Figure 9-4 below. In the wind roses, the length of each spoke

represents the percentage of time that the wind blew from that direction during the period. The percentage scale is presented on the concentric grey lines (the circle scale increment is indicated on each of the wind roses). Each spoke is divided by colour into wind speed ranges.

The predominant wind direction at the City Deep site (as given by the WRF data for the period from 2015 to 2017 for the project area) is from the north-north-westerly direction (for approximately 8.1% of the time). However, a similar number of winds is expected from the directions spanning from north through to south-east (Figure 9-3). The highest number of winds with speeds greater than 6.5 m/s are expected from a northerlyWIND direction. ROSE PLOT: The average hourly wind speed predicted by the Weather and Research Station #OS_ID: Forecasting (WRF) model is approximately 1.63 m/s. Calm conditions (wind speeds below 0.5 m/s) are predicted for approximately 2.4% of the time.

NORTH

10% 8% 6% 4% 2% WEST EAST

WIND SPEED (m/s)

>= 6.50 5.50 - 6.50 4.50 - 5.50 3.50 - 4.50 SOUTH 2.50 - 3.50 1.50 - 2.50 0.50 - 1.50 Calms: 2.40% Figure 9-3: Wind rose of the average winds produced by the WRF model for the City Deep reclamation site, for the yearsCOMMENTS: 2015-2017. DATA PERIOD: Start Date: 1/1/2015 - 00:00 End Date: 12/31/2017 - 23:59 There is a clear diurnal variation in both wind direction and wind speed at the City Deep site. During the warmer hours of the day, higher windCALM WINDS: speeds are expected,TOTAL COUNT: and the winds blow mainly from the north- 2.40% 26304 hrs. westerly and northerly directions. AVG.During WIND SPEED: the night, average wind speedsPROJECT are NO.: much lower, and the winds tend to blow more from the south-1.63easterly m/s and east-south-easterly directions (Figure 9-4). WRPLOT View - Lakes Environmental Software

Page |55 City Deep Dumps Reclamation and Reprocessing Project Draft Environmental Impact Assessment Report © 2019 Kongiwe Environmental (Pty) Ltd WIND ROSE PLOT: WIND ROSE PLOT: Station #OS_ID: Station #OS_ID:

Day Night NORTH NORTH

12% 12% 9.6% 9.6% 7.2% 7.2% 4.8% 4.8% 2.4% 2.4% WEST EAST WEST EAST

WIND SPEED WIND SPEED (m/s) (m/s)

>= 6.50 >= 6.50 5.50 - 6.50 5.50 - 6.50 4.50 - 5.50 4.50 - 5.50 3.50 - 4.50 3.50 - 4.50 SOUTH 2.50 - 3.50 SOUTH 2.50 - 3.50 1.50 - 2.50 1.50 - 2.50 0.50 - 1.50 0.50 - 1.50 Calms: 4.43% Calms: 0.02%

COMMENTS: DATA PERIOD: COMMENTS: DATA PERIOD:

Start Date: 1/1/2015 - 06:00 Start Date: 1/1/2015 - 00:00 Figure 9-4: Diurnal windEnd Date: 12/31/2017 roses - 18:00 predicted by the WRF model forEnd Date: the 12/31/2017 City - 23:59 Deep reclamation site, for the years 2015-2017. CALM WINDS: TOTAL COUNT: CALM WINDS: TOTAL COUNT:

4.43% 14248 hrs. 0.02% 14248 hrs.

AVG. WIND SPEED: PROJECT NO.: AVG. WIND SPEED: PROJECT NO.:

1.70 m/s 1.58 m/s

The seasonalWRPLOT View - Lakes variation Environmental Software s in wind direction for the CityWRPLOT View Deep - Lakes Environmental siteSoftware are illustrated in Figure 9-5. The highest wind speeds (wind speeds above 6.5 m/s) are experienced in Spring and Summer, with the highest average wind speeds occurring in Spring. The maximum number of calm conditions are experienced in Autumn.

WIND ROSE PLOT: WIND ROSE PLOT: Station #OS_ID: Station #OS_ID: Summer Autumn

NORTH NORTH

10% 10% 8% 8% 6% 6% 4% 4% 2% 2% WEST EAST WEST EAST

WIND SPEED WIND SPEED (m/s) (m/s)

>= 6.50 >= 6.50 5.50 - 6.50 5.50 - 6.50 4.50 - 5.50 4.50 - 5.50 3.50 - 4.50 3.50 - 4.50 SOUTH 2.50 - 3.50 SOUTH 2.50 - 3.50 1.50 - 2.50 1.50 - 2.50 WIND ROSE PLOT: WIND ROSE PLOT: 0.50 - 1.50 0.50 - 1.50 Station #OS_ID: Station #OS_ID: Calms: 3.46% Calms: 2.12%

COMMENTS: DATA PERIOD: Winter COMMENTS: DATA PERIOD: Spring Start Date: 3/1/2015 - 00:00 Start Date: 1/1/2015 - 00:00 End Date: 5/31/2017 - 23:59 NORTH End Date: 12/31/2017 - 23:59NORTH

CALM WINDS: TOTAL COUNT: CALM WINDS: TOTAL COUNT: 3.46% 6624 hrs. 10% 2.12% 6504 hrs. 10% AVG. WIND SPEED: PROJECT NO.: 8% AVG. WIND SPEED: 8% PROJECT NO.: 1.47 m/s 1.62 m/s

WRPLOT View - Lakes Environmental Software 6% WRPLOT View - Lakes Environmental Software 6% 4% 4% 2% 2% WEST EAST WEST EAST

WIND SPEED WIND SPEED (m/s) (m/s)

>= 6.50 >= 6.50 5.50 - 6.50 5.50 - 6.50 4.50 - 5.50 4.50 - 5.50 3.50 - 4.50 3.50 - 4.50 SOUTH 2.50 - 3.50 SOUTH 2.50 - 3.50 1.50 - 2.50 1.50 - 2.50 0.50 - 1.50 0.50 - 1.50 Calms: 2.60% Calms: 1.40%

Figure 9COMMENTS:-5: SeasonalDATA PERIOD: wind roses of winds predicted by theCOMMENTS: WRF modelDATA PERIOD: for the City Deep reclamation Start Date: 6/1/2015 - 00:00 Start Date: 9/1/2015 - 00:00 End Date: 8/31/2017 - 23:59 site, for the years 2015-2017. End Date: 11/30/2017 - 23:59

CALM WINDS: TOTAL COUNT: CALM WINDS: TOTAL COUNT:

2.60% 6624 hrs. 1.40% 6552 hrs.

AVG. WIND SPEED: PROJECT NO.: AVG. WIND SPEED: PROJECT NO.:

1.58 m/s 1.83 m/s

WRPLOT View - Lakes Environmental Software WRPLOT View - Lakes Environmental Software

9.2 Topography

The Highveld inland plateau is fairly flat with elevations varying from 1400 m to 1800 m (Johannesburg 1757 m). As per Figure 9-6 below, the local topography of the Proposed Project area is dominated by urban structures and old Mine Residue Areas.

Figure 9-6: Topography of City Deep dumps and surrounding areas (Source: Topographic-Map, 2018).

The topography varies from 1 665 metres above mean sea level (mamsl) directly west of Dump 4L3, to 1 620 mamsl directly south-east of Dump 4L4. The height of Dump 4L3 and 4L4 is approximately 30 m and 8 m respectively. Dump 4L3 consists of steep side slopes.

The elevation at the eastern dumps varies from 1 650 mamsl directly north of Dump 4L6, to 1 605 mamsl towards the south of Dump 4L6, at the confluence of two non-perennial streams. Dump 4L6 has a height of approximately 8 m. Dump 4L6 consists of steep side slopes.

9.3 Geology

The City Deep project area is located within the Central Rand Goldfields of the Witwatersrand Supergroup. The Central Rand Goldfields are geologically one of the most interesting and economically significant areas in South Africa’s history (Figure 9-7). Having yielded more than one third of all the gold ever produced on the planet, the Witwatersrand Basin held the world’s largest gold reserves (Tucker et al, 2016).

Figure 9-7: The geology of the Witwatersrand Basin stripped of younger cover and showing the position of the seven major goldfields (Source: Tucker et al., 2016).

The Witwatersrand Supergroup comprises a lower “West Rand Group” and an upper “Central Rand Group” (SACS, 1980). The continuity of the major geological units, marker horizons and individual conglomerate reef horizons around the auriferous northern and western basin edges, is a feature of the Witwatersrand as exemplified by the major stratigraphic units of the Central Rand Group.

The lower or West Rand Group (WRG) sediments accumulated in response to rapid episodes of mechanical subsidence related to a pull-apart basin developed under trans-tensional rifting conditions (Maynard & Klein, 1995). Quartzites and iron-rich shales prevail in roughly equal proportions (Pretorius, 1974). Many of the quartzites are shallow marine shelf sand bodies (Eriksson et al., 1979; Beukes & Nelson, 1995). The WRG comprises the lower Hospital Hill Subgroup; middle Government Subgroup and upper Jeppestown Subgroup. The shales of the WRG are characterised by the presence of magnetite bearing interlayers. These layers played a significant role during deep basin exploration, as they were used as magnetic markers.

The overlying Central Rand Group (CRG) is a dominantly arenaceous sequence comprised of quartz-pebble conglomerates, quartzites, quartzwackes and minor shales. The quartzite to shale ratio is 12.6:1 (Pretorius, 1974), as opposed to a ratio of only 1:1 for the WRG. The CRG contains by far the bulk of the gold mineralisation. It is divided into a lower Johannesburg Subgroup and an upper Turffontein Subgroup. These Subgroups are separated by the Booysens Shale Formation, often called the “Upper Shale marker” in the Welkom Goldfield. The Central Rand Group comprises several formations which, although varying in thickness, can be traced and correlated, with a few exceptions, in all the goldfields. The gold-bearing

conglomerate reefs tend to occur in clusters which are informally referred to as “reef groups”. All the important gold reefs lie on prominent unconformity surfaces, many of which can be traced around the entire basin. Compressional tectonic episodes with significant strike movement (Beukes & Nelson, 1995), led to periodic uplift in the hinterland of the basin which was a necessary trigger mechanism for the development of each of the placer gravels

Another characteristic of the Witwatersrand mining area is a series of cross-cutting lineaments representing faults and dykes. The dykes are not 100% impermeable. Fault appearance varies from a hairline width to large breccia filled widths. Faults are commonly filled with intrusive material (Biccard & Jeppe, 1946).

9.4 Soils, Land Use, and Land Capability 9.4.1 Soils

Based on the Digby Wells (2013) Consolidated EIA/EMPr, the soil mainly consists of hill wash materials, with alluvium along watercourses and residual soils all derived from the underlying geology. Major constituents of the materials include sand, fine gravels and minor silt, whilst the alluvial deposits are primarily made up of sand and clay, with minor gravels. Locally developed pedogenic horizons of ferricrete and ferruginous soils are to be found, particularly along the margins of water courses and the capillary fringes of perched water. These soils are typically poor and acid, stony or sandy. See Figure 9-8 below.

9.4.2 Land Capability

There is no agricultural land capability for the Proposed Project area. As a historical mining site, the area is ideal for supporting urban development. This includes land currently occupied by the mine dumps. The land capability of the old dumps is considered as wilderness.

9.4.3 Land Use

The land uses in the immediate vicinity of the project site are generally urban land uses. Typical land uses include industrial activities, residential areas, transport systems and Mine Residue Areas.

Figure 9-8: Soil type around the Proposed Project area.

Figure 9-9: Land uses of the Proposed Project site and surrounding areas.

9.5 Biodiversity 9.5.1 Gauteng Biodiversity Conservation Plan

The Gauteng Conservation Plan (Version 3.3) (GDARD, 2014) (Gauteng C-Plan) classified areas within the province based on its contribution to reach the conservation targets within the province. The Gauteng C- Plan uses the following terms to categorise the various land used types according to their biodiversity and environmental importance:

❖ Critical Biodiversity Area (CBA); ❖ Ecological Support Area (ESA); ❖ Other Natural Area (ONA); ❖ Protected Area (PA); and ❖ Moderately or Heavily Modified Areas (MMA’s or HMA’s).

According to the Gauteng C-plan, parts of the Proposed Project area fall within CBAs, ESAs, and Unclassified areas (Figure 9-10). Based on this desktop information, much of the project area is identified as unclassified, although the pipeline area falls within an important CBA.

Figure 9-10: City Deep project area superimposed on the Gauteng C-plan.

9.5.2 National Biodiversity Assessment

The latest completed National Biodiversity Assessment (NBA) 2011 provides an assessment of South Africa’s biodiversity and ecosystems, including headline indicators and national maps for the terrestrial,

freshwater, estuarine and marine environments. The NBA 2011 was led by the South African National Biodiversity Institute (SANBI) in partnership with a range of organisations, including the Department of Environmental Affairs (DEA), Council for Scientific and Industrial Research (CSIR) and South African National Parks (SANParks). It follows on from the National Spatial Biodiversity Assessment 2004, broadening the scope of the assessment to include key thematic issues as well as a spatial assessment. The NBA 2011 includes a summary of spatial biodiversity priority areas that have been identified through systematic biodiversity plans at national, provincial and local level.

The NBA also provides standard national spatial data layers that can be used in other national, provincial and local planning projects, and an agreed set of national biodiversity targets. In the NBA 2011 these include the first national map of coastal and marine habitat types, and the first national spatial demarcation of the estuarine functional zone.

The two headline indicators assessed in the NBA are ecosystem threat status and ecosystem protection level (Driver et al., 2011).

9.5.2.1 Threatened Ecosystem

Ecosystem threat status outlines the degree to which ecosystems are still intact or alternatively losing vital aspects of their structure, function and composition, on which their ability to provide ecosystem services ultimately depends (Driver et al., 2011).

Ecosystem types are categorised as Critically Endangered (CE), Endangered (EN), Vulnerable (VU) or Least Threatened (LT). According to the Ecosystem Threat Status, defined by the National Biodiversity Assessment (2011), the project area overlaps with ecosystems that are listed as CE. See Figure 9-11. The Proposed Project area is also situated in a “Not Protected” area. This means that the ecosystems in the area are not adequately protected.

Figure 9-11: City Deep Dumps project area showing the ecosystem threat status of the associated terrestrial ecosystems (NBA, 2011).

9.5.2.2 Ecosystem Protection Level

Ecosystem protection level tells us whether ecosystems are adequately protected or under-protected. Ecosystem types are categorised as not protected, poorly protected, moderately protected or well protected, based on the proportion of each ecosystem type that occurs within a protected area recognised in the Protected Areas Act (Driver et al., 2011).

The City Deep project area was superimposed on the ecosystem protection level map to assess the protection status of terrestrial ecosystems associated with the development (Figure 9-12). Based on Figure 9-12 the terrestrial ecosystems associated with the development are rated as not protected for most of the project area.

Figure 9-12: City Deep project area showing the level of protection of terrestrial ecosystems (NBA, 2011)

9.5.3 Gauteng Ridges

The quartzite ridges of Gauteng are one of the most important natural assets in the province. This is because these ridges, and the area immediately surrounding the ridges, provide habitat for a wide variety of fauna and flora, some of which are Red List, rare or endemic species or, in the case of certain of the plant species, are found nowhere else in South Africa or the world.

The different classifications mean that:

❖ Class 1: >= 95% natural; ❖ Class 2: >= 65% and < 95% natural; ❖ Class 3: >= 35% and < 65% natural; and ❖ Class 4: < 35% natural.

From a GIS study, a section of the City Deep project area falls directly on a class 4 ridge, as well as a portion of the pipeline. A class 3 ridge is in proximity (within the 200-metre ridge buffer) (Figure 9-13). To confirm these classifications, ground truthing was done. It was found that some of the mine dumps were interpreted as ridges during the spatial analysis or that the natural ridges were altered historically by amongst other things mining and invasive vegetation (Figure 9-14).

Figure 9-13:The project area in relation to the Gauteng ridge

A B

Figure 9-14: Mine dumps in the project area seen as possible ridges.

9.5.4 Project Area in relation to Protected Areas

Formally protected areas refer to areas protected either by national or provincial legislation. Based on the SANBI (2010) Protected Areas Map and the National Protected Areas Expansion Strategy (NPAES) the project area does not overlap with, nor will it impact upon, any formally protected areas. The closest formally protected area (Walter Sisulu National Botanical Gardens) is 28.96 km away from the project area.

9.5.5 National Freshwater Ecosystem Priority Area (NFEPA) Status

To conserve aquatic ecosystems better, South Africa has recently categorised its river systems according to set ecological criteria (i.e. ecosystem representation, water yield, connectivity, unique features, and threatened taxa) to identify Freshwater Ecosystem Priority Areas (FEPAs) (Driver et al., 2011). The FEPAs are intended to be conservation support tools and envisioned to guide the effective implementation of measures to achieve the National Environment Management Biodiversity Act (NEM:BA) biodiversity goals (Nel et al., 2011).

Figure 9-15 shows the location of the project area in relation to wetland and river FEPAs. Based on this information, the project area does overlap with certain wetland areas and a stream. However, none of these areas are classified as NFEPA wetlands or streams. A few True FEPA wetlands do occur to the west and East of the project area, but none fall within the 500m buffer.

Figure 9-15: The project area in relation to the National Freshwater Ecosystem Priority Areas

9.5.6 The Gauteng Freshwater Assessment

The Gauteng Freshwater Assessment outlines priority areas for freshwater biodiversity in Gauteng. The resulting features are predominantly derived from the NFEPA products, layers include CBA Rivers (based on FEPA and free-flowing rivers), CBA Wetlands (based on FEPA wetlands), CBA Aquatic species (Odonata & crab taxa of conservation concern only), ESA Wetland Clusters (FEPA wetland clusters), and ESA

Wetlands (all other non-FEPA wetlands). This data, together with high-resolution aerial imagery, was used to update and clean some of the features (Freshwater Assessment, 2011).

The project area in relation to the Gauteng Freshwater Assessment overlaps with the following areas: Non-perennial watercourses (Figure 9-16).

Figure 9-16: The City Deep project area in relation to the Gauteng Freshwater Assessment

9.5.7 Flora

The Proposed Project area is situated within the grassland biome. This biome is centrally located in southern Africa, and adjoins all except the desert, fynbos and succulent Karoo biomes (Mucina & Rutherford, 2006). The grassland biome comprises many different vegetation types. The project area is situated within one vegetation type; namely Soweto Highveld Grassland according to Mucina & Rutherford (2006) (Figure 9-17).

Figure 9-17: The City Deep project area showing the vegetation type based on the Vegetation Map of South Africa, Lesotho & Swaziland (BGIS, 2017).

9.5.7.1 Conservation Status

According to Mucina and Rutherford (2006), the Soweto Highveld Grassland vegetation type is classified as Endangered. The national target for conservation protection for both these vegetation types is 24%, but only a few patches are statutorily conserved in Waldrift, Krugersdorp, Leeuwkuil, Suikerbosrand, Rolfe’s Pan Nature Reserves or privately conserved in Johanna Jacobs, Tweefontein, Gert Jacobs, Nikolaas and Avalon Nature Reserves and the Heidelberg Natural Heritage Site.

By 2006 nearly half of the area of occupancy of this vegetation type had already been transformed by cultivation, urban sprawl, mining and building of road infrastructure. The amount of area transformed has most likely increased substantially. Grassland areas have been flooded by dams including Grootdraai, Leeukuil, Trichardtsfontein, Vaal and Willem Brummer.

9.5.7.2 Plant Species of Conservation Concern

Based on the Plants of Southern Africa (BODATSA-POSA, 2016) database, 134 plant species are expected to occur in the area (Figure 9-18). Of the 134-plant species, two (2) species are listed as being Species of Conservation Concern (SCC) (Table 9-4).

Site Location

Figure 9-18: Map showing the grid drawn to compile an expected species list, while the red blocks indicate the areas where the highest densities were surveyed (BODATSA-POSA, 2016)

Table 9-4:Plant Species of Conservation Concern (SCC) expected to occur in the project area (BODATSA- POSA, 2016) Family Taxon IUCN Ecology Asteraceae Cineraria longipes VU Indigenous; Endemic Aizoaceae Khadia beswickii VU Indigenous; Endemic

Cineraria longipes is listed as VU according to the Red List of South African Plants (SANBI, 2017) and can be found in the Andesite Mountain Bushveld, Gold Reef Mountain Bushveld and Soweto Highveld Veld type. As a result of extensive habitat loss over a long period of time only six subpopulations of this species now remain in South Africa (SANBI, 2017).

Khadia beswickii is listed as VU according to the Red List of South African Plants (SANBI, 2017). It is endemic to South Africa where it mainly occurs in Gauteng and the North West in the Tsakane Clay Grassland, Soweto Highveld Grassland, Carletonville Dolomite Grassland, Andesite Mountain Bushveld and Gauteng Shale Mountain Bushveld veld types. It occurs in open shallow soil over rocks in grassland. Major threats to this species include habitat loss, invasive species and harvesting (SANBI, 2017).

9.5.7.3 Habitat Assessment

Habitats identified during the field visit can be seen in Figure 9-19. A general project area was drawn to assist with the division of the habitat types. Three primary habitats were delineated for this assessment, namely: Disturbed, Natural Grassland and Wetland Habitats.

Figure 9-19: Habitats identified in a general study area

Disturbed habitats are those which were considered to have been extensively altered from their natural state and no longer provide ecosystem services or suitable habitat for indigenous species. Areas such as roads, existing infrastructure and degraded grassland occur in this habitat type and is usually infested with alien or invasive plant species.

Natural grassland habitats were those areas which are considered to be in a relatively natural or semi- natural condition and provide suitable habitat and a food resource for various species, including possible species of conservation concern. The riverine area is included in this habitat type.

Wetland habitats are found in the northern parts of the project area. These areas, although somewhat disturbed, provide habitat for various waterfowl and act as important corridors for local wildlife.

9.5.7.4 Vegetation Assessment

The vegetation assessment was conducted throughout the extent of the project area. A total of 41 tree, shrub and herbaceous plant species were recorded in the project area during the field assessment (Table 9-5). Plants listed as alien or invasive species under the NEM:BA category 1 appear in green text.

Table 9-5: Trees, shrubs and weeds recorded at the proposed project area Thread status Scientific Name Common Name SA Endemic NEM:BA Category (SANBI, 2017) Acacia mearnsii Black Wattle NEM:BA Category 2 Agave sisalana Sisal NEM:BA Category 2 Celtis australis Nettle Tree NEM:BA Category 4 Not indigenous; Conyza bonariensis Hairy Fleabane Naturalised NEM:BA Category Cortaderia selloana Pampas Grass 1b Bermuda Grass / Common Cynodon dactylon NEM:BA Category 2 Couch Naturalised; Datura ferox Long Spined Thorn Apple Invasive Diospyros lycioides Bluebush, star-apple No subsp. lycioides Eragrostis curvula Weeping love grass LC No NEM:BA - a. Eucalyptus sp Gum Trees Category 1b within- (i) riparian areas Felicia muricata Fine-leaved aster LC No Not Endemic; Flaveria bidentis Smelter’s bush Naturalised; Invasive Hermannia Orange hermannia LC Yes lancifolia Imperata cylindrica Cogon Grass LC No Ipomoea purpurea Morning Glories Nemba Category 1b Ledebouria luteola Highveld African Hyacinth LC No Ledebouria Flat-leaved African Hyacinth LC Yes ovatifolia Morus alba Common Mulberry NEM:BA Category 3 Nemesia fruticans Mauve nemesia LC No

Thread status Scientific Name Common Name SA Endemic NEM:BA Category (SANBI, 2017) NEM:BA Category Pennisetum Kikuyu Grass 1b in protected clandestinum areas and wetlands Phragmites australis Commom Reed LC No Plantago lanceolata Narrow-leaved Ribwort LC No Polygala Small Purple Broom LC No hottentotta Polypogon Not Endemic; Beard-grass monspeliensis Naturalised Populus alba White Poplar NEM:BA Category 2 Robinia NEM:BA Category Black Locust pseudoacacia 1b Scabiosa Wild scabious LC No columbaria NEM:BA Category Schinus molle False Pepper Tree 1b Not Indigenous; Schkuhria pinnata Dwarf Mexican marigold Naturalised Selago densiflora LC No Solanum NEM:BA Category Bugweed mauritianum 1b Solanum NEM:BA Category Dense-thorned Bitter Apple sisymbriifolium 1b Stoebe plumosa Bakrupt Bush LC No Weed in disturbed places. Has become naturalised and due Tagetes minuta Khaki Weed to the vast amount of seed set, difficult to control Tamarix NEM:BA Category Pink Tamarisk ramosissima 1b NEM:BA Category Tecoma stans Yellow Bells 1b Tipuana tipu Tipu Tree NEM:BA Category 3 Not Indigenous; Verbena aristigera Fine Leaved Verbena Naturalised Verbena NEM:BA Category Purple Top / Tall verbena bonariensis 1b Vernonia Bicoloured-leaved vernonia LC No oligocephala Vigna vexillata Zombi pea LC No

9.5.7.5 Alien and Invasive Plants

Declared weeds and invader plant species have the tendency to dominate or replace the canopy or herbaceous layer of natural ecosystems, thereby transforming the structure, composition and function of these systems. Therefore, it is important that these plants are controlled and eradicated by means of an eradication and monitoring programme. Some invader plants may also degrade ecosystems through superior competitive capabilities to exclude native plant species.

The NEM:BA is the most recent legislation pertaining to alien invasive plant species. In August 2014, the list of Alien Invasive Species was published in terms of the NEM:BA in Government Gazette No 78 of 2014. The Alien and Invasive Species Regulations were published in the Government Gazette No. 37886, 1 August 2014. The legislation calls for the removal and / or control of alien invasive plant species (Category 1 species). In addition, unless authorised thereto in terms of the NWA, no land user shall allow Category 2 plants to occur within 30 metres of the 1:50 year flood line of a river, stream, spring, natural channel in which water flows regularly or intermittently, lake, dam or wetland. Category 3 plants are also prohibited from occurring within proximity to a watercourse.

Note that according to the regulations, a person who has under his or her control a category 1b listed invasive species must immediately:

❖ Notify the competent authority in writing. ❖ Take steps to manage the listed invasive species in compliance with: o Section 75 of the Act; o The relevant invasive species management programme developed in terms of regulation 4; and o Any directive issued in terms of section 73(3) of the Act.

Nine Category 1b invasive plant species were recorded within the project area and the reclamation will result in the removal of these species as per section 75 of the Act as stated above. The NEM:BA listed species identified within the project area are marked in green (Table 9-5).

9.5.8 Fauna

9.5.8.1 Avifauna

Based on the South African Bird Atlas Project, Version 2 (SABAP2) database, 422 bird species are expected to occur in the vicinity of the project area (pentads 2605_2755, 2605_2800, 2605_2805, 2610_2755, 2610_2800, 2610_2805, 2615_2755, 2615_2800, 2615_2805). Of the expected bird species, thirty-seven (37) species (8.7%) are listed as Species of Conservation Concern (SCC) either on a regional (33) or global scale (18)).

The SCC include the following:

❖ Ten (10) species that are listed as EN on a regional basis; ❖ Ten (10) species that are listed as VU on a regional basis; and

❖ Thirteen (13) species that are listed as NT on a regional basis;

On a global scale, three (3) are listed as EN, five (5) species are listed as VU and ten (10) species as NT.

Important Bird and Biodiversity Areas (IBAs) are the sites of international significance for the conservation of the world's birds and other conservation significant species as identified by BirdLife International. These sites are also all Key Biodiversity Areas (KBA); sites that contribute significantly to the global persistence of biodiversity (Birdlife, 2017).

According to Birdlife International (2017), the selection of IBAs is achieved through the application of quantitative ornithological criteria, grounded in up-to-date knowledge of the sizes and trends of bird populations. The criteria ensure that the sites selected as IBAs have true significance for the international conservation of bird populations and provide a common currency that all IBAs adhere to, thus creating consistency among, and enabling comparability between, sites at national, continental and global levels.

No IBA is found close to the project area. The closest IBA (Suikerbosrand) is 28km away followed by Magaliesberg IBA (35km). The proposed project will not have an impact on these IBAs.

Twenty five bird species were recorded in the project area during the November 2018 survey based on either direct observations, vocalisations, or the presence of visual tracks & signs (Table 9-6).

No avifaunal SCC were recorded during the survey but based on the presence of some suitable grassland habitat, there is a moderate probability that other bird SCC occur within the project area – especially grassland bird species.

Table 9-6: A list of avifaunal species recorded for the project area Conservation Status Species Common Name Regional (SANBI, 2016) IUCN (2017) Acridotheres tristis Myna, Common Unlisted LC Anthus cinnamomeus Pipit, African Unlisted LC Bostrychia hagedash Ibis, Hadeda Unlisted LC Burhinus capensis Thick-knee, Spotted Unlisted LC Columba livia Dove, Rock Unlisted LC Corvus albus Crow, Pied Unlisted LC Elanus caeruleus Kite, Black-shouldered Unlisted LC Euplectes orix Bishop, Southern Red Unlisted LC Falco amurensis Falcon, Amur Unlisted LC Hirundo albigularis Swallow, White-throated Unlisted LC Hirundo cucullata Swallow, Greater Striped Unlisted LC Lamprotornis nitens Starling, Cape Glossy Unlisted LC Lanius collaris Fiscal, Common (Southern) Unlisted LC Passer domesticus Sparrow, House Unlisted LC Passer melanurus Sparrow, Cape Unlisted LC Ploceus velatus Masked-weaver, Southern Unlisted LC Psophocichla litsipsirupa Thrush, Groundscraper Unlisted Unlisted

Conservation Status Species Common Name Regional (SANBI, 2016) IUCN (2017) Pycnonotus tricolor Bulbul, Dark-capped Unlisted Unlisted Quelea quelea Quelea, Red-billed Unlisted LC Saxicola torquatus Stonechat, African Unlisted LC Streptopelia capicola Turtle-dove, Cape Unlisted LC Threskiornis aethiopicus Ibis, African Sacred Unlisted LC Urocolius indicus Mousebird, Red-faced Unlisted LC Vanellus armatus Lapwing, Blacksmith Unlisted LC Vanellus senegallus Lapwing, African Wattled Unlisted LC

9.5.8.2 Mammals

The IUCN Red List Spatial Data (IUCN, 2017) lists 86 mammal species that could be expected to occur within the Project area. It must be noted that this data is based on the natural unaltered environment before impacts. Of these species, 5 are medium to large conservation dependant species, such Ceratotherium simum (Southern White Rhinoceros) and Tragelaphus oryx (Common Eland) that, in South Africa, are generally restricted to protected areas such as game reserves. Of the remaining 81 small to medium sized mammal species, thirteen (16%) are listed as being of conservation concern on a regional or global basis. These species are not expected to occur in the project area.

Overall, mammal diversity in the project area was low, with signs of one mammal species recorded during the November 2018 survey based on direct observations and/or the presence of visual tracks & signs. No mammal SCC was recorded, but due to the availability of some natural areas the likelihood of other SCCs being present does exist.

Table 9-7:The mammal species recorded in the project area. Conservation Status Species Common Name Regional (SANBI, 2016) IUCN (2017) Lepus saxatilis Scrub Hare LC LC

9.5.8.3 Herpetofauna (Reptiles and Amphibians)

Based on the IUCN Red List Spatial Data (IUCN, 2017) and the ReptileMap database provided by the Animal Demography Unit (ADU, 2017) 50 reptile species are expected to occur in the project area. Of the expected reptile species, only one is regarded as a SCC, namely the Striped Harlequin Snake (Homoroselaps dorsalis) which is partially fossorial and known to inhabit old termitaria in grassland habitat (IUCN, 2017). Most of its range is at moderately high altitudes, reaching 1 800 m in Mpumalanga and Swaziland, but it is also found at elevations as low as about 100 m in KwaZulu-Natal. The likelihood of occurrence was rated as moderate due to some suitable habitat remaining in the grassland areas.

Based on the IUCN Red List Spatial Data (IUCN, 2017) and the AmphibianMap database provided by the Animal Demography Unit (ADU, 2017) 20 amphibian species are expected to occur in the project area. The Giant Bull Frog (Pyxicephalus adspersus) is a species of conservation concern that will possibly occur in the project area. The Giant Bull Frog is listed as near threatened on a regional scale. It is a species of

drier savannahs. It is fossorial for most of the year, remaining buried in cocoons. They emerge at the start of the rains, and breed in shallow, temporary waters in pools, pans and ditches (IUCN, 2017). The likelihood of occurrence is rated as moderate due to the proximity to urbanization and the lack of adequate temporary water pool in the project area.

Herpetofauna diversity was considered to be low with no reptile or amphibian species were observed or recorded in the project area during the November 2018 survey. Based on the disturbed nature of the area the herpetofauna diversity is expected to be low.

9.5.9 Sensitivity mapping

Areas that were classified as having low or moderate sensitivities are those areas which were deemed by the specialists to have been most impacted upon and/or were modified from their original condition due to factors such as over-grazing, human activity and/or presence of alien invasive species. The disturbed nature of the project area decreased the sensitivity and as such the whole area is rated as low to moderately sensitive (Figure 9-20).

Freshwater ecosystems such as rivers and wetlands are generally the lowest point in a landscape, and therefore particularly vulnerable to pollution from waste, sedimentation and pollutants present in runoff. This combined with the strong connectivity of freshwater ecosystems makes them highly susceptible to upstream impacts. Vegetative buffer areas have a significant impact on pollution control, the associated water quality in nearby water bodies, and soil erosion control, as well as providing wildlife habitat and movement corridors for species such as Water Monitors and Otters. Therefore, such areas are typically given a higher sensitivity rating. Due to the dam in the project area being impacted upon due to human encroachment and disturbance, these areas were given a moderate sensitivity.

It is important to note that these maps do not replace any local, provincial or government legislation relating to these areas or the land use capabilities or sensitivities of these environments.

Figure 9-20: Habitat sensitivity map of the project area

9.5.10 Current Impacts

The current impacts observed during surveys are listed below. Photographic evidence of a selection of these impacts is shown in Figure 9-21.

❖ Existing slime dams; ❖ Erosion; ❖ Human encroachment; ❖ Alien and/or Invasive Plants (AIP); ❖ Servitudes and infrastructure (powerlines); ❖ Building rubble dumping; and ❖ Vegetation removal.

Figure 9-21:Some of the impacts observed in the project area7.

9.6 Wetlands 9.6.1 NRFPA Wetlands

One wetland type has been identified according to the NFEPA wetland layer within the 500 m regulated area, namely a hillslope seep, see Figure 9-22.

9.6.2 City of Johannesburg Wetland

A wetland audit was completed for the City of Johannesburg (2009) with the intention of locating wetland areas that may then be considered for spatial planning. From the available dataset, it was indicative that there was a channelled valley bottom wetland within the 500m regulated area of the Proposed Project (Figure 9-22).

7 A) Building rubble that is being dumped in the area, B) Run down buildings and invasive plant species, C) Mine dump with electrical cables and D) High voltage electrical cables.

Figure 9-22:City of Johannesburg and NFEPA wetland layers within the 500 m regulated area

9.6.3 Wetland Delineation

The wetland areas were delineated in accordance with the DWAF (2005) guidelines (see Figure 9-23). The National Wetland Classification Systems (NWCS) developed by the South African National Biodiversity Institute (SANBI) comprises a hierarchical classification process of defining a wetland based on the principles of the hydrogeomorphic (HGM) approach at higher levels, and then also includes structural features at the lower levels of classification (Ollis et al. 2013).

During the field survey, one channelled valley bottom wetland system, various hillslope seeps, a wetland flat and an unchannelled valley bottom wetland was identified, of which the latter two have been excluded from this assessment. The wetland flat is located up-slope from the location where the proposed pipeline ends (at the Rosherville Dam pump), which renders the wetland safe from any impacts. This wetland with its recommended buffer zone has been added into the wetland delineation to ensure that the area remains a no-go-area. The unchannelled valley bottom wetland is located on top of and adjacent to the dumps which indicates the presence of a Witbank soil form, which according to (DWAF, 2005) is not a suitable hydromorphic soil and can therefore not be classified as a wetland area.

The channelled valley bottoms (HGM 1) are located within the 500 m regulated area, adjacent to the City Deep dumps. One of these wetlands are fed by steady flow from the Rosherville Dam, located to the north of the project area. Temporary flooding events occur throughout the wet season, following high rainfall

events, which allow for the overspill of the channelled valley bottom wetland’s banks, subsequently resulting in temporary saturated wet zones, see Figure 9-23.

A series of hillslope seeps (HGM 2) are located within the middle of the project area and adjacent to the proposed pipeline. These seeps are fed by stormwater drains and general overland flow from the surrounding artificial surfaces and in turn feeds the channelled valley bottom to the south of the wetland.

Figure 9-23: Delineation of wetlands within project area

Figure 9-24: Wetlands identified within the 500 m regulated area

These systems are covered in Imperata cylindrica which makes these wetlands easily identifiable (Figure 9-24).

9.6.4 Wetland Unit Identification

The wetland classification as per SANBI guidelines (Ollis et al. 2013) is presented in Table 9-8. Two wetland types were identified within the project assessment boundary, namely a channelled valley bottom wetland (HGM 1) and a hillslope seep (HGM 2).

Table 9-8: Wetland classification as per SANBI guideline (Ollis et al. 2013) Level 1 Level 2 Level 3 Level 4 Wetland DWS NFEPA Wet Veg Landscape System System 4A (HGM) 4B 4C Ecoregion/s Group/s Unit Highveld Grassland Channelled HGM 1 Inland Highveld Valley Floor N/A N/A Group 3 Valley Bottom Without Highveld Grassland HGM 2 Inland Highveld Hillslope Hillslope Seep channelled N/A Group 3 outflow

9.6.5 Wetland Ecological Functional Assessment

The ecosystem services provided by the wetlands identified on site were assessed and rated using the WET-EcoServices method (Kotze et al. 2008). The summarised results for HGM 1 and HGM 2 are shown in Table 9-9. The average ecosystem services score has been determined to be “Intermediate” for HGM 1 and HGM 2.

Table 9-9: The ecosystem services being provided by the HGM units Wetland Unit HGM 1 HGM 2

Flood attenuation 2.0 1.8

Streamflow regulation 1.7 1.7

Sediment trapping 1.6 1.5

Phosphate assimilation 2.1 2.3 Water Quality supporting benefits supporting Nitrate assimilation 2.4 2.8 enhancement benefits

Indirect Benefits Indirect Toxicant assimilation 2.3 2.0

Erosion control 1.6 2.5

Regulating and and Regulating Carbon storage 1.0 1.0

Biodiversity maintenance 1.3 1.4

Provisioning of water for human use 0.8 0.3

Provisioning of harvestable resources 0.0 0.0

benefits Provisioning of cultivated foods 0.0 0.0

Ecosystem Services Supplied by Wetlands by Supplied Services Ecosystem Provisioning Provisioning

Cultural heritage 0.0 0.0 Direct Benefits Direct

Tourism and recreation 0.4 0.4 Cultural Cultural benefits Education and research 2.0 2.0

Average Eco Services Score 1.3 1.3

Table 9-10 illustrates the ecosystem services rated “High” for the delineated wetlands with summarised descriptions of these ecosystem services. For HGM 1, three ecosystem services have been rated “High”, namely the assimilation of phosphates, nitrates and toxicants. Similarly, three ecosystem services have been rated “High” for HGM 2, namely that of erosion control and the assimilation of phosphates and nitrates.

Table 9-10: Ecosystem services scored "High” for the delineated wetland

EcoService HGM 1 HGM 2 Justification of High Score

Phosphate The high score presented for the assimilation of phosphates, nitrates Assimilation and toxicants is described to the potential of large concentrations Nitrate these contaminants entering the wetland and the opportunity to decrease the concentration of contaminants entering important Assimilation

watercourses down-stream. Additionally, the extent of vegetation Toxicant cover within HGM 2 contributes to the high scores rated for the Assimilation assimilating of various contaminants.

The high surface cover and the nature of diffuse flows within the Erosion Control wetland contributes significantly to the high erosion control ecosystem service score for HGM 2.

9.6.6 The Ecological Health Assessment

The Present Ecological Status (PES) for the assessed HGM types is presented in Table 9-11. The hydrology component for HGM 1 and HGM 2 has been scored “Critically Modified” and “Moderately Modified” respectively. The geomorphology component of HGM 1 and HGM 2 have been scored “Moderately Modified” and “Natural” respectively whereas the vegetation component for HGM 1 and HGM 2 has been rated “Critically Modified” and “Moderately Modified” respectively. The overall PES for HGM 1 and HGM 2 has been determined to be “Seriously Modified” and “Moderately Modified”, which indicates high disturbances within HGM 1 and its catchment and moderate disturbances within HGM 2’s catchment.

The hydrology component has been modified due to altered water inputs by means stormwater outlets, the presence of the Rosherville Dam that impedes the flow of water and the presence of alien invasive species, including an abundance of Acacia mearnsii and Eucalyptus globulus. The geomorphology component has been modified by changes in run-off characteristics, which include the increase in run-off from the surrounding dumps and artificial surfaces. The vegetation component has been modified by dumping and artificial surfaces (including dumps).

Table 9-11: Summary of the scores for the wetland PES Hydrology Geomorphology Vegetation Wetland Rating Score Rating Score Rating Score C: Moderately HGM 1 F: Critically Modified 9.5 3.0 F: Critically Modified 8.2 Modified Overall PES 7.3 Overall PES Class E: Seriously Modified Score C: Moderately C: Moderately HGM 2 3.5 A: Natural 0.5 3.1 Modified Modified Overall PES 2.5 Overall PES Class C: Moderately Modified Score

9.6.7 The EIS Assessment of the Remaining Wetland Areas

The wetland Ecological Importance and Sensitivity (EIS) assessment was applied to the HGM units described in the previous section to assess the levels of sensitivity and ecological importance of the wetlands. The results of the assessment are shown in Table 9-12.

A “Moderate” score has been determined for the ecological importance and sensitivity for both wetlands. These scores are low due to very few aspects contributing to the sensitivity of these wetlands or the ecological importance. Very few significant species were identified during the survey with habitat types restricted to one or two.

The Hydrological/Functional Importance has been rated “Moderate” for both wetlands due to very few ecosystem service scores related to the improvement of water quality. The only ecosystem scores that have been scored “High: includes;

❖ Erosion control; and ❖ The assimilation of toxicants, nitrates and phosphates.

The Direct Human Benefits have been scored “Low” for both HGM units due to inability of the wetlands to provide sustenance, cultural and religious benefits for the surrounding community.

Table 9-12: The EIS results for the delineated HGM types Importance Wetland Importance & Sensitivity HGM 1 HGM 2

Ecological importance and sensitivity 1.4 1.2

Hydrological/functional importance 1.9 1.8

Direct human benefits 0.9 0.8

9.6.8 Buffer Requirements

The GDARD requires that wetlands within Gauteng be granted a buffer zone of 30m in urban areas and 50m in rural areas, (Macfarlane et al., 2009). Seeing that the project area is in an urban area, a 30m buffer zone is required for the delineated wetland zones, see Figure 9-25.

Figure 9-25: 30m buffer requirement

9.7 Surface Water 9.7.1 Regional Catchments and Drainage

The project is located in the Vaal Water Management Area (WMA), within quaternary catchment C22B in the Klip River Catchment. Three non-perennial tributaries drain the dumps into the Natalspruit immediately south of Dump 4L6. The Natalspruit flows in a south-easterly direction until it meets the Elsburgspruit, and then in a southerly direction until it forms a confluence with the Rietspruit at the outlet of quaternary catchment C22B. From here, the Rietspruit flows in a westerly direction until it meets the Klip River above the settlement of Daleside. The Klip River then flows in a south-westerly direction past the town of Meyerton, and into the Vaal River immediately above the Vaal Barrage, near the town of Vereeniging ( refer to Figure 9-26).

Figure 9-26: Regional catchments around the project location.

9.7.2 Surface Water Runoff

According to the WR2012 study, quaternary catchment C22B has a Mean Annual Runoff (MAR)8 of 19.4 million cubic metres (mcm). The peak runoff volumes from the dumps for various storm durations and frequencies are indicated in Table 9-13, and were calculated using the Soil Conservation Service (SCS) method.

Table 9-13: Estimated peak runoff volumes from the dump areas.

1:2 Year 1:5 Year 1:10 Year 1:20 Year 1:50 Year 1:100 Year Peak Peak Peak Peak Peak Peak Catchment CN Dump Runoff Runoff Runoff Runoff Runoff Runoff Area (m2) Value Volume Volume Volume Volume Volume Volume (m3) (m3) (m3) (m3) (m3) (m3)

4L3 452 487 60 3 300 7 300 10 900 15 200 22 500 29 000 4L4 276 710 60 2 000 4 500 6 700 9 300 13 600 17 700 4L6 604 618 60 4 200 9 200 13 900 19 600 28 900 37 500

9.7.3 Surface Water Quality

Monitoring is currently taking place in the vicinity of the project at the monitoring points indicated in Table 9-14 and Figure 9-27. Surface water quality monitoring data was obtained from Ergo.

Table 9-14: Location of the mines surface water quality monitoring points in the vicinity of the project. Monitoring Point Description of Location Latitude (South)* Longitude (East)* U/S Basin reclamation - Behind N17 Mooi CD1 -26.231111 28.070278 Street Bridge CD2 D/S Basin reclamation- Behind City Deep Plant -26.227778 28.074722

CD3 Upstream Maretsel Inlet - Chilvers off ramp -26.207778 28.107500

CD4 Downstream Maretsel outlet -26.217222 28.108333

CD5 Rosherville dam outlet - Container depot -26.227778 28.106667

CD6 South of 4A11 - Lower Germiston -26.217500 28.133611

CD7 Germiston N3 -26.239817 28.123450 *Coordinates in decimal degrees, geographic coordinate system (latitude and longitude), WGS84 datum

8 The MAR is used in stormwater management design and water balance calculations.

Figure 9-27: Location of the mines surface water quality monitoring points in the vicinity of the project.

The surface water quality results for the January and September 2018 monitoring are indicated in Table 9-15. Results were compared to the Klip River catchment guideline limits, as the monitoring points are located on tributaries of the Natalspruit, which falls within the Klip River catchment. The guideline limits are specified as:

❖ Ideal – this is the range that results should ideally fall within; ❖ Acceptable – results that fall within this range are acceptable but not ideal; ❖ Tolerable – results that fall within this range are tolerable; and ❖ Unacceptable – results that fall within this range are unacceptable.

Results falling within the above ranges were coloured appropriately.

Water quality results for the monitoring points indicated the following:

❖ CD2 – exceeded unacceptable limits for iron; ❖ CD4 – exceeded unacceptable limits in pH, electrical conductivity, sulphates, magnesium, aluminium and manganese; ❖ CD6 – exceeded tolerable and unacceptable limits for iron and manganese; and ❖ CD7 – exceeded tolerable limits for manganese.

The catchment in which the monitoring points are located, is characterised by industrial areas and historical mine dumps, some of which are currently being reclaimed. It is likely that the elevated parameters are a result of runoff from these areas.

Table 9-15: Surface water quality results for January and September 2018. Instream Water Quality Guidelines for the Klip River Monitoring Points and Water Quality Results Analyses in mg/ℓ Catchment (Unless specified Units Ideal Acceptable Tolerable CD1 CD2 CD3 CD4 CD5 CD6 CD7 otherwise) Catchment Management Interim Unacceptable Jan-18 Sep-18 Jan-18 Sep-18 Jan-18 Sep-18 Jan-18 Sep-18 Jan-18 Sep-18 Jan-18 Sep-18 Jan-18 Sep-18 Background Target Target pH - Value @ 25 º pH units 6.0 - 9.0 ------< 6.0; > 9.0 7.3 7.6 6.9 6.6 7.4 7.4 3.5 4 7.4 7.4 7 7.3 6.3 --- C Electrical Conductivity in mS/m <80 80 - 100 100 - 150 > 150 50.1 53.6 46.1 55.3 41 56.4 151 164 50.3 77.6 51.6 51.7 70.3 --- mS/m @ 25°C Total Dissolved Solids @ 180°C mg/ℓ ------390 356 346 362 232 294 1436 1610 330 518 368 284 560 --- mg/l Total Acidity as mg/ℓ ------<5 <5 8 <5 <5 <5 220 328 <5 <5 8 <5 12 --- CaCO₃ mg/l Chloride as Cl mg/l mg/ℓ < 50 50 - 75 75 - 100 > 100 24 22 33 29 36 46 21 24 25 31 25 29 29 --- Sulphate as SO₄ mg/ℓ < 200 200 - 350 350 - 500 > 500 133 131 111 182 31 47 876 1039 108 227 115 67 264 --- mg/l Fluoride as F mg/l mg/ℓ < 0.19 0.19 - 0.7 0.7 - 1.00 > 1.00 0.3 0.2 <0.2 0.2 <0.2 <0.2 <0.2 <0.2 0.2 0.2 0.2 0.2 <0.2 ---

Nitrate as N mg/l mg/ℓ < 2 2.0 - 4.0 4.0 - 7.0 > 7.0 0.2 0.4 2.6 1.4 0.9 <0.1 0.1 <0.1 0.1 1.1 0.1 <0.1 2.3 ---

Nitrite as N mg/l mg/ℓ ------<0.05 <0.05 0.1 0.1 0.2 <0.05 <0.05 <0.05 0.06 0.1 <0.05 <0.05 <0.05 ---

Bromide as Br mg/l mg/ℓ ------0.2 <0.1 0.3 <0.1 0.3 <0.1 0.1 <0.1 0.2 <0.1 0.2 <0.1 0.2 --- Ortho Phosphate mg/ℓ ------<0.1 <0.1 <0.1 <0.1 0.2 0.2 <0.1 <0.1 <0.1 <0.1 <0.1 0.5 <0.1 --- as P mg/l Total Cyanide as mg/ℓ ------<0.02 <0.07 <0.02 <0.07 <0.02 <0.07 <0.02 <0.07 <0.02 <0.07 <0.02 <0.07 <0.02 --- CN mg/l Free and Saline Ammonia as N mg/ℓ ------0.1 0.2 2.2 2.6 6.6 14 1.6 0.3 8 8.9 2 15 0.6 --- mg/l Sodium as Na mg/l mg/ℓ < 50 50 -80 80 - 100 > 100 24 23 29 28 33 45 23 26 26 35 21 24 21 --- Potassium as K mg/ℓ ------4.1 6 5.1 5.5 6 8.4 6.2 6.2 7.8 8.6 5.4 7.5 5.3 --- mg/l Calcium as Ca mg/l mg/ℓ ------54 57 33 50 24 24 129 144 44 72 50 32 75 --- Magnesium as Mg mg/ℓ < 8 8.00 - 30.00 30 - 70 > 70 15 16 12 14 8 9 73 85 13 22 19 13 29 --- mg/l Aluminium as Al mg/ℓ --- < 0.3 0.3 - 0.5 > 0.5 <0.100 <0.100 <0.100 <0.100 <0.100 <0.100 24 40 <0.100 <0.100 <0.100 <0.100 <0.100 --- (Dissolved) mg/l Antimony as Sb mg/ℓ ------<0.020 <0.001 <0.020 <0.001 <0.020 0.001 <0.020 0.001 <0.020 <0.001 <0.020 <0.001 <0.020 --- (Dissolved) mg/l Arsenic as As mg/ℓ ------<0.010 0.002 <0.010 0.001 <0.010 0.004 <0.010 0.016 <0.010 0.002 <0.010 0.001 <0.010 --- (Dissolved) mg/l

Instream Water Quality Guidelines for the Klip River Monitoring Points and Water Quality Results Analyses in mg/ℓ Catchment (Unless specified Units Ideal Acceptable Tolerable CD1 CD2 CD3 CD4 CD5 CD6 CD7 otherwise) Catchment Management Interim Unacceptable Jan-18 Sep-18 Jan-18 Sep-18 Jan-18 Sep-18 Jan-18 Sep-18 Jan-18 Sep-18 Jan-18 Sep-18 Jan-18 Sep-18 Background Target Target Barium as Ba mg/ℓ ------0.036 0.073 0.056 0.063 0.057 0.044 0.046 0.03 0.03 0.031 0.059 0.033 0.025 --- (Dissolved) mg/l Beryllium as Be mg/ℓ ------<0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 --- (Dissolved) mg/l Bismuth as Bi mg/ℓ ------<0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 --- (Dissolved) mg/l Boron as B mg/ℓ ------0.052 0.065 0.041 0.053 0.033 0.043 0.089 0.085 0.068 0.101 0.071 0.055 0.067 --- (Dissolved) mg/l Cadmium as Cd mg/ℓ ------<0.003 <0.003 <0.003 <0.003 <0.003 <0.003 <0.003 <0.003 <0.003 <0.003 <0.003 <0.003 <0.003 --- (Dissolved) mg/l Hexavalent Chromium as Cr mg/ℓ ------<0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 <0.010 --- mg/l Total Chromium as mg/ℓ ------<0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 --- Cr (Dissolved) mg/l Cobalt as Co mg/ℓ ------<0.025 <0.025 0.045 0.089 <0.025 <0.025 2.56 3.5 <0.025 0.064 0.044 0.025 0.067 --- (Dissolved) mg/l Copper as Cu mg/ℓ ------<0.010 <0.010 <0.010 <0.010 <0.010 <0.010 0.125 0.304 <0.010 <0.010 <0.010 <0.010 <0.010 --- (Dissolved) mg/l Iron as Fe mg/ℓ < 0.5 0.5 - 1.0 1.0 - 1.5 > 1.5 <0.025 0.274 0.032 2.43 0.053 0.884 0.716 0.52 0.028 0.068 1.4 2.02 0.028 --- (Dissolved) mg/l Ferrous Iron as Fe2+ (Dissolved) mg/ℓ ------<0.025 0.11 <0.025 2.14 0.044 0.057 0.716 0.358 0.054 0.05 <0.025 0.043 <0.025 --- mg/l Ferric Iron as Fe3+ mg/ℓ ------<0.025 0.164 0.032 0.293 <0.025 0.827 <0.025 0.162 <0.025 <0.025 1.4 1.97 0.028 --- (Dissolved) Lead as Pb mg/ℓ ------<0.010 <0.010 <0.010 <0.010 <0.010 <0.010 0.026 0.022 <0.010 <0.010 <0.010 <0.010 <0.010 --- (Dissolved) mg/l Lithium as Li mg/ℓ ------<0.025 <0.025 <0.025 <0.025 <0.025 <0.025 0.039 0.067 <0.025 <0.025 <0.025 <0.025 <0.025 --- (Dissolved) mg/l Manganese as Mn mg/ℓ < 1 1.0 - 2.0 2.0 - 4.0 > 4.0 0.042 0.171 1.16 1.11 0.059 0.097 33 40 0.872 2.02 3.97 1.17 2.62 --- (Dissolved) mg/l Mercury as Hg mg/ℓ ------0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 0.001 <0.001 0.001 <0.001 <0.001 <0.001 --- (Dissolved) mg/l Molybdenum as Mo (Dissolved) mg/ℓ ------<0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 --- mg/l Nickel as Ni mg/ℓ ------<0.025 <0.025 0.112 0.193 <0.025 <0.025 2.29 3.19 0.027 0.061 0.075 0.029 0.094 --- (Dissolved) mg/l Phosphorus as P mg/ℓ ------<0.025 <0.025 <0.025 <0.025 0.202 0.849 <0.025 <0.025 <0.025 <0.025 <0.025 0.877 <0.025 --- (Dissolved) mg/l

Instream Water Quality Guidelines for the Klip River Monitoring Points and Water Quality Results Analyses in mg/ℓ Catchment (Unless specified Units Ideal Acceptable Tolerable CD1 CD2 CD3 CD4 CD5 CD6 CD7 otherwise) Catchment Management Interim Unacceptable Jan-18 Sep-18 Jan-18 Sep-18 Jan-18 Sep-18 Jan-18 Sep-18 Jan-18 Sep-18 Jan-18 Sep-18 Jan-18 Sep-18 Background Target Target Selenium as Se mg/ℓ ------<0.010 <0.001 <0.010 <0.001 <0.010 <0.001 <0.010 0.006 <0.010 0.001 <0.010 <0.001 <0.010 --- (Dissolved) mg/l Silicon as Si mg/ℓ ------1.7 1.9 3.8 3.4 5 5.7 7.1 9.8 4.8 4.4 6.2 5.1 2.4 --- (Dissolved) mg/l Silver as Ag mg/ℓ ------<0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 --- (Dissolved) mg/l Strontium as Sr mg/ℓ ------0.168 0.206 0.108 0.151 0.105 0.109 0.363 0.416 0.142 0.258 0.223 0.154 0.184 --- (Dissolved) mg/l Thallium as Tl mg/ℓ ------<0.025 <0.025 <0.025 <0.025 <0.025 <0.025 0.214 0.332 <0.025 <0.025 <0.025 <0.025 <0.025 --- (Dissolved) mg/l Thorium as Th mg/ℓ ------<0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 0.002 <0.001 <0.001 <0.001 <0.001 <0.001 --- (Dissolved) mg/l Tin as Sn mg/ℓ ------<0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 --- (Dissolved) mg/l Titanium as Ti mg/ℓ ------<0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 --- (Dissolved) mg/l Tungsten as W mg/ℓ ------<0.001 <0.001 <0.001 <0.001 0.003 0.004 <0.001 0.001 0.001 <0.001 <0.001 <0.001 <0.001 --- (Dissolved) mg/l Uranium as U mg/ℓ ------0.005 0.007 0.002 0.001 <0.001 0.004 0.281 0.43 0.004 0.005 0.004 0.001 <0.001 --- (Dissolved) mg/l Vanadium as V mg/ℓ ------<0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 --- (Dissolved) mg/l Zinc as Zn mg/ℓ ------<0.025 <0.025 0.09 0.153 0.032 <0.025 1.45 2.33 <0.025 0.052 <0.025 0.029 0.184 --- (Dissolved) mg/l Zirconium as Zr mg/ℓ ------<0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 --- (Dissolved) mg/l

9.7.4 Floodlines

According to Regulation 4 of GN R704, no person in control of a mine or activity may:

❖ Locate or place any residue deposit, dam, reservoir, together with any associated structure or any other facility within the 1:100 year floodline or within a horizontal distance of 100 metres from any watercourse or estuary, borehole or well, excluding boreholes or wells drilled specifically to monitor the pollution of groundwater, or on water-logged ground, or on ground likely to become water-logged, undermined, unstable or cracked; and ❖ Carry on any underground or opencast mining or prospecting or any other operation or activity under or within the 1:50 year floodline or within a horizontal distance of 100 m from any watercourse or estuary, whichever is the greatest.

The purpose of this section is to determine 1:50 and 1:100 year floodlines, as well as the 100 m buffer of watercourses, to ensure that the proposed project is compliant with GN R704 Regulations. It should be noted that the dumps were established prior to GN R704 and may be located within the floodlines or 100 m buffer of watercourses.

The 1:50 and 1:100 year floodlines and 100 m stream buffer are indicated on Figure 9-28. The proposed pipeline crosses a stream directly north-east of dump 4L4.

Figure 9-28: Floodline determination and 100 m stream buffer

9.8 Groundwater 9.8.1 Conceptual Hydrogeological Model

Groundwater occurrence in the Witwatersrand rocks is generally associated with zones of deep weathering, or faulting and jointing. Groundwater is often encountered in both the saturated weathered material below the regional groundwater rest level and in the transition zone between weathered and fresh formations. The depth of weathering for the City Deep area is generally between 20 m and 30 m deep.

According to Barnard (2000) various aquifer types are found in the area i.e. fractured aquifers and intergranular and fractured aquifers:

❖ Weathered and fractured aquifers: The Klipriviersberg Group and Vryheid Formation present aquifers that have a combination of loose unconsolidated/ weathered material and hard rock formations, in which fractures, fissures or joints potentially hold water. ❖ Fractured aquifers: The Turffontein Subgroup and Black Reef quartzite are hard rock aquifers where water is stored and moves through fractures, fissures and joints.

Most fault and joint zones in the deeper fractured aquifers are steeply dipping structures that tend to narrow and even pinch out at depth, with a corresponding decrease in permeability. The porosity is usually less than 1% while the fresh rock may be regarded as impermeable.

The Central Rand Group’s fractured aquifers produce moderate borehole yields with most boreholes obtaining a yield of 2 L/s or less (Barnard, 2000). The hydraulic parameters obtained during previous aquifer tests indicate characteristics of low permeability, where groundwater movement at depth is controlled by limited discontinuous fractures in the quartzite/conglomerate bedrock. Water bearing zones can be associated with:

❖ the tailings material and hard rock contact zone; ❖ the sandstone/shale and quartz contact; and ❖ fractures (possible faults) within the sandstone/shale and quartzite.

Groundwater strikes are generally between 10 m and 40 m below surface and associated with the base of the weathered material, or with fractures and joints in the shallow weathered and fractured aquifers.

Static groundwater levels vary between 5 m and 20 m below ground level. The aquifers underlying the study area can be classified as confined aquifers because the rest groundwater levels are located higher inside the borehole compared to the water strike depths. A study by Digby Wells Environmental in 2011 indicates groundwater levels of 9 to 16 metres below ground level (mgbl) at the City Deep Plant area, to 5 metres below surface at the tailings facilities to the north of the study area. There are no boreholes close to the local stream and the interaction between surface and groundwater resources could not be confirmed.

Literature studies suggest that groundwater drains radially from a TSF due to the impact of artificial recharge from the TSF, to the underlying aquifers.

Groundwater movement often mimics the topography and in the City Deep area it will generally flow towards the south. The primary flow of groundwater and the migration of contamination in the shallow weathered aquifer is predominantly horizontally.

Groundwater level and quality data are not available for the project site – dumps 4L3, 4L4 or 4L6.

9.8.2 Hydrocensus

In 2011 Digby Wells Environmental drilled five groundwater exploration / monitoring boreholes at the 3L40, 3L42 and 4L2 tailings facilities. Ergo1 and Ergo2 are located approximately 3 km west of the current study area, adjacent to the City Deep Plant. Ergo3, Ergo4 and Ergo5 are located approximately 1,5 km north of the current study area. The 2011 groundwater study found that borehole yields are typically below 1 L/s. Water strikes are associated with the shallow weathered and fractured aquifer. Table 9-16 is a summary of the borehole information.

Table 9-16: 2009 Borehole drilling data Latitude Borehole Longitude Depth (m) Water level (m bgl) Yield (L/s) (WGS84) Ergo1 S 26.36877 E 28.30023 50 9.48 0.70 Ergo2 S 26.36993 E 28.29843 50 15.82 0.83 Ergo3 S 26.36085 E 28.28828 50 None Dry Ergo4 S 26.36212 E 28.30193 50 5.21 0.70 Ergo5 S 26.36212 E 28.30193 50 None Dry

Aquifer tests were conducted on three boreholes in 2011. Transmissivity values vary between 0.23 m2/day and 5.03 m2/d, which indicate a low-yielding aquifer system. High yielding boreholes are not expected in the area due to historical dewatering of the underground mine workings in the area.

Based on information on the TCTA website, the water level in the Central Basin is maintained at 113 m below ground level, but still 13 m above the Environmental Critical Level at 126 m below ground level.

9.8.3 Groundwater Quality

Contaminants of concern that typically occur at gold tailings facilities include:

❖ Low pH; ❖ Total Dissolved Solids (TDS) higher than 1 200 mg/L;

❖ Sulphate (SO4) higher than 600 mg/L; and ❖ High metal concentrations, especially Iron (Fe), Manganese (Mn), Arsenic (As) and Cyanide (CN).

The groundwater in the area is usually dominated by SO4, calcium (Ca) and magnesium (Mg) and could indicate impacts by mining activities. The City Deep area is an industrial area and many pollution sources

do exist that can contribute to groundwater contamination. It will be difficult to pinpoint the source unless very detailed assessments are undertaken at each facility in the City Deep area

A gold TSF can potentially add SO4, chloride (Cl), Ca, Mg, Mn and aluminium (Al) to the local groundwater system if the management of contaminated water on site is not effective, but also through seepage from the TSF. Metals like cobalt (Co), copper (Cu), nickel (Ni) and zinc (Zn) can also be elevated. In general, SO4 concentrations around a tailings complex vary between 20 and 2 500 mg/L. Table 9-17 presents results of the 2011 Digby Wells study. It presents only the parameters where exceedances were measured.

The Turffontein Subgroup shale is made up of quartz, chlorite and mica and is enriched in Fe, Mg and Mn. Low pH water (acidic conditions) results in elevated concentrations of heavy and trace metals in water.

The pyrite present in the tailings and sand material is oxidised in the presence of oxygen and water to form ferrous SO4 and sulphuric acid (H2SO4). Both reactions result in an acidic pH, and high SO4 and metal concentrations (AMD) are often measured in leachate from tailings. The rate at which pyrite oxidation takes place within the TSF varies and decreases with depth. The addition of lime during the gold recovery process raises the pH to neutral conditions when tailings are deposited on the facilities (Digby Wells, 2009).

Groundwater quality (Table 9-17) in both the shallow and deeper aquifers would have been impacted by the three TSF facilities. Although As and uranium (U) are not expected to leach at significant concentrations, they are generally perceived to be contaminants of concerns at gold mines and TSFs. A study by MINTEK in 2016, on several TSF dumps in the Witwatersrand gold mining zone indicate that the tailings samples from the East Rand and Central Gauteng regions contained the lowest uranium concentrations (generally not requiring uranium removal prior to relocation).

Table 9-17: Local groundwater qualities - 2011 SANS 241 limits (Concentrations as Ergo1 Ergo2 Ergo4 mg/L) Total Dissolved 1,200 1,975.0 3,397.0 4,662.0 Solids Sulphate 500 1,311.0 2,437.0 3,743.0 Calcium DWS limits - 32 126.15 348.0 396.0 Magnesium DWS limits - 70 299.0 286.0 387.0 Iron 2.0 0.005 1.27 509.0 Manganese 0.4 1.35 76.5 131.0 Conductivity at 170 236.60 334.00 570.0 25° C in mS/m pH-Value at 25° C ≥5 - ≤9.7 7.32 4.85 3.79 Aluminium 0.3 0.005 6.44 255.0 Free and Saline 1.5 0.63 1.89 0.94 Ammonia as N Fluoride 1.5 0.09 1.68 0.09

9.8.4 Aquifer Characterisation

Aquifer characterisation is done based on the information presented thus far, and guidelines and maps provided by the DWS. This system was created as it allows the grouping of aquifer areas into types according to their associated supply potential, water quality and local importance as a resource.

All aquifers in the study area are classified as minor aquifer systems according to the South African aquifer system management classification. The groundwater is therefore of limited quantity, but potentially important for local water supply and base flow for rivers.

9.8.4.1 Groundwater Vulnerability

Groundwater vulnerability indicates the tendency or likelihood for contamination to reach a specified position in the groundwater system after introduction at some location above the uppermost aquifer. Based on the aquifer vulnerability map published by the DWS in July 2013 the Witwatersrand and Ventersdorp formations are classified as less vulnerable.

9.8.4.2 Aquifer Classification

Based on the aquifer classification map published by the DWS in August 2012 the Witwatersrand and Ventersdorp systems are classified as minor aquifers.

9.8.4.3 Aquifer Susceptibility

Aquifer susceptibility is a qualitative measure of the relative ease with which a groundwater body can potentially be contaminated by anthropogenic activities and includes both aquifer vulnerability and the relative importance of the aquifer in terms of its classification. Based on the classification above the Witwatersrand and Ventersdorp formations have a low susceptibility to contamination.

9.9 Air Quality 9.9.1 Health Effects of Particle Pollutants

There are an increasing number of research studies highlighting the impact of gases and air pollutants on humans. Many of these emissions, even in small quantities, have adverse effects on workers and neighbouring residents alike.

Particles (PM) can be classified by their aerodynamic properties into coarse particles, PM10 and fine particles, PM2.5 (Harrison & Van Grieken, 1998). The fine particles contain the secondarily formed aerosols such as sulphates and nitrates, combustion particles and re-condensed organic and metal vapours. The coarse particles contain earth crust materials and fugitive dust from roads and industries (Fenger, 2002). It is the amount of fine dust and the chemical and mineralogical composition of the dust which will dictate the potential for health impacts (Schwegler, 2006).

Particle size is important for health because it controls where in the respiratory system a given particle is deposited. Fine particles are thought to be more damaging to human health than coarse particles, as they

can penetrate deeper into the lungs (Manahan, 1991). Larger particles are deposited into the extrathoracic part of the respiratory tract while smaller particles are deposited into the smaller airways leading to the respiratory bronchioles (WHO, 2000).

In terms of health effects, particulate air pollution is associated with respiratory and cardiovascular morbidity, such as aggravation of asthma, respiratory symptoms and an increase in hospital admissions. Inhalable PM also leads to increased mortality from cardiovascular and respiratory diseases and from lung cancer (WHO, 2013). A study was undertaken to investigate the association between proximity to mine dumps and prevalence of chronic respiratory disease in people aged 55 years and older (Nkosi, Wichmann, & Voyi, 2015). Elderly people in communities 1-2 km (exposed) and ≥5 km (unexposed), from five mine dumps in Gauteng and North West Province, in South Africa were included in a cross-sectional study. The results showed that exposed elderly people had a significantly higher prevalence of chronic respiratory symptoms and diseases than those who were unexposed.

In the past, daily particulate concentrations were in the range 100 to 1 000µg/m3 whereas in more recent times, daily concentrations are between 10 and 100µg/m3. However, it has been found that overall, exposure-response can be described as curvilinear, with small absolute changes in exposure at the low end of the curve having similar effects on mortality to large absolute changes at the high end (WHO, 2000). Both short-term and long-term exposure to particulate matter in the air can have health impacts (Table 9-18).

Table 9-18: Short-term and long-term health effects associated with exposure to PM (WHO, 2004).

Pollutant Short-term exposure Long-term exposure

Particulate • Lung inflammatory reactions • Increase in lower respiratory symptoms matter • Respiratory symptoms • Reduction in lung function in children • Adverse effects on the cardiovascular • Increase in chronic obstructive system pulmonary disease • Increase in medication usage • Reduction in lung function in adults • Increase in hospital admissions • Reduction in life expectancy • Increase in mortality • Reduction in lung function development

9.9.1.1 Short-term Exposure

There is good evidence that short-term exposure to particulate matter is associated with health effects (WHO, 2013). Health effects associated with short-term exposure to particulates include increases in lower respiratory symptoms, medication use and small reductions in lung function. Susceptible groups with pre-existing lung or heart disease, as well as elderly people and children, are particularly vulnerable. Exposure to particulate matter affects lung development in children, including reversible deficits in lung function as well as chronically reduced lung growth rate and a deficit in long-term lung function (WHO, 2011). There is no evidence of a safe level of exposure or a threshold below which no adverse health effects occur (WHO, 2013).

9.9.1.2 Long-term Exposure

Long-term exposure to low concentrations (~10µg/m3) of particulates is associated with mortality and other chronic effects such as increased rates of bronchitis and reduced lung function (WHO, 2000). Studies have indicated an association between lung function, chronic respiratory disease and airborne particles. Relative risk estimates suggest an 11% increase in cough and bronchitis rates for each 10µg/m3 increase in annual average particulate concentrations (WHO, 2000). Based on studies conducted in the USA, 3 Europe and Canada, mortality is estimated to increase by 0.2–0.6% per 10 μg/m of PM10 (WHO, 2005;

Samoli, et al., 2008). PM2.5 is a higher risk factor than the coarse part of PM10 (particles in the 2.5–10 μm range), especially as a consequence of long-term exposure. Long-term exposure to PM2.5 is associated with 3 an increase in the long-term risk of cardiopulmonary mortality by 6–13% per 10 μg/m of PM2.5 (Beelen, et al., 2008; Krewski, et al., 2009; Pope III, et al., 2002).

9.9.2 Background PM Concentrations

The graph (compiled on the South African Air Quality Information System (SAAQIS) website) of the measured PM10 ambient concentrations in Germiston, near the City Deep site, illustrates the high ambient concentrations of PM10 in in the area, with exceedances of the National Ambient Air Quality Standards (NAAQS) (Figure 9-29).

The dumps are also located immediately adjacent to the Highveld Priority Area (HPA) for air quality. The Minister declared the HPA on 23 November 2007 as the second National Priority Area (Government Notice No. 1123, 2007). Despite this, the Highveld area in South Africa is generally associated with poor air quality. These elevated concentrations of criteria pollutants occur due to the concentration of industrial and nonindustrial sources (Held, 1996; DEAT, 2006).

Figure 9-29: Daily average PM10 concentrations for Germiston (SAAQIS, 2018).

9.9.3 Dispersion Modelling

An emissions inventory lists all sources that would generate pollutants of concern.

❖ Construction activities: Construction of buildings and roads is a source of dust emissions that may have a substantial temporary impact on local air quality. However, it is expected that there will be minimal construction activities associated with the reclamation process. Basic infrastructure will be of a temporary nature e.g. mobile change houses and mobile offices. Furthermore, pump stations and holding dams are already established. The pipelines which will need to be constructed will join into existing pipelines to and from the Ergo Plant. Emissions to the air from the laying of the pipelines are likely to be of relatively short duration and are deemed to be of low significance. Furthermore, dust emissions may vary substantially from day to day, depending on the level of activity, the specific operations, and the prevailing meteorological conditions. Information on the time scale and activities related to laying the pipelines was not available. ❖ Vehicle emissions: Although vehicles at the reclamation sites would emit gases, the impact of these compounds were not included in this assessment. The sulphur content of South African TM diesel is too low (0.05% for Sasol Turbodiesel ) to cause sulphur dioxide (SO2) levels to be exceeded. Suspension of particulate matter caused by vehicles moving across parts of the tailings site is also a source of emissions. Although instantaneous emissions may be significant, it was deemed that the total emissions from this source will be insignificant when averaged over 24 hours. ❖ Tailings emissions: Mine tailings are made up of fine particles generated by the grinding and processing of ore. These fine, dry particles can be a source of serious dust problems on windy

days, sometimes to the extent that residents living close to tailings in Gauteng take refuge in their homes (Schwegler, 2006). Low levels of organic matter and available nutrients, and unfavorable texture and structure are limitations to revegetation of most tailings (Hossner & Hons, 1992). Aerial images show that the three City Deep dumps are sparsely vegetated, particularly some areas on the top of 4L6 and the northern side of 4L3. Dust emissions due to the erosion of exposed areas occur when the threshold wind speed is exceeded (Cowherd, Muleski, & Kinsey, 1988; US EPA, 1995).

Dispersion simulations were undertaken to determine ambient concentrations of PM2.5 and PM10 as well as deposition of TSP resulting from the City Deep dumps. A scenario illustrating current, undisturbed emissions; four scenarios illustrating worst-case conditions (i.e. the initiation of reclamation along one of the sides of the dumps close to receptors); and a scenario illustrating conditions once the mining is complete and bare ‘red earth’ soil is exposed, were modelled. The position of the modelled cuts is shown in Figure 9-30. The dumps were simulated as raised area sources. The dispersion of particulate matter was modelled up to 10 km from the site.

Figure 9-30: Position of the modelled cut areas and the position of modelled discrete receptors.

Levels of dustfall were raised as a concern for the project. Eight areas were identified as possible areas of concern for dust deposition and were then modelled as discrete receptors. The position of the eight

receptors is shown in Figure 9-29. The results of the modelling (Table 9-19) indicate that dustfall caused by the City Deep dump reclamation process, for the most part, does not approach the national dustfall regulation of between 600 and 1 200 mg/m2/day for non-residential areas nor the 600 mg/m2/day limit for residential areas, averaged over a month. Only dustfall from mining on the west side of 4L3 produces monthly exceedances of the non-residential limit at Receptor 2 and this was only for two months (May and July of 2015) in the three-year period modelled. It should be noted that this does not show the cumulative dustfall from all sources in the area, but it does include emissions from the remainder of 4L3, which was modelled as undisturbed. The modelling does also show that an improvement should be noticeable once the reclamation process is completed.

Table 9-19: Dustfall rates predicted by the modelling for discrete receptors. Dustfall Rate (mg/m2/day) (Derived from the maximum 30-day average for each modelling run) Mining 4L3 Denuded Mining on Mining 4L3 in a stretch land after Mining 4L4 Mining 4L6 Receptor Undisturbed 4L3 along along the from north all tailings along the along the Number Tailings the west north-west to south material south side south side side side across the has been centre removed 1 380 383 497 401 380 384 5 2 404 627 398 408 404 406 6 3 63 67 64 65 64 65 3 4 81 82 82 84 82 83 4 5 41 42 42 42 42 52 3 6 76 76 76 76 76 206 3 7 65 65 65 65 65 92 3 8 209 209 209 209 209 218 3

The isopleths of the modelling results for PM2.5 and PM10 are given in Figure 9-31 to Figure 9-66 below. All areas within the red coloured isopleth in Figure 9-31 to Figure 9-66 can be expected to experience exceedances of the relevant National Standards. Isopleths higher than the National Standards have not been included in these figures. It should be noted that the colour scale of the isopleths in Figure 9-67 and Figure 9-68 are not based on the National Standards being represented by a red isopleth, as concentrations are too low to show on this scale.

It should be noted that isopleth plots reflecting the 24-hour averaging periods contain the average of the fifth-highest predicted ground level concentrations, over the three-year period for which simulations were undertaken. In other words, the model calculates the fifth-highest concentration at each receptor for each year modelled, averages those fifth-highest concentrations at each receptor across the three years of meteorological data, and then selects the highest across all receptors, of the three-year averaged fifth-highest values for plotting. This is in line with the NAAQS which allows for four exceedances per year. Concentrations are presented in µg/m3.

9.9.4 Evaluation of the Status Quo Modelling Results

PM2.5

❖ PM2.5 (24-hour Average Concentrations) – While the City Deep dumps are undisturbed, the predicted worst-case maximum daily average concentrations, caused by emissions from the dumps, do not exceed the current national daily standard of 40µg/m3.

❖ PM2.5 (Annual Average Concentrations) – While the City Deep dumps are undisturbed, the predicted maximum annual average concentrations, caused by emissions from the dumps, do not exceed the national standard of 20µg/m3.

PM10

❖ PM10 (24-hour Average Concentrations) – While the City Deep dumps are undisturbed, the predicted worst-case maximum daily average concentrations, caused by emissions from the dumps, do not exceed the national daily standard of 75µg/m3 beyond the property boundaries.

❖ PM10 (Annual Average Concentrations) – While the City Deep dumps are undisturbed, the predicted maximum annual average concentrations, caused by emissions from the dumps, do not exceed the national annual average standard of 40µg/m3.

Figure 9-31: Modelled prediction of the status quo maximum 24-hour average PM2.5 concentrations, resulting Figure 9-32: Modelled prediction of the status quo annual average PM2.5 concentrations resulting from the City from the City Deep dumps. Deep dumps.

Figure 9-33: Modelled prediction of the status quo maximum 24-hour average PM10 concentrations resulting from Figure 9-34: Modelled prediction of the status quo annual average PM10 concentrations resulting from the City the City Deep dumps. Deep dumps.

9.9.5 Evaluation of the 4L3 North Cut Modelling Results

PM2.5

❖ PM2.5 (24-hour Average Concentrations) – The predicted worst-case maximum daily average concentrations resulting from mining of the City Deep 4L3 north cut do not exceed the current national daily standard of 40µg/m3.

❖ PM2.5 (Annual Average Concentrations) – The predicted maximum annual average concentrations resulting from mining of the City Deep 4L3 north cut do not exceed the national standard of 20µg/m3.

PM10

❖ PM10 (24-hour Average Concentrations) – The predicted worst-case maximum daily average concentrations resulting from mining of the City Deep 4L3 north cut exceed the national daily standard of 75µg/m3 up to approximately 420 m over the industrial area to the north, north-west and west of the dump.

❖ PM10 (Annual Average Concentrations) – The predicted maximum annual average concentrations resulting from mining of the City Deep 4L3 north cut exceed the national annual average standard of 40µg/m3 up to approximately 140 m over the industrial area to the north of the dump.

PM10 Mitigated

❖ PM10 (24-hour Average Concentrations) – The predicted worst-case maximum daily average concentrations resulting from mining of the City Deep 4L3 north cut, with wet suppression of the graded 15-metre-wide band, exceed the national daily standard of 75µg/m3 up to approximately 220 m over the industrial area to the north, north-west and west.

❖ PM10 (Annual Average Concentrations) – The predicted maximum annual average concentrations resulting from mining of the City Deep 4L3 north cut, with wet suppression of the graded 15- metre-wide band, do not exceed the national annual average standard of 40µg/m3.

Figure 9-35: Modelled prediction of the maximum 24-hour average PM2.5 concentrations, resulting from the Figure 9-36: Modelled prediction of the maximum 24-hour average PM2.5 concentrations, resulting from the mining of the north cut of City Deep 4L3. mining of the north cut of City Deep 4L3 with wet suppression of the graded 15-metre-wide band.

Figure 9-37: Modelled prediction of the annual average PM2.5 concentrations resulting from the mining of the Figure 9-38: : Modelled prediction of the annual average PM2.5 concentrations resulting from the mining of the north cut of City Deep 4L3. north cut of City Deep 4L3 with wet suppression of the graded 15-metre-wide band.

Figure 9-39: Modelled prediction of the maximum 24-hour average PM10 concentrations resulting from the Figure 9-40: Modelled prediction of the maximum 24-hour average PM10 concentrations resulting from the mining of the north cut of City Deep 4L3. mining of the north cut of City Deep 4L3 with wet suppression of the graded 15-metre-wide band.

Figure 9-41: Modelled prediction of the annual average PM10 concentrations resulting from the mining of the Figure 9-42: : Modelled prediction of the annual average PM10 concentrations resulting from the mining of the north cut of City Deep 4L3. north cut of City Deep 4L3 with wet suppression of the graded 15-metre-wide band

9.9.6 Evaluation of the 4L3 West Cut Modelling Results

PM2.5

❖ PM2.5 (24-hour Average Concentrations) – The predicted worst-case maximum daily average concentrations resulting from mining of the City Deep 4L3 west cut do not exceed the current national daily standard of 40µg/m3.

❖ PM2.5 (Annual Average Concentrations) – The predicted maximum annual average concentrations resulting from mining of the City Deep 4L3 west cut do not exceed the national standard of 20µg/m3.

PM10

❖ PM10 (24-hour Average Concentrations) – The predicted worst-case maximum daily average concentrations resulting from mining of the City Deep 4L3 west cut exceed the national daily standard of 75µg/m3 up to approximately 490 m over the industrial area to the west.

❖ PM10 (Annual Average Concentrations) – The predicted maximum annual average concentrations resulting from mining of the City Deep 4L3 west cut exceed the national annual average standard of 40µg/m3 up to approximately 120 m to the west of the dump.

PM10 Mitigated

❖ PM10 (24-hour Average Concentrations) – The predicted worst-case maximum daily average concentrations resulting from mining of the City Deep 4L3 west cut, with wet suppression of the graded 15-metre-wide band, exceed the national daily standard of 75µg/m3 up to approximately 150 m over the industrial area to the west.

❖ PM10 (Annual Average Concentrations) – The predicted maximum annual average concentrations resulting from mining of the City Deep 4L3 west cut, with wet suppression of the graded 15-metre- wide band, do not exceed the national annual average standard of 40µg/m3.

Figure 9-43: Modelled prediction of the maximum 24-hour average PM2.5 concentrations, resulting from the Figure 9-44: Modelled prediction of the maximum 24-hour average PM2.5 concentrations, resulting from the mining of the west cut of City Deep 4L3. mining of the west cut of City Deep 4L3 with wet suppression of the graded 15-metre-wide band.

Figure 9-45: Modelled prediction of the annual average PM2.5 concentrations resulting from the mining of the Figure 9-46: Modelled prediction of the annual average PM2.5 concentrations resulting from the mining of the west cut of City Deep 4L3. west cut of City Deep 4L3 with wet suppression of the graded 15-metre-wide band.

Figure 9-47: Modelled prediction of the maximum 24-hour average PM10 concentrations resulting from the Figure 9-48: Modelled prediction of the maximum 24-hour average PM10 concentrations resulting from the mining of the west cut of City Deep 4L3. mining of the west cut of City Deep 4L3 with wet suppression of the graded 15-metre-wide band.

Figure 9-49: Modelled prediction of the annual average PM10 concentrations resulting from the mining of the Figure 9-50: Modelled prediction of the annual average PM10 concentrations resulting from the mining of the west cut of City Deep 4L3. west cut of City Deep 4L3 with wet suppression of the graded 15-metre-wide band.

9.9.7 Evaluation of the 4L4 South Cut Modelling Results

PM2.5

❖ PM2.5 (24-hour Average Concentrations) – The predicted worst-case maximum daily average concentrations resulting from mining of the City Deep 4L4 south cut do not exceed the current national daily standard of 40µg/m3.

❖ PM2.5 (Annual Average Concentrations) – The predicted maximum annual average concentrations resulting from mining of the City Deep 4L4 south cut do not exceed the national standard of 20µg/m3.

PM10

❖ PM10 (24-hour Average Concentrations) – The predicted worst-case maximum daily average concentrations resulting from mining of the City Deep 4L4 south cut exceed the national daily standard of 75µg/m3 up to approximately 70 m over the industrial area to the west. Although exceedances of the standard do stretch beyond the property boundaries to the south-west of the dump, these exceedances are over roads and unused land.

❖ PM10 (Annual Average Concentrations) – The predicted maximum annual average concentrations resulting from mining of the City Deep 4L4 south cut do not exceed the national annual average standard of 40µg/m3.

PM10 Mitigated

❖ PM10 (24-hour Average Concentrations) – The predicted worst-case maximum daily average concentrations resulting from mining of the City Deep 4L4 south cut, with wet suppression of the graded 15-metre-wide band, only exceed the national daily standard of 75µg/m3 within the property boundaries.

❖ PM10 (Annual Average Concentrations) – The predicted maximum annual average concentrations resulting from mining of the City Deep 4L4 south cut, with wet suppression of the graded 15- metre-wide band, do not exceed the national annual average standard of 40µg/m3.

Figure 9-51: Modelled prediction of the maximum 24-hour average PM2.5 concentrations, resulting from the Figure 9-52: Modelled prediction of the maximum 24-hour average PM2.5 concentrations, resulting from the mining of the south cut of City Deep 4L4. mining of the south cut of City Deep 4L4 with wet suppression of the graded 15-metre-wide band.

Figure 9-53: Modelled prediction of the annual average PM2.5 concentrations resulting from the mining of the Figure 9-54: Modelled prediction of the annual average PM2.5 concentrations resulting from the mining of the south cut of City Deep 4L4. south cut of City Deep 4L4 with wet suppression of the graded 15-metre-wide band.

Figure 9-55: Modelled prediction of the maximum 24-hour average PM10 concentrations resulting from the Figure 9-56: Modelled prediction of the maximum 24-hour average PM10 concentrations resulting from the mining of the south cut of City Deep 4L4. mining of the south cut of City Deep 4L4 with wet suppression of the graded 15-metre-wide band.

Figure 9-57: Modelled prediction of the annual average PM10 concentrations resulting from the mining of the Figure 9-58: Modelled prediction of the annual average PM10 concentrations resulting from the mining of the south cut of City Deep 4L4. south cut of City Deep 4L4 with wet suppression of the graded 15-metre-wide band.

9.9.8 Evaluation of the 4L6 South Cut Modelling Results

PM2.5

❖ PM2.5 (24-hour Average Concentrations) – The predicted worst-case maximum daily average concentrations resulting from mining of the City Deep 4L6 south cut do not exceed the current national daily standard of 40µg/m3.

❖ PM2.5 (Annual Average Concentrations) – The predicted maximum annual average concentrations resulting from mining of the City Deep 4L6 south cut do not exceed the national standard of 20µg/m3.

PM10

❖ PM10 (24-hour Average Concentrations) – The predicted worst-case maximum daily average concentrations resulting from mining of the City Deep 4L6 south cut exceed the national daily standard of 75µg/m3 up to approximately 630 m over the industrial area to the north, 490 m over the industrial area to the west and 850 m over the residential area to the south-west. This is a health risk for the people living in this area.

❖ PM10 (Annual Average Concentrations) – The predicted maximum annual average concentrations resulting from mining of the City Deep 4L6 south cut only exceed the national annual average standard of 40µg/m3 up to approximately 100 m to the south and west of the dump, and only over land used for storage and unused land.

PM10 Mitigated

❖ PM10 (24-hour Average Concentrations) – The predicted worst-case maximum daily average concentrations resulting from mining of the City Deep 4L6 south cut, with wet suppression of the graded 15-metre-wide band, only exceed the national daily standard of 75µg/m3 up to approximately 100 m to the west and south of the dump, and only over land used for storage and unused land.

❖ PM10 (Annual Average Concentrations) – The predicted maximum annual average concentrations resulting from mining of the City Deep 4L6 south cut, with wet suppression of the graded 15- metre-wide band, do not exceed the national annual average standard of 40µg/m3.

Figure 9-59: Modelled prediction of the maximum 24-hour average PM2.5 concentrations, resulting from the Figure 9-60: Modelled prediction of the maximum 24-hour average PM2.5 concentrations, resulting from the mining of the south cut of City Deep 4L6. mining of the south cut of City Deep 4L6 with wet suppression of the graded 15-metre-wide band.

Figure 9-61: Modelled prediction of the annual average PM2.5 concentrations resulting from the mining of the Figure 9-62: Modelled prediction of the annual average PM2.5 concentrations resulting from the mining of the south cut of City Deep 4L6. south cut of City Deep 4L6 with wet suppression of the graded 15-metre-wide band.

Figure 9-63: Modelled prediction of the maximum 24-hour average PM10 concentrations resulting from the Figure 9-64: Modelled prediction of the maximum 24-hour average PM10 concentrations resulting from the mining of the south cut of City Deep 4L6. mining of the south cut of City Deep 4L6 with wet suppression of the graded 15-metre-wide band.

Figure 9-65: Modelled prediction of the annual average PM10 concentrations resulting from the mining of the Figure 9-66: Modelled prediction of the annual average PM10 concentrations resulting from the mining of the south cut of City Deep 4L6. south cut of City Deep 4L6 with wet suppression of the graded 15-metre-wide band.

Figure 9-67: Modelled prediction of the maximum 24-hour average PM2.5 concentrations resulting after the removal of the City Deep dumps.

Figure 9-68: Modelled prediction of the maximum 24-hour average PM10 concentrations resulting after the removal of the City Deep dumps.

Once all mining is complete, and all tailings material has been removed, leaving bare ‘red earth’, the predicted worst-case maximum daily average concentrations do not approach the national standards for

PM2.5 and PM10.

9.10 Noise

Natural sounds are a part of the environmental noise surrounding humans. Ambient sound levels are significantly affected by the area where the sound measurement location is situated. When the sound measurement location is situated within an urban area, close to industrial plants or areas with a constant sound source (ocean, rivers, etc.), seasons and even increased wind speeds have an insignificant to massive impact on ambient sound levels.

The site visit confirmed that the area has a highly commercial character, with numerous industrial activities as well as several busy transportation routes (Figure 9-69). Based on the developmental character, the acceptable noise rating level will be typical of an urban area with one or more of the following; workshops, businesses and main routes (SANS 10103: 2008 noise district). Ambient sound levels were audibly elevated and higher than one would expect for an urban noise district.

Figure 9-69: Aerial image indicating potentially noise-sensitive receptors in the vicinity of the City Deep Dumps reclamation project.

9.10.1 Potential Noise Sources

There are a number of potential noise sources associated with the Proposed Project during both the construction and operational phase.

The level and character of the construction noise will be highly variable as different activities with different equipment take place at different times, for different periods of time (operating cycles), in different combinations/sequences and on different parts of the construction site.

The potential extent and impact of construction noises depends on several factors, including the prevailing ambient sound levels during the time in which the maximum noise event occurred, as well as the spectral character of the noise and the ambient surroundings.

Maximum noise generated can be audible over a large distance. However, it is generally of very short duration. If maximum noise levels however exceed 65 Decibels (dBA) at a receptor, or if it is clearly audible with a significant number of instances where the noise level exceeds the prevailing ambient sound level with more than 15 dBA, the noise can increase annoyance levels and may ultimately result in noise complaints. Potential maximum noise levels generated by various types of construction equipment as well as the potential extent of these sounds are presented in Table 9-20.

Average or equivalent sound levels are another factor that impacts on the ambient sound levels and are the constant sound level that the receptor can experience. Typical sound power levels associated with various activities that may be found at a mining construction site are presented in Table 9-21.

The following are likely the main construction related sources:

❖ Transport of workers, components & equipment to site – brought to site by means of flatbed trucks; ❖ Digging of foundations for infrastructure and pipeline support – Tip Load Bucket (TLB); ❖ Development of stormwater infrastructure – TLB; ❖ Civil work to install the substation / transformer, screens, tanks and pump station – cement truck, flatbed trucks (with mobile crane); ❖ Civil construction activities.

Table 9-20:Potential maximum noise levels generated by construction equipment Operational Noise Level at given distance considering potential maximum noise levels Impact Maximum Sound (Cumulative as well as the mitigatory effect of potential barriers or other mitigation not included – Equipment Description9 Device? Power Levels (dBA) simple noise propagation modelling only considering distance) (dBA) 5 m 10 m 20 m 50 m 100 m 150 m 200 m 300 m 500 m 750 m 1000 m 2000 m Compactor (ground) No 114.7 89.7 83.7 77.6 69.7 63.7 60.1 57.6 54.1 49.7 46.2 43.7 37.6 Compressor (air) No 114.7 89.7 83.7 77.6 69.7 63.7 60.1 57.6 54.1 49.7 46.2 43.7 37.6 Concrete Batch Plant No 117.7 92.7 86.7 80.6 72.7 66.7 63.1 60.6 57.1 52.7 49.2 46.7 40.6 Concrete Mixer Truck No 119.7 94.7 88.7 82.6 74.7 68.7 65.1 62.6 59.1 54.7 51.2 48.7 42.6 Drum Mixer No 114.7 89.7 83.7 77.6 69.7 63.7 60.1 57.6 54.1 49.7 46.2 43.7 37.6 Dump Truck No 118.7 93.7 87.7 81.6 73.7 67.7 64.1 61.6 58.1 53.7 50.2 47.7 41.6 Excavator No 119.7 94.7 88.7 82.6 74.7 68.7 65.1 62.6 59.1 54.7 51.2 48.7 42.6 Flat Bed Truck No 118.7 93.7 87.7 81.6 73.7 67.7 64.1 61.6 58.1 53.7 50.2 47.7 41.6 Generator No 116.7 91.7 85.7 79.6 71.7 65.7 62.1 59.6 56.1 51.7 48.2 45.7 39.6 Grader No 119.7 94.7 88.7 82.6 74.7 68.7 65.1 62.6 59.1 54.7 51.2 48.7 42.6 Impact Pile Driver Yes 129.7 104.7 98.7 92.6 84.7 78.7 75.1 72.6 69.1 64.7 61.2 58.7 52.6

9 Equipment list and Sound Power Level source: http://www.fhwa.dot.gov/environment/noise/construction_noise/handbook/handbook09.cfm

Table 9-21: Potential equivalent noise levels generated by various equipment Equivalent Operational Noise Level at given distance considering equivalent (average) sound power emission levels (average) (Cumulative as well as the mitigatory effect of potential barriers or other mitigation not included – Equipment Description Sound Levels simple noise propagation modelling only considering distance) (dBA) (dBA) 5 m 10 m 20 m 50 m 100 m 150 m 200 m 300 m 500 m 750 m 1000 m 2000 m General noise 108.8 83.8 77.8 71.8 63.8 57.8 54.2 51.8 48.2 43.8 40.3 37.8 31.8 Slurry pump 109.0 84.0 78.0 72.0 64.0 58.0 54.5 52.0 48.5 44.0 40.5 38.0 32.0 Tip Load Bucket (TLB) 108.8 83.8 77.8 71.8 63.8 57.8 54.3 51.8 48.3 43.8 40.3 37.8 31.8 Vibrating screens 109.1 84.2 78.1 72.1 64.2 58.1 54.6 52.1 48.6 44.2 40.6 38.1 32.1 Water Dozer, CAT 113.8 88.8 82.8 76.8 68.8 62.8 59.3 56.8 53.3 48.8 45.3 42.8 36.8

9.10.2 Operational Noises – General

Hydraulic Mining involves the use of high-pressure water monitors (water cannons) to break up the material and turn it into slurry as it mixes with the runoff water. The slurry will be screened to remove vegetation and other material with the underflow directed to a penstock, feeding the pump station where the slurry will be delivered to a tank farm via a slurry pipeline.

The level and character of the noise during this phase is generally constant as it does not involve mobile equipment movement around the site. Potential maximum noise levels generated by various mining equipment as well as the potential extent of these sounds are presented in Table 9-20 with Table 9-21 presenting the typical sound power levels associated with various activities (or equipment).

9.10.3 Potential Noise Sources: Decommissioning Phase

The Decommissioning Phase is considered the phase which begins after the dumps were removed from the site and ends when the applicant (Ergo) receives a Closure Certificate from the DMR.

The Decommissioning Phase will include:

❖ Removal of other infrastructure no longer required (temporary buildings). ❖ The rehabilitation of disturbed areas in terms of the desired end use requirement. ❖ Application for a Closure Certificate for the site.

While there are numerous activities that may be taking place during the decommissioning stage, the potential noise impact will only be discussed in general. This is because the noise impacts associated with the decommissioning phase is normally less than both the construction and operational phases for the following reasons:

❖ Final decommissioning normally takes place only during the day, a time period when existing ambient sound levels are higher, generally masking most external noises for surrounding receptors; ❖ There is a lower urgency of completing this phase and less equipment remains onsite (and is used simultaneously) to effect the final decommissioning.

9.11 Traffic

The Proposed Project Site is located in an area with an existing road network. The site is surrounded by the N3 to the east, N17 to the south and a series of Metropolitan and street level routes.

9.11.1 Surrounding Road Network

The Road Classification and Access Management (RCAM) guideline 2010 provides for roads classification into the following six class systems:

❖ Class 1 Principal arterial

❖ Class 2 Major arterial ❖ Class 3 Minor arterial ❖ Class 4 Collector ❖ Class 5 Local street ❖ Class 6 Walkway

The first three classes (the arterials) are mobility roads, the second three classes are activity/access streets.

The following existing roads are of importance within the study area:

❖ Houer Street o Class of Road: 3 o Managing Authority: Johannesburg Roads Agency (Johannesburg Roads Agency (JRA)) o Function of Road: Provides direct access to industrial properties, including Transnet Freight Depot and Bidvest SACD, also serves as a collector for other roads. o This road bounds the site to the north and direct access to the site is proposed directly off this road. ❖ Bonsmara Road o Class of Road: 4 o Managing Authority: Johannesburg Roads Agency (JRA) o Function of Road: Provides direct access to industrial properties. o This road bounds the site to the west, but no access to the site is proposed off this road.

As per the Road Master Planning of the JRA, no future roads are planned for this area.

9.11.2 Existing Traffic Demand

The Traffic Impact Assessment discussion is limited to the access position of the site. The traffic generated by the site does not warrant traffic surveys as the distribution and influence on existing traffic and road infrastructure is very limited.

Considering the type of activities proposed, as well as the surrounding land‐uses, it is expected that the critical traffic impact of the development will be during the weekday AM and PM peak traffic hours. The impact will be less than 15 vehicles per hour (vph), even during the construction phase.

9.11.3 Future Traffic Demand

Considering the existing and future planned surrounding road network, as well as the fact that the surrounding industrial area is already mostly developed, traffic growth at the proposed access position to the site will be very limited.

9.11.4 Trip Generation

The expected trips to be generated by the proposed activities were based on trip rates as per Ergo and the Committee of Transport Officials South African Trip Data Manual (COTO TMH17). Trips are based on details provided by Ergo for the construction period:

❖ Weekday AM peak hour – 12 trips, with a 75:25 (in/out) directional split; and ❖ Weekday PM peak hour – 10 trips, with a 25:75 (in/out) directional split.

9.11.5 Proposed Access Position and Layout

One access to the site is proposed directly off Houer Street, as indicated in Figure 9-70. This proposed access to the site will be opposite the existing Bidvest SACD Access. Traffic from Houer Street will have the right of way and a ‘STOP’ condition will be implemented for the proposed access.

The City of Johannesburg Town‐Planning Scheme was consulted to determine the parking requirement for the proposed development. The number of parking bays required is not specified for mining development. The number of bays required are based on the number of employees expected to be on the site is 10.

Apart from the 10 parking bays to be provided on site, an additional 2 loading zones for heavy vehicles are required. These parking bays, in conjunction with the proposed Pick‐up and Drop‐off facility, will allow vehicles to drop‐off or pick‐up employees inside the site, ensuring safety and not disrupting the traffic.

Figure 9-70: Proposed access to site.

9.12 Visual 9.12.1 Current Status

The City Deep Dumps are in an area that is categorised by flat and gently undulating terrain, and has a topography ranging between 1 585 and 1 760m. No prominent mountains or steep hills are present on site except for the slime dams themselves. The area is dominated by man-made infrastructure (Roads, Powerlines, Business buildings and factories) and industrial activities.

Photo 9-1: View of the 4L4 dump, N from the N17. Photo 9-2: View of the 4L3 dump, NE from (Source Google Earth 2018) Heidelberg Road. (Source Google Earth 2018)

Photo 9-3: View of the 4L3 dump, S from Houer Photo 9-4: View of the 4L6 dump, W from N3. Road. (Source Google Earth 2018) (Source Google Earth 2018)

Photo 9-5: View towards 4L6 dump, NE from the Photo 9-6: View towards 4L6 dump, NW from the N17. (Source Google Earth 2018) N12. (Source Google Earth 2018)

9.12.2 Triggers and Categorisation

The proposed mining activities falls within the Category 5 development, with a Moderate visual impact expected. This translates to the proposed mine area (City Deep Dumps) potentially having significant effect and a noticeable change on the wilderness quality and scenic appearance of the immediate environment.

Table 9-22: Visual Impact Criteria results for City Deep Visual Impact Criteria Potentially significant effect on wilderness quality or scenic resources; Very high visual impact expected: Fundamental change in the visual character of the area; Establishes a major precedent for development in the area. Potential intrusion on protected landscapes or scenic resources; High visual impact expected: Noticeable change in visual character of the area; Establishes a new precedent for development in the area. Potentially some effect on protected landscapes or scenic resources; Some Moderate visual impact expected: change in the visual character of the area; Introduces new development or adds to existing development in the area Potentially low level of intrusion on landscapes or scenic resources; Minimal visual impact expected Limited change in the visual character of the area; Low-key development, similar in nature to existing development Potentially little influence on scenic resources or visual character of the Little or no visual impact expected: area; Generally compatible with existing development in the area; Possible scope for enhancement of the area.

9.12.3 Visual Analysis

This section of the report evaluated the aspects which have been considered to determine the intensity of the visual impact on the area. The criteria include the area from which the City Deep Dumps can be seen (the viewshed), the viewing distance, the capacity of the landscape to visually absorb structures and forms placed upon it (the visual absorption capacity), and the appearance of the project from important or critical viewpoints (sensitivity).

9.12.3.1 Viewshed

This viewshed analysis is carried out to define areas, which contain all possible observation sites from which the City Deep and associated surface infrastructure will be seen. The topography was determined by using a Digital Elevation Model (DEM) from 5m contours of the area.

Figure 9-71 spatially depicts the viewshed area and the areas which have direct visibility of the proposed surface infrastructure area. A single analysis viewshed of the proposed surface infrastructure was used, meaning that the figure illustrates all areas from which the surface infrastructure will be visible, incorporating vertical offset heights (height above natural terrain level) an offset height of 2m for observation points. The total area that has a direct visual connection of the footprint areas is 2 322.1 Ha (42.906%).

Figure 9-71: City Deep Surface Infrastructure Viewshed

The viewshed in Figure 9-71 indicated that City Deep and associated surface infrastructure will have a Medium-High visibility from the southeast to southwest direction of the development and a medium - low visibility to the north of the development with a few areas of high visibility on the higher elevations.

Table 9-23: Viewshed evaluation for City Deep results Viewshed Evaluation Criteria High >50% of zone of influence is visible Moderate 25-50% of zone of influence is visible Low < 25 % of zone of influence is visible

The visibility of the infrastructure is categorised as moderate due to the visibility covering 42.906% (2 322.1 Ha). After proposed reclamation occurs the viewshed will drop significantly as the project moves back to red earth and the slime dumps are completely reclaimed.

9.12.3.2 Viewing Distance

It is established that the visual impact of an object in the landscape diminishes at an exponential rate as the distance between the observer and the object increases. (Hull and Bishop, 1988).

For this site (City Deep) a potential zone of influence (ZOI) (the area defined as the radius about the centre point of the project beyond which the visual impact of the most visible features will be insignificant) was determined at 3km. Over 3km the impact of the proposed infrastructure would have diminished considerably due to the built up and industrial nature of the area.

From the viewshed map above, there are sensitive receptors (residents, industrial areas and motorists) located within 0 – 1.5km range with a good mixture of the entire spectrum of visual exposure.

Table 9-24: Viewing Distance of Receptors Viewing Distance Sensitivity

High Viewing distance that is between 0- 2km of the proposed development area

Moderate Viewing distance that is between 2-5km of the proposed development area

Low Viewing distance that is 5km -10km of the proposed development area

9.12.3.3 Sensitive Receptors

The site is in the midst of an industrial suburb of the CoJ, it has industrial activities located towards the north, east and west. Residential housing is located towards the south of the site. The M31 and the N17 are located towards the south of the site, and the N3 is located towards the east, these roads carry a high number of commuters on a daily basis.

Residents, workers in the industrial areas and motorists are of a high visual exposure (based on the viewshed analysis). As the proposed project advances and the removal of the dumps takes place and the area is restored to red earth, the project will have resulted in a positive visual impact by removing a visual intrusion (Slime dumps). The proposed site already has a dense visual screen due to historic mining in the area and the proposed project will minimise the visual intrusion as the project progresses.

Table 9-25: Sensitive Viewers within 0-2km of proposed surface infrastructure Viewing Distance from Surface Farm Sensitive Viewer distance Infrastructure sensitivity Rosherville 309 IR Portion 4 Industrial plant 0.13 km Low Elandsfontein 107 IR Portion 36 Industrial plant 0.18 km Low Doornfontein 80 IR Industrial plant 0.23 km Low Elandsfontein 107 IR Portion 78 Industrial plant 0.28 km Low Elandsfontein 107 IR Portion 40 Residential housing 0.28 km High Klipriviersberg 106 IR Portion 185 Industrial plant 0.29 km Low Klipriviersberg 106 IR Portion 184 Industrial plant 0.35 km Low Elandsfontein 108 IR Portion 588 Industrial plant 0.37 km Low Doornfontein 92 IR Portion 760 Industrial plant 0.45 km Low Doornfontein 92 IR Portion 762 Industrial plant 0.48 km Low Klipriviersberg 106 IR Portion 74 Residential housing 0.52 km High

Viewing Distance from Surface Farm Sensitive Viewer distance Infrastructure sensitivity Rosherville 309 IR Portion 7 Industrial plant 0.53 km Low Klipriviersberg 106 IR Portion 75 Residential housing 0.70 km High Elandsfontein 108 IR Portion 445 Industrial plant 0.76 km Low Elandsfontein 108 IR Portion 443 Industrial plant 0.93 km Low Klipriviersberg 106 IR Portion 191 Residential housing 1.03 km High Elandsfontein 108 IR Portion 97 Industrial plant 1.04 km Low Klipriviersberg 106 IR Portion 91 Residential housing 1.35 km High Motorists on Houer Road 0.07 km Medium Motorists on the N3 0.26 km Medium Motorists on Heidelberg Rd 0.30 km Medium Motorists on the M2 W 0.37 km Medium Motorists on the N17 0.40 km Medium

9.12.3.4 Viewpoints

Several critical viewpoints were identified towards the project area (City Deep) to illustrate how the surface infrastructure would have an impact on sensitive viewers (Photo 9-7 to Photo 9-9). The most critical viewers were identified as residents. Industrial plant workers and motorist travelling on the N17, N3, Heidelberg Rd and Houer Road where identified as the least critical viewers within 2 km of the proposed development areas.

Table-9-26: Sensitivity of the receptors for the proposed City Deep Sensitivity of Receptors for the proposed City Deep Moderate (People Low (People at work, motorists engaged in sport or High (Residents, travelling on the R50 and recreation so views are Heritage Sites) people who are focused on not focused on other activities) landscape) Motorist on N17, N3, M2 W, Proposed City Deep and Residents of the nearby Heidelberg Rd and Houer Road Surface infrastructure residential areas Industrial plant workers

Proposed City Deep (4L4) A Surface Infrastructure

House

0.54 km NW

Photo 9-7: Residential House 0.54 km looking north west towards the proposed Surface Infrastructure of dump 4L4 (source: Google Earth 2018, Imagery date 18-11-2017).

Proposed City Deep (4L6) surface Infrastructure

0.37 km

NW toward site Motorist on M2 W

Photo 9-8: Motorist travelling on the M2 W approximately 0.37 km NW of proposed surface infrastructure of dump 4L6 (source: Google Earth 2018, Imagery date 18-11-2017).

Proposed City Deep (4L3) Surface Infrastructure

Corner of Houer Road and Bonsmara Rd

0.12 km

SE toward site

Photo 9-9: Corner of Houer Road and Bonsmara Road approximately 0.12 km looking SE towards the proposed Surface Infrastructure dump 4L3 (source: Google Earth 2018, Imagery date 18-11-2017)

9.12.3.5 Visual Absorption Capacity

Visual Absorption Capacity (VAC) signifies the ability of the landscape to accept additional human intervention without serious loss of character and visual quality or value.

Areas which have a high visual absorption capacity are easily able to accept objects so that their visual impact is less noticeable. Conversely areas with low visual absorption capacity will suffer a higher visual impact from structures imposed on them.

It is apparent that the landscape surrounding the hydraulic mining operations ability to ‘visually absorb’ the proposed surface infrastructure area is high due to the following:

❖ The proposed City Deep site is situated on a uniform landform type with flat terrain surrounding the immediate side and small hills in some areas; ❖ The degree of visual screening is high due to an increased number visual screening vegetations due to the historic nature of the dumps; ❖ The colour and contrast of the proposed operations fits in with the current natural colours of the area. This is largely due to the land use and the vegetative cover present in the area; ❖ The terrestrial environment is currently disturbed by activities associated with an industrial area. The required infrastructure, which the planned activities within the surface infrastructure area will require, would not be entirely alien or invasive to the surrounding environments; ❖ Land use as there are numerous other industrial activities that occur in the area.

The landscape therefore has a high absorption capacity. (Refer to Table 9-27) below.

Table 9-27: Criteria to determine absorption capacity for City Deep. Visual Absorption Capacity High Moderate Low Areas with prominent landforms, high Area of undulating Areas of flat topography, low topography, Vegetation screening, topography and landform, lying vegetation type, Landcover diversity Vegetation screening, mixed monotonous landcover. landcover

9.12.4 Magnitude of Visual Impact

In synthesising the criteria used to establish the magnitude of visual impact, a numerical or weighting system is avoided. This table is arrived at by combining the ratings of each of the sections above (viewshed, viewing distance, visual absorption capacity, and sensitivity receptors). The ratings for each of these criteria are indicated in Table 9-28 and derived from the discussion in the preceding sections. These results are based on worst-case scenarios (i.e., at full size and extent of the proposed mining infrastructure in the operational phase of mining) when the impact of all aspects is taken together. It is evident that the Visual impact expected is moderate to high.

Table 9-28: Magnitude of Visual Impact results Triggers & Viewshed Viewing Sensitive Visual Absorption Category of Analysis Distance Receptors Capacity Results Environment Results Results High - High -Sensitive Includes Moderate- Proposed City Deep Moderate- 25-50% of viewers are residents in mine area and Visual Impact zone of within <2km of close High – Moderate associated expected influence is Infrastructure the proposed proximity to visible site the proposed site

9.13 Heritage and Palaeontology 9.13.1 Historical Background

9.13.1.1 City Deep

After the discovery of the Main Reef at Witwatersrand in 1886, various mines were established. The mining method during these early years was labour intensive, while only the surface areas of the gold- bearing reefs were exploited. Lionel Phillips was one of the first mining entrepreneurs to realise the potential of deep-level mining. As part of the company of Hermann Eckstein, Phillips managed to acquire large numbers of claims which were considered of low value as they were located some distance away from the Main Reef. As a result he bought these claims for very reasonable prices, and started implementing the concept of deep level mining on some of these claims.

These steps resulted in the proclamation of various deep-level mines, including Nourse Deep, Jumpers Deep, Glen Deep, Crown Deep (City Deep forming part of this complex), Rose Deep, Village Deep, Geldenhuis Deep as well as Ferreira Deep. In 1893 the company of H. Eckstein formed the company Rand Mines Ltd, which took over the administration of these and other mines (Cartwright, 1965). Russell (n.d.) indicates that Rand Mines was established with start-up capital of £400,000 and was one of the earliest companies formed specifically for mining deep levels. The company quickly acquired 1,729 deep level claims. Lionel Phillips’ foresightedness earned him the respect of his pears, as well as the position of chairman for Rand Mines, a company that soon became the “…biggest mining finance company in the world.” (Cartwright, 1965).

A number of deep level mines, including City Deep, South City, Suburban Deep, Wolhuter Deep, South Wolhuter and Klip Deep, were floated prior to the Anglo-Boer War (1899-1902) as offshoots of the Klipriviersberg Estate Gold Mining Company Limited (Praagh 1906: 574). City Deep Limited also possessed a mining lease on Klipriviersberg 106IR in 1925 (Pelser 2014).

9.13.1.2 Rosherville Power Station & Dam

The Rosherville Power Station was built in 1911 by the Rand Mines Power Supply Company (RMPS) to supply the gold mines of the Witwatersrand with electricity and compressed air. This was at a time when South Africa’s mining industry was increasing in size rapidly and the only way for it to maintain that growth was for it to use electricity. Overall, the Roserville Power Station had a life span of fifty-five years, from 1911 to 1966 (Conradie & Messerschmidt 2000).

The Rosherville Power Station was built halfway between Johannesburg and Germiston on the banks of the Rosherville Dam, which was originally built by Nourse Mines (part of the Rand Mines Group) in 1905. The dam contained, when it was full, held approximately 820 million gallons (3690 million litres) and had a surface area of 215 acres, which was adequate for the needs of the power station. The construction began in 1905 and ended in 1911, by which time it was able to deliver electricity and compressed air to the 17 mines of the Rand Mines and the Corner House Group (Conradie & Messerschmidt 2000).

Figure 9-72: Rosherville Power Station in the foreground and the Rosherville Dam in the Background

9.13.2 Heritage Resource Findings

Heritage resources identified during the fieldwork component of this HIA is described in Table 9-29 and their positions shown in Figure 9-73.

Figure 9-73: Heritage sites identified during field survey.

Table 9-29: Sites identified during heritage survey Site10 number Lat Lon Description Heritage Significance Heritage Rating The site comprises the remains of a structure, consisting of some buried brickwork and an underground pipeline, CTY001 S 26.22981° E 28.10450° most likely forming part of an old mining compound or related dormitories as shown on the historical topographic Low GP.C maps. The structure measures 10m x 10m.

Remains of structure at CTY001 The site comprises the remains of a structure, consisting of a concrete foundation and gravel, most likely forming CTY002 S 26.22841° E 28.10379° part of an old mining compound or related dormitories as shown on the historical topographic maps. The structure Low GP.C measures 10m x 10m.

Remains of structure at CTY002 The site comprises stone-built wall of the Rosherville Dam that formed part of the Rosherville Power Station, built between 1909 - 1911. The Rosherville Dam and its associated infrastructure is clearly visible on the 1st Edition Topographic map dated to 1939. CTY003 S 26.22490° E 28.10555° Medium/High LS (3A) The dam wall is still in incredibly good condition and is currently in use as the retaining wall for the Rosherville Dam. New infrastructure has been incorporated into its design in the form of a pumping station that sits at its Western end.

Site10 number Lat Lon Description Heritage Significance Heritage Rating The site measures approximately 350m in length.

View of portion of Rosherville Dam wall Alternate view of Rosherville Dam wall

View of pumping station at western end of dam wall that is still in operation View of inner side of dam wall

View of Rosherville Dam spillway

Site10 number Lat Lon Description Heritage Significance Heritage Rating The site comprises the remains of a stone walled structure combined with the remains of a stone walled kraal. The site most likely dates to the historic to recent past due to its shape and the construction materials employed. CTY004 S 26.23050° E 28.10712° Low GP.C Looking at the dimensions of the former structure, it was most likely used as some kind of farming utility structure. The structure measures 8m x 8m while the kraal measures 15mx6m.

View of the remains at CTY004 Alternate view of the interior of portion of the stone walling

View of cattle kraal at CTY004 Alternate view of cattle kraal at CTY004

9.13.3 Palaeontological Sensitivity

The Proposed Project is underlain by the Turffontein and Johannesburg Subgroups (with a Zero Palaeontological Sensitivity) (Figure 9-74). These subgroups generally consist of quartzites and conglomerates formed by braided river systems, as well as pyritic sands, insignificant shales, and volcanics as well as debris-flow diamictites. Rock formations with a zero palaeontological sensitivity are unfossiliferous.

Figure 9-74: Regional geology of the proposed City Deep Dumps in Johannesburg, Gauteng Province.

Rock formations of moderate to high Palaeontological Sensitivity are not present in the study area and thus a field-based assessment by a palaeontologist is not required (Table 9-30).

Table 9-30: Palaeontological Sensitivity of various geological supergroups, subgroups and groups (SAHRA, 2018) Palaeontological Supergroup Group Subgroup Formation Sensitivity Karoo Zero Karoo Ecca Vryheid High Karoo Dwyka Moderate Transvaal Chuniespoort Malmani High Supergroup Group Witwatersrand Central Rand Turffontein Zero Witwatersrand Central Rand Johannesburg Zero Ventersdorp Klipriviersberg Zero

9.14 Social

The Proposed Project has the potential to result in both positive and negative social impacts. As such, it is important that the socio-economic baseline conditions are understood to ensure accurate identification and assessment of potential impacts associated with the Proposed Project.

Gauteng is the largest urban economy if Africa, with a population estimated to be 13.3 million, (Gauteng Spatial Development Framework 2030) (GSDF). In terms of land area, Gauteng is the smallest province in South Africa but also densely populated. Gauteng accounts for only 1.5% of the land area. below provides an overview of the socio-economic baseline information for Gauteng province.

Table 9-31: Socio-economic baseline information: Gauteng at a glance Description Statistics Demographics Population size 13 399 724 (about one-quarter of the figure in South Africa Majority of the population (64%) is made up of the population group between Population by size the ages of 18-64. Isizulu is the most spoken language, approximately 3 022 844-slightly less that Language the figure in South Africa. Approximately 93.9% of the population is born in South Africa (slightly less than Migration the rate in South Africa) Households Number of households 4 951 135, with 62% of the population reside in formal dwellings Service Delivery 96.8% are getting water from a regional or local service provider (about 10% Access to water services higher than the rate in South Africa. Access to electricity 7.4% have no access to electricity. Toilet facilities 89% have access to flush or chemical toilets. Education 78.7% have completed grade 9 or higher (about 10% higher than the rate in Educational level South Africa. 52.4% have completed Matric. Employment Employment status 51% are employed (about 1.3 times the rate in South Africa). Unemployment status 26.63% Economics Manufacturing sector providing 14% of the total provincial output, followed by Economic sectors construction at 3%, mining at 2% and agriculture at under 0.5%. Average annual income R57 500 nearly double the amount on South Africa Information extracted from Stats SA: Census 2011 and the Community Survey: 2016

9.14.1 City of Johannesburg Metropolitan-Overview

9.14.1.1 Demographics

The CoJ Integrated development Plan (IDP) 2018/2019 states that, the City of Johannesburg is South Africa’s largest metropolitan municipality in terms of population, size and diversity of its economy. According to the Community Survey 2016, CoJ has a population of approximately 4 949 346, about two- fifths of the figure in Gauteng. It is projected that the population could increase from the 4.9 million (2016) to 5.4 million (2021) and to 7.6 million (2037).

9.14.1.2 Dependency Ratio

CoJ’s population is mainly composed of a young population (persons aged 14 to 35 years) which constitute over 33.2% of the total population. This indicates that the youth is migrating to Johannesburg for better opportunities, but the influx has led to high youth unemployment (approximately 40%) in Johannesburg.

9.14.1.3 Household

The area comprises a mix of formal and informal housing, according to the Community Survey 2016, there are about 1 853 369 households within CoJ. 18% of the households are categorised as informal settlements. The IDP states that the population and households’ dynamics in Johannesburg indicate that the population grew by 11.6% between 2011 and 2016 which poses challenges for planning and development in the city.

9.14.2 Household Ownership

According to the Community Survey 2016, 51.7% of the households within CoJ are fully paid or are being paid off. Table 9-32 below gives an indication of the tenure status.

Table 9-32: Household ownership Description Percentage Owned and fully paid off 38.1% Rented from private individual 26.5% Owned but not yet paid off 13.6% Occupied rent free 12.8% Other 6.4%

9.14.3 Educational Level

53% of the population have completed matric or higher, about the same as the rate in Gauteng: 52.43%. About 5% of the population have a postgraduate qualification.

Population by highest educational level 3% 3% 1%

5% 6% 6%

31%

41%

None Other Some primary Some Secondary Grade 12 Undergrad Post grad N/A

Figure 9-75: Population by highest educational level (Source: Community Survey 2016).

9.14.4 Economy and Livelihoods

The economy sector is dominated by the finance sector, which is the biggest employer in the region, accounting for 26.6% of total employment, followed by the trade sector which employs 21.1% of the formal sector workers and the agricultural sector employs only 0.4%.

9.14.5 Employment Status

About 52% of the population is employed which is slightly higher compared to Gauteng. The IDP review, 2018/2019 indicates that the CoJ’s unemployment rate is 32.3%. According to the CoJ’s Socio-Economic overview document 2016, If the expanded definition for “unemployment” term is taken into account, youth unemployment rate rises to alarming statistic of approximately 40%, this is according to CoJ’s Socio- Economic overview document, 2016. The implications of a high unemployment rate amongst the youth is that it hinders transformation and development. A high unemployment rate has social and economic challenges that can be linked to poverty, increased reliance on public services and social instability.

9.14.6 Infrastructure

This section of the report will discuss the quality of infrastructure and an overview of key social services within the project area and a percentage of the population that has access to such services.

Water

Access to basic services (in terms of water supply) is relatively high, majority (98%) of the population get water from a regional or local service provider. 65% have access to piped water in their house and 29% have access to water in their yards. Only 3% of the population have access to piped water from community stands.

Electricity

Access to electricity

3% 2%

35% 54%

In house prepaid meter In-house conventional meter No access to electricity Other source (not paying for) Other source (not paying for)

Figure 9-76: Population by electricity access (Source: Community survey 2016)

Toilet facilities

4% 2%1%1%

92%

Flush toilet Pit toilet Bucket toilet Chemical toilet Other

Figure 9-77: Access to toilet facilities (Source: Community survey 2016)

Refuse disposal

3%2% 4% 4%

87%

Service provider (regularly) Service provider (not regularly) Communal dump Communal container Other

Figure 9-78: Refuse disposal (Source: Community survey 2016)

9.14.7 Key Challenges with CoJ

According to the IDP review 2018/2019, the city conducts a public participation process to facilitate community consultation sessions. The purpose of the community consultation sessions are to provide feedback and afford community members to raise issues of concern. Based on the overview of issues/concerns from community members it seems the issue of access to sustainable human settlements is a common concern in all the regions. Other challenges that the CoJ is experiencing include:

❖ An uncontrolled influx of people in the Inner City - increased scale of urban growth; ❖ Housing backlogs contributing to the increased rise in illegal occupation in key residential areas; ❖ Service delivery breakouts- due to a lack of infrastructure maintenance and infrastructure backlogs are increased by a continual influx of migrants; ❖ High unemployment rate; ❖ Income inequality and poverty; and ❖ Housing backlogs contributing to the increased rise in illegal occupation in key residential areas.

The abovementioned issues have a bearing on how the proposed project may bring about social change within the affected local area.

9.14.8 Anticipated Social Impacts

9.14.8.1 Job Security and Skills Development

indirect employment will be created by procuring local goods and services, induced employment generated through spending and associated job creation in the economy. Project related employment has the potential to considerably improve the livelihoods and income stability of employees and their dependants.

It should be taken into account that with the high unemployment rate within the project area, there are expectations regarding employment opportunities. Questions regarding employment opportunities were raised during consultations with surrounding community members.

9.14.8.2 Stimulation of Economic Growth

The proposed project may result in several economic benefits for local communities through direct and multiplier effects stimulated by capital expenditure and construction activities. The proposed project is likely to generate contracts for the purchase of equipment and other goods and services. The majority of these contracts will be for specialist goods and services, which will be provided by businesses within the project area. Procuring of specialist goods and services will likely generate more opportunities for Small, Medium and Micro sized Enterprises (SMMEs), provided they meet the procurement requirements as set out by the mine.

The proposed project will contribute to the supply of gold to the local and national markets, and therefore contribution to local, provincial and national economy.

9.14.8.3 Influx of Job Seekers

With a high unemployment rate in the project area, it is anticipated that the proposed project could result in an influx of job seekers during the construction and operational phases. Even though there is a low probability of it resulting in severe negative impacts, pro-active mitigation measures should be implemented to address the issue and to avoid possible long term negative impacts such as potential job seekers remaining in the area putting additional pressure on the local infrastructure and services.

9.14.8.4 Availability of Alternative Land Uses

From an environmental and social perspective, the proposed project is a positive impact. As indicated by van Rensburg (2016: 367) that the benefit of reclamation projects would not only be to extract the additional economical value from the tailings, but the reclamation projects also provide a second opportunity to process the tailings more responsibly with regard to leaving behind a less toxic, more stable, smaller quantity of tailings whilst making the large areas of land available for use.

The removal of the mine dumps will provide more land for the CoJ in line with the Metropolitan Spatial Development Vision. Although there will be availability of land, the end land uses should be sustainable and agreed upon with Interested and Affected Parties as they will be the future land users.

It should be noted that availability of alternative land uses will only materialise once the dumps have been successfully reclaimed, therefore this impact has been assessed for a period when the project is being decommissioned.

9.14.8.5 Safety Impacts

The presence of a development project in the area can make the area seem like an optimal area of possible employment and informal trading. It is also possible that illegal miners may see an opportunity to illegal extract gold from the dumps, this might impact on people’s perceptions of safety.

There is also a risk that residents in the area may be exposed to risks and hazards due to the proposed project. According to GDARD (2012), most Mine Residue Areas s have an element of lawlessness to them and should be considered as badlands where state penetration is minimal. The absence of security results in theft of equipment and the damage of infrastructure required to mitigate the negative impacts of Mine Residue Areas. Dust control equipment such as sprayers and pumps are often stolen, which reverts back to environmental issues; while copper theft in the Mine Residue Areas is widespread. These issues pose safety risks for law enforcement, affected land owners and adjacent communities.

9.14.8.6 Increased Dust Levels and Rise in Associated Health Impacts

Concerns that the proposed project might increase dust levels during the construction and operational phases was recorded during public consultations, this concern was linked to compromised health for individuals in close proximity to the proposed project area. The dust usually contains fine particulate matter, which can be inhaled, causing damage to lung tissues. The dust also potentially contains a number of hazardous substances that can result in chemical toxicity.

Tailings with high level of radioactive material can cause radiological pollution. Collectively, the dust problem poses a significant health risk and reduces the quality of life for a large number of citizens. Furthermore, this undermines the credibility of the mining industry as a responsible corporate citizen (GDARD, 2012, ply). The approval of this project would eliminate the City Deep Dumps as a source of air pollution upon completion.

According to the Health effects associated with short-term exposure to particulates include increases in lower respiratory symptoms, medication use and small reductions in lung function. Susceptible groups with pre-existing lung or heart disease, as well as elderly people and children, are particularly vulnerable. Exposure to particulate matter affects lung development in children, including reversible deficits in lung function as well as chronically reduced lung growth rate and a deficit in long-term lung function.

Findings from the air quality impact assessment indicate the following:

❖ Increased PM emissions from the area being reclaimed can be expected to increase ambient air concentrations of PM10 and PM2.5, particularly in the areas within the first 1 000 m; ❖ Dustfall caused by the reclamation process decreases rapidly with distance from the area being worked on.; ❖ If mining is initiated on the southern side of 4L6, worst-case windy days cause the predicted maximum daily average concentration to exceed the national daily standard for PM10 of 75µg/m3 up to approximately 630 m to the north and up to 490 m to the west over adjacent industrial areas as well as up to 850 m over the residential areas to the south-west. This is a

health risk for people living in this area. ❖ The removal of the City Deep dumps as a permanent pollution source will, in the long term, ameliorate the air quality of the surrounding areas, and reduce the health risk of fine particulate matter inhalation for the surrounding communities.

9.14.8.7 Increased Nuisance Factors and Changed Sense of Place

The construction of the proposed project will represent a significant intrusion into the surrounding physical environment, which could impact on surrounding communities in various ways.

9.15 Radioactivity

A study by MINTEK in 2016, on several TSF dumps in the Witwatersrand gold mining zone indicate that the tailings samples from the East Rand and Central Gauteng regions contained the lowest uranium concentrations (generally not requiring uranium removal prior to re-dumping). The bulk make up of each of the TSFs included quartz, pyrophyllite and mica as major minerals (Table 9-33). The City Deep site is situated within the Central Gauteng region, and based on the information for the area is not considered as a radiation risk.

Table 9-33: Average gold, uranium, sulphur and carbon analysis of typical dump samples (Mintek, 2016). Element East Rand Central Gauteng West Rand Free State Au Gramm/tonne 0.27 0.3 0.35 0.41 (g/t) (some with spots as high as 8 g/t) Uranium g/t 19 Not determined 59 65 Sulphide % 0.41 0.25 0.5 0.9 Sulphate % 0.5 0.01 0.3 0.4 Total S % 0.9 0.28 0.8 1.05 Total C % 0.31 0.14 0.26 0.06

A Public Hazard Assessment Report was undertaken for DRDGold in April 2018 (Zimkile Consulting cc, 2018) to determine the impact of radiation due to naturally occurring radioactive materials on the population living on and around the Crown Gold Recoveries (Crown). The assessment was performed in accordance with NNR License Guide LG-1032. The pathways identified that might contribute to public exposure were (i) radon, (ii) dust, and (iii) surface water (potential).

9.15.1 Radon Pathway

Radon is considered to be the main contributor to public exposure. Regional radon monitoring was done to establish radon concentration values. The 90th percentile average result obtained over the period of 2008 to 2010 is at 1.54 milli sievert per annum (mSv/a).

The tailings dams assessed contain low levels of radioactivity. A fugitive dust source term for the dumps was not assessed since the nuclide-specific activity concentrations of the material in the dumps do not exceed 0.5 Becquerel per gram (Bq/g). However the radon source term assessments were performed.

9.15.2 Dust Inhalation

Dust inhalation calculations undertaken indicated a maximum specific activity of 195Bq/kg, which is below the regulatory limit of 500Bq/kg.

9.15.3 Water Ingestion

The lifetime doses obtained is equivalent of 3.75mSv/a. This falls with Class 2 (marginal water quality) of the DWAF Guidelines for Assessing Radiological Quality of Water. However as the water in the water courses involved are not used for drinking water this pathway is therefore not considered for dose calculation as it is unlikely to occur.

9.15.4 Total Dose from Pathways

The calculation is as follows:

Total Dose = (Radon + Dust + Water11) Pathways

= 1 585+12.68 Micro sievert per annum (µSv/a)

= 1 597.68 µSv/a

= 1.6 mSv/a

11 Water pathway not considered.

10 Impact Assessment

10.1 Methodology for Assessing the Significance of Environmental Impacts

The impact significance rating process serves two purposes: firstly, it helps to highlight the critical impacts requiring consideration in the management and approval process; secondly, it shows the primary impact characteristics, as defined above, used to evaluate impact significance. As read within the DWS’s Best Practice Guideline: G4 – Impact Prediction, there are three basic components that define an impact (or a risk). Figure 10-1 represents the relationship between these three components and their influence on the significance of a certain impact of a project.

Figure 10-1: Impact prediction model.

The impact significance rating system is presented in Table 10-1, Table 10-2 and Table 10-3, and involves three parts:

❖ Part A: Define impact consequence using the three primary impact characteristics of magnitude, spatial scale/ population and duration; ❖ Part B: Use the matrix to determine a rating for impact consequence based on the definitions identified in Part A; and ❖ Part C: Use the matrix to determine the impact significance rating, which is a function of the impact consequence rating (from Part B) and the probability of occurrence.

10.1.1 Part A: Defining Consequence in Terms of Magnitude, Duration and Spatial Scale

Use these definitions to define the consequence in Part B.

Table 10-1: Consequence rating definitions. Impact Characteristics Definition Criteria Substantial deterioration or harm to receptors; receiving environment has an inherent value to stakeholders; receptors Major - of impact are of conservation importance; or identified threshold often exceeded Moderate/measurable deterioration or harm to receptors; Moderate - receiving environment moderately sensitive; or identified threshold occasionally exceeded

Minor deterioration (nuisance or minor deterioration) or Magnitude Minor - harm to receptors; change to receiving environment not measurable; or identified threshold never exceeded

Minor improvement; change not measurable; or threshold Minor + never exceeded

Moderate improvement; within or better than the threshold; Moderate + or no observed reaction

Substantial improvement; within or better than the threshold; Major + or favourable publicity

Site or local Site specific or confined to the immediate project area May be defined in various ways, e.g. cadastral, catchment, Spatial scale or Regional population topographic National/ Nationally or beyond International Short term Up to 18 months.

Duration Medium term 18 months to 5 years

Long term Longer than 5 years

10.1.2 Part B: Determining Consequence Rating

Rate consequence based on definition of magnitude, spatial extent and duration.

Table 10-2: Consequence rating methodology. Spatial Scale/ Population Magnitude Duration Site or Local Regional National/ International Long term Medium Medium High Minor Medium term Low Low Medium Short term Low Low Medium

Spatial Scale/ Population Magnitude Duration Site or Local Regional National/ International Long term Medium High High Moderate Medium term Medium Medium High Short term Low Medium Medium Long term High High High Major Medium term Medium Medium High Short term Medium Medium High

10.1.3 Part C: Determining Significance Rating

Rate significance based on consequence and probability.

Table 10-3: Significance rating methodology. Probability (of Consequence Negative Consequence Positive exposure to impacts) Low Medium High Low Medium High Definite Medium Medium High Medium Medium High Possible Low Medium High Low Medium High Unlikely Low Low Medium Low Low Medium

10.2 Impacts and Cumulative Impacts Identified

This Subchapter serves to provide insight on the major positive, negative and cumulative impacts associated with the development of the City Deep Project. The potential impacts are discussed per environmental feature/ aspect. For more detail please refer to the specialist studies contained in the appendices.

10.2.1 Construction Phase

During the construction phase the following activities will take place on site:

❖ Site clearance (for infrastructure); ❖ Establishment of infrastructure (pipelines, temporary site offices, change houses and portable ablution facilities, stormwater management infrastructure, collection sump, reclamation station); ❖ Waste handling; and ❖ Vehicle and machinery movement.

10.2.1.1 Topography

The removal of vegetation and the associated construction activities to prepare footprint for construction will allow for increased surface water runoff, which may lead to change in topographical characteristics

of the area. This is however not envisaged to be a significant impact as most of the infrastructure will be located on already existing servitudes and Brownfield’s areas.

Table 10-4: Significance rating of construction impacts on topography. NATURE OF IMPACT 1: The removal of vegetation and infrastructure construction could lead to soil erosion which may lead to change in topographical characteristics Impact Rating without Impact Rating with Mitigation Mitigation Impact Status: (positive or negative) Negative Negative Extent (Local, Regional, International) Local Local

Duration (Short term, Medium term, Long term) Short term (construction phase Short term (construction period) phase period) Magnitude (Major, Moderate, Minor) Minor Minor

Probability (Definite, Possible, Unlikely) Possible Unlikely

Calculated Significance Rating (Low, Medium, Low Low High)

Reversibility: (Reversible or Irreversible) Yes Irreplaceable loss of resources: (Yes or No) No Can impacts be enhanced: (Yes or No) Yes Residual impacts ❖ None foreseen Mitigation measures ❖ Construction areas must be clearly demarcated to control movement of personnel and vehicles, providing clear boundaries for construction sites to limit the spread of impacts. ❖ Removal of vegetation must be undertaken in a phased approach to limit the amount of bare areas at a time. ❖ Temporary erosion control measures that reduce flow velocity (e.g. runoff berms) should be implemented around construction areas.

10.2.1.2 Soils, Land Use, Land Capability

The sites are already disturbed by past activities.

Topsoil removal during establishment of infrastructure will disturb the natural sequence of soil layers thereby permanently changing the soil and land capability. A change in soil capability will in turn affect the end land use. The movement of heavy vehicles in the construction area will result in compaction of soil, water runoff and soil erosion especially during the rainy season. Construction of the proposed pipeline will remove very little topsoil because relatively small soil areas are impacted on through the digging of foundation trenches. Temporary storage of hazardous products may cause the pollution of soil.

Table 10-5: Significance rating of construction impacts on soil, land use and land capability. NATURE OF IMPACT 1: Topsoil removal during establishment of infrastructure will disturb the natural sequence of soil layers thereby permanently changing the soil and land capability. Impact Rating without Impact Rating with Mitigation Mitigation Impact Status: (positive or negative) Negative Negative Extent (Local, Regional, International) Local Local

Duration (Short term, Medium term, Long term) Short term (construction Short term (construction phase period) phase period) Magnitude (Major, Moderate, Minor) Minor Minor

Probability (Definite, Possible, Unlikely) Possible Unlikely

Calculated Significance Rating (Low, Medium, Low Low High)

Reversibility: (Reversible or Irreversible) Yes Irreplaceable loss of resources: (Yes or No) No Can impacts be enhanced: (Yes or No) Yes Residual impacts ❖ None foreseen Mitigation measures ❖ Surface runoff water from compacted areas such as roads must be controlled to indirectly also control soil erosion. ❖ Roads must be inspected and eroded shoulders repaired especially during the rainy season. ❖ Storage areas must be contained using brick walls. ❖ Any hydro-carbon spills on soil must be reported to the environmental officer and cleaned up by trained personnel using commercially available emergency clean-up kits.

10.2.1.3 Biodiversity

The following list provides a framework for the anticipated impacts associated with the project.

❖ Loss / degradation of ecosystems o Project activities that can cause loss of habitat (especially with regard to the two proposed infrastructure areas): ▪ Physical removal of vegetation ▪ Access roads and servitudes ▪ Soil dust precipitation ▪ Water leakages ▪ Stochastic events such as fire (cooking fires or cigarettes from staff) o Secondary impacts anticipated ▪ Displacement/loss of flora & fauna (including possible SCC) ▪ Increased potential for soil erosion ▪ Habitat fragmentation

▪ Increased potential for establishment of alien & invasive vegetation ❖ Spread and/or establishment of alien and/or invasive species o Project activities that can cause the spread and/or establishment of alien and/or invasive species ▪ Vegetation removal ▪ Vehicles potentially spreading seed ▪ Unsanitary conditions surrounding infrastructure promoting the establishment of alien and/or invasive rodents ▪ Creation of infrastructure suitable for breeding activities of alien and/or invasive birds o Secondary impacts anticipated ▪ Habitat loss for native flora & fauna (including SCC) ▪ Spreading of potentially dangerous diseases due to invasive and pest species ▪ Alteration of fauna assemblages due to habitat modification ❖ Direct mortality of fauna o Project activities that can cause direct mortality of fauna ▪ Clearing of vegetation ▪ Roadkill due to vehicle collision ▪ Pollution of water resources due to dust effects, chemical spills, acid mine drainage etc. ▪ Intentional killing of fauna for food (hunting) or otherwise (killing of snakes) ▪ Bird collisions with electrical lines o Secondary impacts anticipated ▪ Loss of ecosystem services ▪ Explosion of rodent populations and associated disease risk ❖ Reduced dispersal/migration of fauna o Project activities that can cause reduced dispersal/migration of fauna ▪ Compacted roads ▪ Removal of vegetation o Secondary impacts associated with reduced dispersal/migration of fauna ▪ Loss of ecosystem services ▪ Reduced plant seed dispersal ❖ Environmental pollution due to water/ mine drainage runoff o Project activities that can cause pollution in water courses ▪ Chemical (organic/inorganic) spills ▪ Erosion ▪ Acid mine drainage o Secondary impacts associated with pollution in water courses ▪ Faunal mortality (direct and indirectly e.g. algal blooms) ▪ Groundwater pollution ▪ Loss of ecosystem services ❖ Disruption/alteration of ecological life cycles (breeding, migration, feeding) due to noise o Project activities that can cause disruption/alteration of ecological life cycles due to noise ▪ Operation of machinery (generators, crushers, vehicles)

o Secondary impacts associated with disruption/alteration of ecological life cycles due to noise ▪ Loss of ecosystem services ❖ Disruption/alteration of ecological life cycles (breeding, migration, feeding) due to dust o Project activities that can cause disruption/alteration of ecological life cycles due to dust ▪ Vehicles ▪ Exposed mine dump o Secondary impacts associated with disruption/alteration of ecological life cycles due to dust ▪ Loss of ecosystem services ❖ Staff and others interacting directly with potentially dangerous fauna or pouching of animals o Project activities that can cause staff to interact directly with potentially dangerous fauna ▪ All activities outdoors Table 10-6: Significance rating of construction impacts on Biodiversity. NATURE OF IMPACT 1: Site clearance for access roads as well as disturbances such as noise and dust could lead to the loss of areas classified as CBA and wetlands of importance. NATURE OF IMPACT 2: Site clearance for access roads as well as disturbances such as noise and dust could lead to the loss of area of plant endemism. NATURE OF IMPACT 3: Site clearance for access roads as well as disturbances such as noise and dust could lead to the loss of Endangered & Critically Endangered habitat. Impact Rating Without Impact Rating With

Mitigation Mitigation Impact Status: (positive or negative) Negative Negative

Extent (Local, Regional, International) Local Local

Duration (Short term, Medium term, Long Short-term Short-term term)

Magnitude (Major, Moderate, Minor) Moderate Minor

Probability (Definite, Possible, Unlikely) Definite Possible

Calculated Significance Rating (Low, Medium, Medium Low High) Cumulative Impact Yes Reversibility: (Reversible or Irreversible) Irreversible Irreplaceable loss of resources: (Yes or No) Yes Can impacts be enhanced: (Yes or No) Yes Residual impacts ❖ None foreseen Mitigation measures ❖ Avoid CBA areas and implement buffer zones. ❖ Avoid areas of remaining indigenous vegetation ❖ Avoid high biodiversity sensitivity areas (natural vegetation, watercourses & wetlands) and comply to prescribed buffer zones.

Table 10-7: Significance rating of construction impacts on Flora. NATURE OF IMPACT 1: Site clearance for access roads as well as disturbances such as noise and dust could lead to the loss of plant species of conservation importance NATURE OF IMPACT 2: Site clearance for access roads as well as disturbances such as noise and dust could lead to the encroachment of alien invasive plant species. Impact Rating Without Impact Rating With

Mitigation Mitigation Impact Status: (positive or negative) Negative Negative

Extent (Local, Regional, International) Local Local

Duration (Short term, Medium term, Long Short-term Short-term term)

Magnitude (Major, Moderate, Minor) Moderate Minor

Probability (Definite, Possible, Unlikely) Definite Possible

Calculated Significance Rating (Low, Medium, Medium Low High) Cumulative Yes Reversibility: (Reversible or Irreversible) Irreversible Irreplaceable loss of resources: (Yes or No) Yes Can impacts be enhanced: (Yes or No) Yes Residual impacts ❖ None foreseen Mitigation measures ❖ Avoid areas in which plant species of conservation concern occur; ❖ If some areas cannot be avoided implement rescue of plant species of conservation concern. ❖ An alien invasive plant management plan needs to be compiled and implemented during construction to prevent the growth of invasive on cleared areas

Table 10-8: Significance rating of construction impacts on Fauna. NATURE OF IMPACT 1: Site clearance for access roads as well as disturbances such as noise and dust could lead to the loss of habitat for species of conservation concern. Impact Rating Without Impact Rating With

Mitigation Mitigation Impact Status: (positive or negative) Negative Negative

Extent (Local, Regional, International) Local Local

Duration (Short term, Medium term, Long Short-term Short-term term)

Magnitude (Major, Moderate, Minor) Moderate Minor

Probability (Definite, Possible, Unlikely) Definite Possible

Calculated Significance Rating (Low, Medium, Medium Low High) Cumulative Yes Reversibility: (Reversible or Irreversible) Reversible Irreplaceable loss of resources: (Yes or No) Yes Can impacts be enhanced: (Yes or No) Yes Residual impacts ❖ None foreseen Mitigation measures ❖ Avoid high biodiversity sensitivity areas (natural vegetation, watercourses & wetlands) and comply with prescribed buffer zones. ❖ Implement training to ensure that all staff are aware of faunal sensitivity. Put protocols in place to deal with fauna that are encountered during construction.

10.2.1.4 Wetlands

The impacts on wetlands anticipated during the construction phase are presented in Table 10-9. Impacts on wetlands were assessed using the Department of Water and Sanitation’s (DWS) risk matrix. The risk table for this section will therefore be different to that done for the rest of the aspects.

Table 10-9: Construction impacts on wetlands.

Without With Activity Aspect Impact Mitigation Measures

Biota Mitigation Mitigation

Severity

Duration

Detection

Likelihood

Legal Issues Legal

Significance

Spatial scale Spatial

Flow Regime Flow

Consequence

(Water Quality) (Water

and Vegetation) and

Habitat (Geomorph (Geomorph Habitat

Frequency of impact of Frequency

Frequency of activity of Frequency Physico and Chemical Chemical and Physico

Removal of 2,7 6,7 3 2 3 3 2 2 2 2 1 2 7 47,25 Low Low vegetation ❖ Impeding 5 5 ❖ The footprint area of the route should be kept a minimum. The hydrology; footprint area must be clearly demarcated to avoid Excavations ❖ Siltation of unnecessary disturbances to adjacent areas; (for plinths) channels and ❖ All construction activities and access must make use of the and 4 3 3 2 3 2 2 7 2 2 5 2 11 77 Moderate Low wetlands; existing access routes as much as possible. The number of installation of the pipeline ❖ Erosion of channels access routes and working areas must be minimised, and the and wetlands; footprint area of these must be reduced and demarcated; Vehicles, ❖ Loss of indigenous 2,2 6,2 ❖ The proposed pipeline will be aboveground. The number and machines and 2 2 2 3 2 2 2 2 5 2 11 68,75 Moderate Low equipment in vegetation; 5 5 size of plinths must be kept to a minimum, and avoid wetland use ❖ Direct loss of areas and the associated buffer as much as possible; wetland areas; ❖ If plinth support structures are needed for the pipeline to span Construction of ❖ Decrease in 2,7 6,7 a water resource, then plinths should be placed outside of the Proposed Ablution 2 4 2 3 2 2 2 2 1 2 7 47,25 Low Low functionality; preferential flow paths; Pipeline facilities 5 5 ❖ Additional water ❖ Pipelines crossings should preferably span the watercourses quality above ground. This prevents disruptions to sub surface flow Domestic and impairment; 2,2 8,2 dynamics and allows the pipeline to be monitored for leaks; industrial 2 3 2 2 3 3 2 2 1 2 7 57,75 Moderate Low ❖ Altering 5 5 ❖ When a pipeline spans a water resource, it should be attached waste hydromorphic to any existing crossing or bridge structures. This will limit the soils; need to disturb new areas of the systems with the Storage of ❖ Drainage patterns construction of new structures; and 2 4 2 2 2,5 3 3 8,5 2 3 1 2 8 68 Moderate Low chemicals, change; and ❖ Pre-fabricated structures should be made use of (where mixes and fuel ❖ Altering overland possible) to avoid the mixing of these materials on site, flow reducing the likelihood of onsite contamination. Spills and characteristics. 2,2 8,2 ❖ 2 3 2 2 3 3 1 3 5 3 8 66 Moderate Low leaks 5 5

10.2.1.5 Surface Water

The activities and impacts that are likely to occur during the construction phase are summarised in Table 10-10

Table 10-10: Summary of activities and impacts for the construction phase Activity Impact Description Impact 1: Erosion and consequent increase in Removal of vegetation and exposure of soils. Total Dissolved Solids (TSS) of surface water resources leading to deteriorated water quality. Impact 2: Increased velocity in surface water Lay down of impermeable surfaces such as concrete. runoff leading to erosion and consequent increase in TSS of surface water resources. Impact 3: Alteration in surface water drainage Alteration to the natural topography (excavations, shaft patterns leading to erosion and consequent portal, dumps, etc.). increase in TSS of surface water resources.

The ratings and proposed mitigation measures for the impacts indicated in Table 10-10, are provided in Table 10-11,

Table 10-12 and Table 10-13.

Table 10-11: Significance rating of construction impact 1 NATURE OF IMPACT 1: The removal of vegetation will expose soils to water erosion that may lead to a deterioration in water quality of surrounding surface water in terms of increased TSS and turbidity Impact Rating without Impact Rating with Mitigation Mitigation Impact Status: (positive or negative) Negative Negative Extent (Local, Regional, International) Regional Local

Duration (Short term, Medium term, Long term) Short term (construction Short term (construction phase period) phase period) Magnitude (Major, Moderate, Minor) Moderate Minor

Probability (Definite, Possible, Unlikely) Possible Possible

Calculated Significance Rating (Low, Medium, Medium Low High)

❖ Temporary erosion control measures that reduce flow velocity (e.g. runoff berms) should be implemented around construction areas; ❖ Clearance of vegetation must be limited as far as possible; and ❖ Water quality sampling must be implemented upstream and downstream of construction sites.

Table 10-12: Significance rating of construction impact 2 NATURE OF IMPACT 2: Lay down of impermeable areas is likely to result in increased velocity in surface water runoff, that may lead to erosion and consequent increase in TSS of surface water resources Impact Rating without Impact Rating with Mitigation Mitigation Impact Status: (positive or negative) Negative Negative Extent (Local, Regional, International) Regional Local

Duration (Short term, Medium term, Long Short term (construction phase Short term (construction term) period) phase period) Magnitude (Major, Moderate, Minor) Moderate Minor

Probability (Definite, Possible, Unlikely) Possible Possible

Calculated Significance Rating (Low, Medium, Medium Low High)

Reversibility: (Reversible or Irreversible) Irreversible Irreplaceable loss of resources: (Yes or No) No Can impacts be enhanced: (Yes or No) Yes Residual impacts ❖ None foreseen Mitigation measures ❖ Measures (energy dissipaters, detention dams, swales, etc.) that reduce flow velocity from impermeable areas should be implemented; ❖ Impermeable areas must not be constructed unnecessarily; and ❖ Water quality sampling must be implemented upstream and downstream of construction sites. Specific parameters that should be monitored include TSS and turbidity. They should be kept within the baseline water quality range.

Table 10-13: Significance rating of construction impact 3 NATURE OF IMPACT 3: Changes in the topography are likely to result in an alteration in surface water drainage patterns leading to erosion and a consequent increase in TSS of surface water resources Impact Rating without Impact Rating with Mitigation Mitigation Impact Status: (positive or negative) Negative Negative Extent (Local, Regional, International) Regional Local

Duration (Short term, Medium term, Long Short term (construction phase Short term (construction term) period) phase period) Magnitude (Major, Moderate, Minor) Moderate Minor

Probability (Definite, Possible, Unlikely) Possible Possible

Calculated Significance Rating (Low, Medium, Medium Low High)

Reversibility: (Reversible or Irreversible) Irreversible Irreplaceable loss of resources: (Yes or No) No Can impacts be enhanced: (Yes or No) Yes Residual impacts ❖ None foreseen Mitigation measures ❖ Stormwater management measures should be implemented around working areas; and ❖ Water quality sampling must be implemented upstream and downstream of construction sites. Specific parameters that should be monitored include TSS and turbidity. They should be kept within the baseline water quality range.

10.2.1.6 Groundwater

Dumps 4L3, 4L4 and 4L6 are old tailings dumps and negative groundwater quality impacts are suspected. There will potentially be groundwater quality impacts in the shallow and deeper aquifers.

No additional impact is expected on the water quantity and quality during the construction phase. The groundwater environment will assume its current status. Construction will be conducted in a relatively short period compared to the operational and post-closure phases. Impacts on the groundwater environment are therefore rated as Low (Table 10-14).

Table 10-14: Construction Phase water quality impacts NATURE OF THE IMPACT: Impact on the local groundwater quality Impact Rating Without Impact Rating with Mitigation Mitigation Impact Status: (positive or negative) Negative Negative Extent (Local, Regional, International) Local Local Duration (Short term, Medium term, Long term) Short term Short term

Magnitude (Major, Moderate, Minor) Minor - Minor +

Probability (Definite, Possible, Unlikely) Possible Possible Calculated Significance Rating (Low, Medium, High) Low Low

Reversibility: (Reversible or Irreversible) Reversable Irreplaceable loss of resources: (Yes or No) No

Cumulative impacts (yes or no) Yes. Combined impact associated with 4L3, 4L4 and 4L6 TSFs. Mitigation measures ❖ Plan for and provide sufficient budget to implement a groundwater monitoring programme before any reclamation starts. ❖ Should monitoring results indicate a loss of groundwater to private users, Ergo must supply the user with an equal water resource. ❖ Develop sound surface runoff management plans to ensure that all dirty runoff is contained and diverted to the emergency control dams. No pooling of water on surface allowed. ❖ Ensure that paddocks are designed to contain all dirty water generated during the reclamation process, to prevent overflows and spillages.

10.2.1.7 Air Quality

Impacts expected to occur are the generation of nuisance dust during construction of the infrastructure. It is proposed to establish a dust management plan in consultation with the environmental manager and include dust suppression as part of the contractor’s responsibility.

Table 10-15: Construction Phase air quality impacts. NATURE OF THE IMPACT 1: Dust generated from soil stripping activities, construction of infrastructure and traffic on access roads

Mitigation Mitigation Impact Status: (positive or negative) Negative Negative

Extent (Local, Regional, International) Local Local

Duration (Short term, Medium term, Long Short term Short term term)

Magnitude (Major, Moderate, Minor) Minor - Minor -

Probability (Definite, Possible, Unlikely) Definite Possible

Calculated Significance Rating (Low, Medium Low Medium, High) Reversibility: (Reversible or Irreversible) Yes Irreplaceable loss of resources: (Yes or No) No

Cumulative impacts (yes or no) No Mitigation measures ❖ Keep areas to be cleared as small as possible. ❖ Strict speed control of 20km/hr on all on-site roads, ❖ Restriction of the use of storage piles. 10.2.1.8 Noise

The information available is adequate to conclude that there will be a low potential for a noise impact during the construction phase due to:

❖ The very temporary nature of the proposed construction of the pipeline (few days); ❖ The projected construction noise level will be less than the acceptable daytime noise rating level for residential use; ❖ The projected construction noise level will be less than the noise rating level for an urban area with one or more of the following; workshops, business and main roads; and ❖ The construction of the reclamation plant will take place far from the closest noise-sensitive development (NSD).

It is the opinion of the specialist that the potential of a noise impact would be of a low significance.

Table 10-16: Impact Assessment: Construction Activities during the day NATURE OF THE IMPACT 1: Increased total noise levels in the area, changing existing ambient sound levels at receptors as a result of numerous simultaneous construction activities during the day Rural noise district. Acceptable Rating Level Use LReq,D of 45 dBA Impact Rating Without Impact Rating with

Mitigation Mitigation Impact Status: (positive or negative) Negative Negative The project will not impact on the ambient sound levels further than Extent (Local, Regional, International) 1,000 m from the activity during the day. Site or Local Noise levels will be elevated for Duration (Short term, Medium term, Long the construction phase. term) Short Term Daytime noise levels will be less No mitigation required. than the acceptable noise rating Magnitude (Major, Moderate, Minor) level for a rural area. Minor negative Ambient sound levels could be low at times and the activities may Probability (Definite, Possible, Unlikely) be audible but it will not be disturbing. Unlikely

Calculated Significance Rating (Low, Low Medium, High) Reversibility: (Reversible or Irreversible) Yes

10.2.1.9 Visual

Impacts expected to occur are dust generation from site clearance and creation of a visual disturbance from site clearance and construction of infrastructure.

Table 10-17: Significance rating of construction impact 1. NATURE OF IMPACT 1: Dust generation from the clearing and preparation of the site. Impact Rating Without Impact Rating With Mitigation Mitigation Impact Status: (positive or negative) Negative Negative

Extent (Local, Regional, International) Site Site

Duration (Short term, Medium term, Long Short term (construction phase Short term (construction phase term) period) period)

Magnitude (Major, Moderate, Minor) Moderate Minor

Probability (Definite, Possible, Unlikely) Definite Possible

Calculated Significance Rating (Low, Medium Low Medium, High) Reversibility: (Reversible or Irreversible) Reversible Irreplaceable loss of resources: (Yes or No No) Can impacts be enhanced: (Yes or No) Yes Residual impacts ❖ None foreseen Mitigation measures ❖ Ensure that dust suppression occurs on all dirt surfaces.

Table 10-18: Significance rating of construction impact 2. NATURE OF IMPACT 2: Creation of a visual disturbance when the site is cleared. Impact Rating Without Impact Rating With Mitigation Mitigation Impact Status: (positive or negative) Negative Negative

Extent (Local, Regional, International) Site Site

Duration (Short term, Medium term, Long Short term (construction phase Short term (construction phase term) period) period)

Magnitude (Major, Moderate, Minor) Moderate Minor

Probability (Definite, Possible, Unlikely) Definite Possible

Calculated Significance Rating (Low, Medium Low Medium, High) Reversibility: (Reversible or Irreversible) Reversible Irreplaceable loss of resources: (Yes or No No) Can impacts be enhanced: (Yes or No) Yes Residual impacts ❖ None foreseen Mitigation measures ❖ Clearly define areas to be cleared. Do not clear past designated areas

Table 10-19: Significance rating of construction impact 3. NATURE OF IMPACT 3: Disturbance of the view due to the construction of the equipment and offices used on site. Impact Rating Without Impact Rating With Mitigation Mitigation Impact Status: (positive or negative) Negative Negative

Extent (Local, Regional, International) Site Site

Duration (Short term, Medium term, Long Short term (construction phase Short term (construction phase term) period) period)

Magnitude (Major, Moderate, Minor) Minor Minor

Probability (Definite, Possible, Unlikely) Definite Possible

Calculated Significance Rating (Low, Medium Low Medium, High) Reversibility: (Reversible or Irreversible) Reversible Irreplaceable loss of resources: (Yes or No No) Can impacts be enhanced: (Yes or No) Yes Residual impacts ❖ None foreseen Mitigation measures ❖ Clearly define areas to be cleared. Do not clear past designated areas

10.2.1.10 Heritage and Palaeontology

Considering the fact that a large portion of the pipeline already exists, and that the proposed pipeline will avoid the Rosherville Dam entirely because it will only be joining up at the pumping station at its western end, only sites CTY002 & CTY004 will be affected by the proposed pipeline. Site CTY002 will not require any mitigation measures.

However, the following recommendations are made for site CTY004:

❖ A minimum of a 20m buffer zone should be implemented around the site; ❖ If this buffer zone is not able to be maintained, then appropriate mitigation measures will need to be implemented.

While site CTY003 will not be directly impacted by the pipeline, a 50m buffer should be maintained around the length of the dam as a deterrent.

Even though mine dump 4L3 is represented on the historical topographic map of 1954 and thus older than 60 years, it is the author’s considered opinion that this fact alone should not warrant its classification as a heritage site and subsequent protection privileges associated with that classification.

Table 10-20: Impacts on heritage site CTY004 NATURE OF THE IMPACT 1: Destruction of heritage site CTY004. The site comprises the remains of a stone walled structure combined with the remains of a stone walled kraal Impact Rating Without Impact Rating with

Mitigation Mitigation Impact Status: Negative Negative

Extent Local Local

Duration Long term Long term

Magnitude Minor - Minor -

Probability Definite Possible

Calculated Significance Rating Low Low

Reversibility: Not applicable Irreplaceable loss of resources: Not applicable Can impacts be enhanced: Yes Cumulative impact: No Residual impacts ❖ None Mitigation measures ❖ Implement 20m buffer around site. ❖ If buffer zone cannot be maintained then appropriate mitigation measures will need to be implemented.

Table 10-21: Impacts on heritage site CTY003 NATURE OF THE IMPACT 2: Impacts on the Rosherville Dam Wall (CTY003)

Impact Rating Without Impact Rating with

Mitigation Mitigation Impact Status: Negative Negative

Extent Local Local

Duration Long term Long term

Magnitude Major - Minor -

Probability Unlikely Unlikely

Calculated Significance Rating Medium Low

Reversibility: Not applicable Irreplaceable loss of resources: Not applicable Can impacts be enhanced: Yes Cumulative impact: No Residual impacts ❖ None Mitigation measures ❖ Implement 50m buffer around site. ❖ If buffer zone cannot be maintained then appropriate mitigation measures will need to be implemented.

10.2.1.11 Socio-Economic

It is understood that the proposed project will not create additional job opportunities but will provide job security for the current personnel. Employment opportunities include direct employment by the Project, indirect employment will be created by procuring local goods and services, induced employment generated through spending and associated job creation in the economy. Project related employment has the potential to considerably improve the livelihoods and income stability of employees and their dependants.

Table 10-22: Impacts on job security and skills development NATURE OF THE IMPACT: Job security and skills development Impact Rating Without Impact Rating with

Mitigation Mitigation Impact Status: Positive Positive

Extent Local Local

Duration Short term Short term

Magnitude Moderate + Major +

Probability Definite Definite

Calculated Significance Rating Medium Medium

Reversibility: Not applicable Irreplaceable loss of resources: Not applicable Can impacts be enhanced: Yes Residual impacts

❖ The residual impacts associated with the creation of employment and business opportunities and training during the construction phase is that the workers can improve their skills by gaining more experience; ❖ Improved economic development; ❖ Increased capacity to develop and maintain livelihood strategies. Mitigation measures

❖ Establish targets for employment and training; ❖ Effective implementation of training and skills development initiatives.

The proposed project will contribute to the supply of gold to the local and national markets, and therefore contribution to local, provincial and national economy.

Table 10-23: Impacts on economic growth NATURE OF THE IMPACT: Stimulation of economic growth Impact Rating Without Impact Rating with

Mitigation Mitigation Impact Status: (positive or negative) Positive Positive

Extent Local Local

Duration Short term Short term

Magnitude Moderate + Major +

Probability Definite Definite

Calculated Significance Rating Medium Medium

Reversibility: (Reversible or Irreversible) N/A Irreplaceable loss of resources: (Yes or No No) Can impacts be enhanced: (Yes or No) Yes Residual impacts ❖ Developed local economy; Mitigation measures ❖ Preference should be given to capable subcontractors who based within the local municipal area; and ❖ Align skills development to build capacity of SMMEs as per the existing Social and Labour Plan (SLP).

Table 10-24: Impacts on municipal services NATURE OF THE IMPACT: Increased pressure on municipal services Impact Rating Without Impact Rating With

Mitigation Mitigation Impact Status: (positive or negative) Negative Negative

Extent Local Local

Duration Medium term Short term

Magnitude Moderate- Low -

Probability (Definite, Possible, Unlikely) Unlikely Unlikely

Calculated Significance Rating (Low, Low Low Medium, High) Reversibility: (Reversible or Irreversible) Irreversible Irreplaceable loss of resources: (Yes or No) No Can impacts be enhanced: (Yes or No) No Residual impacts ❖ No residual impacts are anticipated. Mitigation measures ❖ To limit, as far as reasonably possible, additional pressure on existing infrastructure and services; ❖ To work in partnership with government, industry, and relevant organisations to enhance the existing infrastructure and services; ❖ To liaise openly and frequently with affected stakeholders to ensure they have information about the proposed Project; and ❖ To make available, maintain and effectively implement a grievance/complaint register that is easily accessible to all neighbours and affected stakeholders.

There is also a risk that residents in the area may be exposed to risks and hazards due to the proposed project. According to GDARD (2012), most MRAs have an element of lawlessness to them and should be considered as badlands where state penetration is minimal. The absence of security results in theft of equipment and the damage of infrastructure required to mitigate the negative impacts of MRAs. Dust control equipment such as sprayers and pumps are often stolen, which reverts back to environmental issues; while copper theft in the MRAs. These issues pose safety risks for law enforcement, affected land owners and adjacent communities.

Table 10-25: Impacts on safety NATURE OF THE IMPACT: Safety impacts Impact Rating Without Impact Rating With

Mitigation Mitigation Impact Status: Negative Negative

Extent Local Local

Duration Short term Short term

Magnitude Moderate - Low

Probability Possible Possible

Calculated Significance Rating Low Low

Reversibility: Not applicable Irreplaceable loss of resources: Not applicable Can impacts be enhanced: No Residual impacts ❖ Increased perceptions of unsafety Mitigation measures ❖ Mine security patrols should monitor the perimeters of the project site thereby providing an increased security presence; ❖ Consult with the local police branch to establish standard operating procedures for the control and/or removal of loiterers; ❖ Work with local authorities and the police to prevent informal settlement development on the site; ❖ All project infrastructure should be contained in a secured area to prevent unauthorized access and potential health and safety risks; ❖ Develop an effective Grievance Register that can be monitored regularly.

individuals in close proximity to the proposed project area. The dust usually contains fine particulate matter, which can be inhaled, causing damage to lung tissues. The dust also potentially contains a number of hazardous substances that can result in chemical toxicity.

Table 10-26: Impacts on health NATURE OF IMPACT: Increased dust levels and rise in associated health impacts Impact Rating Without Impact Rating With

Mitigation Mitigation Impact Status: (positive or negative) Negative Negative

Extent Local Local

Duration Short term Short Term

Magnitude Moderate- Minor -

Probability (Definite, Possible, Unlikely) Probable Probable

Calculated Significance Rating (Low, Medium Low Medium, High) Reversibility: (Reversible or Irreversible) Irreversible Irreplaceable loss of resources: (Yes or No) Yes Can impacts be enhanced: (Yes or No) No Residual impacts ❖ Compromised quality of life Mitigation measures ❖ Dust suppression techniques should be used to limit the amount of dust created during construction; ❖ It is also essential that continuous dust fallout monitoring (dust)be undertaken for the project; ❖ Make available, maintain and effectively implement a grievance/complaint register that is easily accessible to all neighbours and affected stakeholders; ❖ Liaise openly and frequently with affected stakeholders to ensure they have information about activities that will generate nuisance factors.

The construction of the proposed project will represent a significant intrusion into the surrounding physical environment, which could impact on surrounding communities in various ways.

Table 10-27: Impacts on sense of place NATURE OF IMPACT: Increased nuisance factors and changed sense of place Impact Rating Without Impact Rating With

Mitigation Mitigation Impact Status: (positive or negative) Negative Negative

Extent Local Local

Duration Short term Short Term

Magnitude Moderate- Minor -

Probability (Definite, Possible, Unlikely) Possible Possible

Calculated Significance Rating (Low, Medium, Low Low High) Reversibility: (Reversible or Irreversible) Irreversible Irreplaceable loss of resources: (Yes or No) Yes Can impacts be enhanced: (Yes or No) No Residual impacts ❖ Altered sense of place Mitigation measures ❖ Minimise all nuisance factors such as noise, air quality and implement all mitigation measures as specified in the EMPr; ❖ Make available, maintain and effectively implement a grievance/complaint register that is easily accessible to all neighbours and affected stakeholders; ❖ Liaise openly and frequently with affected stakeholders to ensure they have information about activities that will generate nuisance factors.

10.2.1.12 Radiation Table 10-28: Radioactivity impacts NATURE OF IMPACT: Impacts of radioactivity on human health Impact Rating Without Impact Rating With

Mitigation Mitigation Impact Status: (positive or negative) Negative Negative

Extent Local Local

Duration Short term Short term

Magnitude Major- Major-

Probability (Definite, Possible, Unlikely) Unlikely Unlikely

Calculated Significance Rating (Low, Medium, Low Low High) Reversibility: (Reversible or Irreversible) Reversible Irreplaceable loss of resources: (Yes or No) No Can impacts be enhanced: (Yes or No) No Residual impacts ❖ None Mitigation measures ❖ Obtain authorisation to work on the dumps. ❖ Ensure all staff are equipped with appropriate PPE where required.

10.2.2 Operational Phase

This section comprises of the description of potential impacts associated with the proposed operation of the mine on the biophysical, socio-economic and heritage and cultural environment. These descriptions are followed by the impact tables which contain the assessment of the significance of each identified impact without, and then with mitigation measures.

10.2.2.1 Topography

The removal of the City Deep dumps will result in the re-establishment of the original topography of the area.

Table 10-29: Significance rating of operational impact. NATURE OF IMPACT: Removal of slimes dam due to the reclamation process resulting in re-establishment of original topography. Impact Rating Without Impact Rating With

Mitigation Mitigation Impact Status: (positive or negative) Positive Positive

Extent (Local, Regional, International) Site Site

Duration (Short term, Medium term, Long Long-Term Long-Term term)

Magnitude (Major, Moderate, Minor) Major Major

Probability (Definite, Possible, Unlikely) Definite Definite

Calculated Significance Rating (Low, Medium, High High High) Reversibility: (Reversible or Irreversible) Irreversible Irreplaceable loss of resources: (Yes or No) No Can impacts be enhanced: (Yes or No) Yes Residual impacts ❖ None foreseen Mitigation measures ❖ The removal of the TSF serves as the mitigation measure.

10.2.2.2 Soils, Land Use, Land Capability

No significant impacts are envisaged during the operational phase.

10.2.2.3 Biodiversity

The following potential impacts were considered on biodiversity (including flora and fauna) during the operational phase:

❖ Spread and/or establishment of alien and/or invasive species; ❖ Erosion and dust dispersal; ❖ Water runoff and acid mine drainage; ❖ Continued displacement, direct mortalities and disturbance of faunal community due to habitat loss and disturbances (such as dust and noise); and ❖ Infringement by humans into the few remaining natural grassland and wetlands areas, with associated impacts such as litter and introduction of diseases and feral species such as cats.

Table 10-30: Significance rating of operational impacts on Biodiversity. NATURE OF IMPACT 1: Re-mining of tailing facility could lead to erosion, noise and dust. NATURE OF IMPACT 2: Re-mining of tailing facility could lead to water and Acid Mine Drainage. Impact Rating Without Impact Rating With

Mitigation Mitigation Impact Status: (positive or negative) Negative Negative

Extent (Local, Regional, International) Site Site

Duration (Short term, Medium term, Long Long term Long term term)

Magnitude (Major, Moderate, Minor) Major Major

Probability (Definite, Possible, Unlikely) Definite Possible

Calculated Significance Rating (Low, High Medium Medium, High) Reversibility: (Reversible or Irreversible) Reversible Irreplaceable loss of resources: (Yes or No) No Can impacts be enhanced: (Yes or No) Yes Residual impacts ❖ Removal of the tailings facility will result in the elimination of the existing impacts on biodiversity. Mitigation measures ❖ Dust-reducing mitigation measures must be put in place and must be strictly adhered to. This includes wetting of exposed soft soil surfaces and not conducting activities on windy days which will increase the likelihood of dust being generated. ❖ The spread of Acid mine drainage must be restricted; ❖ Runoff of water must be limited by installing gabions and drainage systems.

Table 10-31: Significance rating of operational impacts on Flora. NATURE OF IMPACT: Re-mining of tailing facility could lead to the encroachment of alien invasive plant species Impact Rating Without Impact Rating With

Mitigation Mitigation Impact Status: (positive or negative) Negative Negative

Extent (Local, Regional, International) Site Site

Duration (Short term, Medium term, Long Long term Long term term)

Magnitude (Major, Moderate, Minor) Moderate Minor

Probability (Definite, Possible, Unlikely) Definite Possible

Calculated Significance Rating (Low, Medium Medium Medium, High) Reversibility: (Reversible or Irreversible) Reversible Irreplaceable loss of resources: (Yes or No) No Can impacts be enhanced: (Yes or No) Yes Residual impacts ❖ Removal of the tailings facility could result in encroachment of invasives on cleared areas. Mitigation measures ❖ Implementation of alien invasive plant management plan needs to be continued during operation to prevent the growth of invasives on cleared areas.

Table 10-32: Significance rating of operational impacts on Fauna. NATURE OF IMPACT: Re-mining of tailing facility could lead to the loss of species of conservation concern and their habitat

Impact Rating Without Impact Rating With

Mitigation Mitigation Impact Status: (positive or negative) Negative Negative

Extent (Local, Regional, International) Site Site

Duration (Short term, Medium term, Long Long term Long term term)

Magnitude (Major, Moderate, Minor) Moderate Minor

Probability (Definite, Possible, Unlikely) Definite Possible

10.2.2.4 Wetlands

Table 10-33: Construction Phase Impacts on Wetlands

activity

Without With Activity Aspect Impact Mitigation Measures

Biota Mitigation Mitigation

Severity

Duration

Detection

Likelihood

Legal Issues Legal

Significance

Spatial scale Spatial

Flow Regime Flow

Consequence

(Water Quality) (Water

and Vegetation) and

Habitat (Geomorph (Geomorph Habitat

Frequency of impact of Frequency

Frequency of of Frequency Physico and Chemical Chemical and Physico

❖ Impeding hydrology; ❖ Siltation of channels and ❖ All reclamation activities and supporting aspects (i.e. laydown wetlands; areas, ablutions etc) must be located within the existing Sedimentation ❖ of Erosion of channels 3 4 3 3 3,25 3 3 9,25 3 4 5 3 10 92.5 Moderate Low footprint area of the dumps being reclaimed; Watercourses and wetlands; ❖ Vegetation along the edges of the dumps (where reclamation ❖ Loss of indigenous is not active) should be left as is, and only be removed when vegetation; the rest of the dump has been reclaimed; ❖ Direct loss of ❖ All soils compacted in the wetland area as a result of Reclamation of wetland areas; operational activities should be ripped (two directions), the City Deep ❖ Decrease in profiled and a seed-mix applied for re-vegetation of the area; Dumps functionality; ❖ All reclamation activities and access must make use of the ❖ Additional water existing access routes as much as possible. The number of quality access routes and working areas must be minimised, and the impairment; footprint area of these must be reduced and demarcated; and ❖ Altering ❖ Paddocks will be built around the City Deep dumps for any Spills and 2 3 2 2 2,25 3 3 8,25 2 4 5 2 8 66 Moderate Low Leaks hydromorphic unwanted spillages from the reclamation process. This will soils; ensure that tailings material does not end up in the ❖ Drainage patterns surrounding watercourses. change; and ❖ Altering overland flow characteristics ❖ A spill response plan and measures to be in place and on Operation of the ❖ Contamination of Spills and standby. The incident must be reported on and if necessary a proposed sediments and 2 3 2 2 2,25 3 3 8,25 2 4 5 2 8 66 Moderate Low Leaks wetland specialist must investigate the extent of the impact pipeline water resources. and provide rehabilitation recommendations.

10.2.2.5 Surface Water

During the operational phase, hydraulic reclamation will take place, whereby water cannons are used to convert the dry tailings on the dumps into slurry, which will flow in open channels downslope to a slurry sump, located at the lowest point of the site. The slurry will then be pumped and will ultimately end up at the Ergo Plant where it will be processed.

The activities and impacts that could potentially occur during the operational phase are summarised in Table 10-34.

Table 10-34: Summary of activities and impacts for the operational phase Activity Impact Description Uncontrolled runoff from hydraulic reclamation Impact 1: Slurry runoff into the downslope stream activities and flooding of the site due to high rainfall. impacting on water quality and sedimentation. Impact 2: Silted channels, slurry sump and emergency control dams, as well as eroded berms, leading to Poor maintenance of stormwater infrastructure. spills into the downslope streams impacting on water quality and sedimentation.

The ratings and proposed mitigation measures for the impact indicated in Table 10-34, are indicated in Table 10-35.

Table 10-35: Significance rating of operational impact 1 NATURE OF IMPACT 1: Slurry runoff from hydraulic reclamation activities and high rainfall have the potential to impact on water quality and sedimentation of the downslope streams Impact Rating without Impact Rating with Mitigation Mitigation Impact Status: (positive or negative) Negative Negative Extent (Local, Regional, International) Regional Local

Duration (Short term, Medium term, Long Medium term (operational Medium term (operational term) phase) phase) Magnitude (Major, Moderate, Minor) Major Minor

Probability (Definite, Possible, Unlikely) Definite Possible

Calculated Significance Rating (Low, Medium, Medium Low High)

NATURE OF IMPACT 1: Slurry runoff from hydraulic reclamation activities and high rainfall have the potential to impact on water quality and sedimentation of the downslope streams Mitigation measures ❖ Implementation of the proposed Surface Water Management Plan (SWMP) detailed in the EMPr. It must be ensured that the stormwater system is designed, constructed and operated, to ensure that it does not spill more than once in 50 years, to be compliant with GN R704 Regulations.

Table 10-36: Significance rating of operational impact 2 NATURE OF IMPACT 2: Poor maintenance of the berms, channels, slurry sump and emergency control dams, leading to runoff of slurry into the downslope streams, impacting on water quality and sedimentation Impact Rating without Impact Rating with Mitigation Mitigation Impact Status: (positive or negative) Negative Negative Extent (Local, Regional, International) Regional Local

Duration (Short term, Medium term, Long term) Medium term (operational Medium term (operational phase) phase) Magnitude (Major, Moderate, Minor) Major Minor

Probability (Definite, Possible, Unlikely) Definite Possible

Calculated Significance Rating (Low, Medium, Medium Low High)

Reversibility: (Reversible or Irreversible) Irreversible Irreplaceable loss of resources: (Yes or No) No Can impacts be enhanced: (Yes or No) Yes Residual impacts ❖ None, as the impact will cease after the operational phase. Mitigation measures ❖ Implementation of the stormwater monitoring system as detailed in the EMPr.

10.2.2.6 Groundwater

Groundwater Quality

Historically the sources of pollution associated with slimes dumps and tailings facilities include:

❖ Contaminated storm water runoff; ❖ Seepage water from the dump, possibly containing high sulphates and metals; and ❖ Recharge of contaminated water by means of seepage from the dumps/TSF and any unlined storm water channels.

Groundwater quality will be negatively affected with the formation of AMD during the reclamation activities. The old tailings material contains pyrite minerals and when exposed to oxygen and water during

reclamation it results in the formation of acidic conditions. The risk of groundwater contamination during the hydraulic mining will be low in view of the existing impacts, as long as the surface water management and containment guidelines are followed during the reclamation process.

The sulphate plume in the subsurface is generally limited to the weathered zone and will extend in a south-easterly direction. The concentration of pollutants will decrease as it moves further away from the site due to dispersion and dilution. Removal of the dump should however have a long-term positive impact on the groundwater quality, as the source of contamination is removed.

Monitoring of groundwater quality and water levels is recommended (up- and downgradient of the TSF) with continuous review and updating of the monitoring network based on the monitoring results.

Table 10-37: Operational Phase water quality impacts NATURE OF THE IMPACT: Groundwater pollution during reclamation as result of AMD water seeping into the aquifers Impact Rating Without Impact Rating with Mitigation Mitigation Impact Status: (positive or negative) Negative Negative Extent (Local, Regional, International) Local Local

Duration (Short term, Medium term, Long term) Long term Long term

Magnitude (Major, Moderate, Minor) Major - Minor -

Probability (Definite, Possible, Unlikely) Possible Possible

Calculated Significance Rating (Low, Medium, High) High Medium

Reversibility: (Reversible or Irreversible) Reversable Irreplaceable loss of resources: (Yes or No) No Cumulative impacts (yes or no) Yes. Combined impact associated with 4L3, 4L4 and 4L6 TSFs. Mitigation measures

❖ Maintain sound surface runoff management to ensure that all dirty runoff is contained and diverted to paddocks. Ensure no pooling of water on reclaimed surfaces occurs. ❖ Monitor groundwater quality in all boreholes identified. ❖ Should monitoring results indicate a loss of groundwater to private users, Ergo must supply the user with an equal water resource. ❖ Ensure that the paddocks can contain all dirty water generated during the reclamation process to prevent overflows and spillages.

Groundwater Quantity

The proposed dump reclamation will not have any significant impacts on the groundwater quantity. The reclamation activities will be driven by water jetting. Large volumes of water are used in the process.

There is a possibility that water will seep into the underlaying formations, but the additional recharge should be neglectable and should have no impact on the groundwater table elevation. The proposed monitoring boreholes must be used to monitor groundwater level fluctuations over time.

The seepage rate from the TSF is expected to increase and reach a maximum when it is fully operational.

10.2.2.7 Air Quality

The results of the modelling indicate that dustfall caused by the City Deep dump reclamation process, for the most part, does not approach the national dustfall regulation of between 600 and 1 200 mg/m2/day for non-residential areas nor the 600 mg/m2/day limit for residential areas, averaged over a month. Only dustfall from mining on the west side of 4L3 producedmonthly exceedances of the non-residential limit at Receptor 2 and this was only for two months (May and July of 2015) in the three-year period modelled.

Table 10-38: Impact Assessment: Operational Activities NATURE OF THE IMPACT: Stripping of vegetation from the surface of TSFs causes the emission of particulate

matter into the air, thus increasing existing ambient air concentrations of criteria pollutants (both PM10 and PM2.5) at receptors.

PM10 ❖ 24-hour Average Concentrations: National Ambient Air Quality Standard of 75µg/m3 ❖ Annual Average Concentrations: National Ambient Air Quality Standard of 40µg/m3 Acceptable rating level PM2.5 ❖ 24-hour Average Concentrations: National Ambient Air Quality Standard of 40µg/m3 ❖ Annual Average Concentrations: National Ambient Air Quality Standard of 20µg/m3 Impact Rating Without Mitigation Impact Rating with Mitigation Impact Status: (positive or Negative Negative negative) Moderate negative: Although the Moderate negative: Although the reclamation of the dumps is reclamation of the dumps is expected to expected to cause exceedances of Magnitude cause exceedances of the PM10 NAAQS, the PM10 NAAQS, the undisturbed the undisturbed dumps are already dumps are already significant significant emission sources. emission sources. Medium Term: This phase of the Medium Term: The project is planned to Duration project is planned to take 5 years. take 5 years. Local: Worst-case conditions may Local: Worst-case conditions may lead to lead to the NAAQS being exceeded the NAAQS being exceeded over Spatial Scale over approximately 850 m from the approximately 850 m from the project project footprint. footprint. Probable: The undisturbed dumps are Definite. The undisturbed dumps are Probability already emitting PM. With wet already emitting PM. suppression, the annual average NAAQS

are not exceeded. However, this does not take cumulative concentrations into account. Significance of Air Quality Medium Medium Impact

Reversibility: (Reversible or Reversible Irreversible)

Irreplaceable loss of No resources: (Yes or No) Mitigation measures ❖ Restriction of the stripped band to a width of 15 metres; ❖ Wet suppression of the 15-m-wide band stripped for reclamation or restriction of the length of the stripped band to 200 m; Mitigation ❖ Strict speed control of 20km/hr on all on-site roads; ❖ Restriction of the use of storage piles; ❖ Removing all tailings material down to ‘red earth’ as the area of work progresses, and not leaving remnants of tailings material behind which could be exposed to wind erosion. Emissions from the reclamation of the City Deep dumps are predicted to only

produce a limited increase in ambient concentrations of PM10 and PM2.5. In the Cumulative Impact long term, removal of the dumps will ameliorate the air quality of the surrounding areas.

10.2.2.8 Noise

There are no potential noise-sensitive receptors within 200m from the area where hydraulic mining activities may take place. It is the opinion of the specialist that there exists a low potential for a noise impact and that no further acoustical studies (with regards to operational noises) would be required.

Table 10-39: Impact Assessment: Operational Activities during the day NATURE OF THE IMPACT 1: Increased total noise levels in the area during the day, changing existing ambient sound levels at receptors. Industrial noise district. Acceptable Rating Level Use LReq,D of 45 dBA Impact Rating Without Impact Rating with

Daytime noise levels will be less than the acceptable noise rating level for Magnitude (Major, Moderate, Minor) an industrial area. Minor negative Ambient sound levels could be low at times and the activities may be Probability (Definite, Possible, Unlikely) audible but it will not be disturbing. Unlikely Calculated Significance Rating (Low, Low Medium, High) Reversibility: (Reversible or Irreversible) Yes Irreplaceable loss of resources: (Yes or No) No

Cumulative impacts (yes or no) No Mitigation measures ❖ Significance of the noise impact is Low and no additional mitigation measures are required.

Table 10-40: Impact Assessment: Operational Activities at night NATURE OF THE IMPACT 1: Increased total noise levels in the area during the day, changing existing ambient sound levels at receptors. Industrial noise district. Acceptable Rating Level Use LReq,D of 45 dBA Impact Rating Without Impact Rating with

Mitigation Mitigation Impact Status: (positive or negative) Negative Negative The project will not impact on the ambient sound levels further than Extent (Local, Regional, International) 1,000 m from the activity at night. Site or Local Noise levels will be elevated for the Duration (Short term, Medium term, Long operational phase. term) Long Term Night time noise levels will be less than the acceptable noise rating level Magnitude (Major, Moderate, Minor) No mitigation required. for an industrial area. Minor negative Ambient sound levels could be low at times and the activities may be Probability (Definite, Possible, Unlikely) audible but it will not be disturbing. Unlikely Calculated Significance Rating (Low, Low Medium, High) Reversibility: (Reversible or Irreversible) Yes

Irreplaceable loss of resources: (Yes or No) No

Cumulative impacts (yes or no) No Mitigation measures ❖ Significance of the noise impact is Low and no additional mitigation measures are required.

10.2.2.9 Visual

The impacts anticipated during the operational phase are listed in Table 10-41 below.

Table 10-41: Potential Visual operational Impacts Activity Negative Impact Positive Impact Removal of stockpiled Removal of visually intrusive material material/stockpiles Constructed pipes for Increased visual intrusion Minimised amount of traffic opposed to the transportation of truck hauling material Hydraulic mining Increase visual intrusion of related Removal of visually intrusive slime dumps activities infrastructure and increased noise disturbance Removal of stockpiled Loss in topography Removal of visually intrusive slime dumps material Removal of stockpiled Change in current landscape Increased area for development material Removal of stockpiled Dust generation Removal of visually intrusive slime dumps material

Table 10-42: Significance rating of operational impact 1. NATURE OF IMPACT 1: Dust generation due to the reclamation process. Impact Rating Without Impact Rating With

Mitigation Mitigation Impact Status: (positive or negative) Negative Negative

Extent (Local, Regional, International) Site Site

Duration (Short term, Medium term, Long Long-Term Long-Term term)

Magnitude (Major, Moderate, Minor) Moderate Minor

Probability (Definite, Possible, Unlikely) Definite Possible

Calculated Significance Rating (Low, Medium, Medium Medium High) Reversibility: (Reversible or Irreversible) Reversible Irreplaceable loss of resources: (Yes or No) No

Can impacts be enhanced: (Yes or No) Yes Residual impacts ❖ None foreseen Mitigation measures ❖ Ensure that dust suppression occurs on all dirt surfaces.

Table 10-43: Significance rating of operational impact 2. NATURE OF IMPACT 2: Removal of slimes dam due to the reclamation process resulting in positive visual impacts. Impact Rating Without Impact Rating With

Mitigation Mitigation Impact Status: (positive or negative) Positive Positive

Extent (Local, Regional, International) Site Site

Duration (Short term, Medium term, Long Long-Term Long-Term term)

Magnitude (Major, Moderate, Minor) Major Major

Probability (Definite, Possible, Unlikely) Definite Definite

Calculated Significance Rating (Low, Medium, High High High) Reversibility: (Reversible or Irreversible) Reversible Irreplaceable loss of resources: (Yes or No) No Can impacts be enhanced: (Yes or No) Yes Residual impacts ❖ None foreseen Mitigation measures ❖ The removal of the TSF serves as the visual mitigation measure.

Table 10-44: Significance rating of operational impact 3. NATURE OF IMPACT 3: Removal of slimes dam due to the reclamation process resulting in re-establishment of original topography. Impact Rating Without Impact Rating With

Mitigation Mitigation Impact Status: (positive or negative) Positive Positive

Extent (Local, Regional, International) Site Site

Duration (Short term, Medium term, Long Long-Term Long-Term term)

Magnitude (Major, Moderate, Minor) Major Major

Probability (Definite, Possible, Unlikely) Definite Definite

10.2.2.10 Heritage and Palaeontology

There are no anticipated impacts on heritage sites during the operational phase of the Project.

Table 10-45: Impacts on heritage sites NATURE OF THE IMPACT 1: Impacts on the heritage sites Impact Rating Without Mitigation Impact Rating with Mitigation Impact Status: Negative Negative

Extent Local Local

Duration Long term Long term

Magnitude Minor - Minor -

Probability Unlikely Unlikely

Calculated Significance Rating Low Low

Reversibility: Not applicable Irreplaceable loss of resources: Not applicable Can impacts be enhanced: Yes Cumulative impact: No Residual impacts ❖ None.

Mitigation measures ❖ Maintain 20m buffer around site.

10.2.2.11 Socio-Economic

It should be taken into account that with high unemployment rate within the project area, there are expectations regarding employment opportunities. Questions regarding employment opportunities were raised during consultations with surrounding community members.

Table 10-46: Impacts on Job security NATURE OF THE IMPACT: Job security and skills development Impact Rating Without Impact Rating with

Mitigation Mitigation Impact Status: Positive Positive

Extent Local Local

Duration Long term Long term

Magnitude Moderate + Major +

Probability Definite Possible

Calculated Significance Rating Medium High

Reversibility: Not applicable Irreplaceable loss of resources: Not applicable Can impacts be enhanced: Yes Residual impacts ❖ The residual impacts associated with the creation of employment and business opportunities and training during the construction phase is that the workers can improve their skills by gaining more experience; ❖ Improved economic development; ❖ Increased capacity to develop and maintain livelihood strategies. Mitigation measures ❖ Establish targets for employment and training; ❖ Effective implementation of training and skills development initiatives.

these contracts will be for specialist goods and services, which will be provided by businesses within the project area. Procuring of specialist goods and services will likely generate more opportunities for Small, Medium and Micro sized Enterprises (SMMEs), provided they meet the procurement requirements as set out by the mine.

The proposed project will contribute to the supply of gold to the local and national markets, and therefore contribution to local, provincial and national economy.

Table 10-47: Impacts on economic growth NATURE OF THE IMPACT: Stimulation of economic growth Impact Rating Without Impact Rating with Mitigation Mitigation Impact Status: (positive or negative) Positive Positive

Extent Local Local

Duration Long term Long term

Magnitude Moderate + Major +

Probability Possible Definite

Calculated Significance Rating (Low, Low High Medium, High) Reversibility: (Reversible or Irreversible) Not applicable Irreplaceable loss of resources: (Yes or No) Not applicable Can impacts be enhanced: (Yes or No) Yes Residual impacts ❖ Local suppliers will have gained experience and exposure to meeting standards of quality and scale that could be transferrable to business opportunities Mitigation measures ❖ As per the existing SLP, preference should be given to capable SMMEs who are based within the local municipal area; and ❖ Consider measures recommended to maximise benefits from local employment, skills and economic development.

Table 10-48: Impacts on municipal services NATURE OF THE IMPACT: Increased pressure on municipal services Impact Rating Without Impact Rating With

Mitigation Mitigation

Impact Status: (positive or negative) Negative Negative

Extent Local Local

Duration Medium term Short term

Magnitude Moderate- Low -

Probability (Definite, Possible, Unlikely) Unlikely Unlikely

Calculated Significance Rating (Low, Low Low Medium, High) Reversibility: (Reversible or Irreversible) Reversible Irreplaceable loss of resources: (Yes or No) No Can impacts be enhanced: (Yes or No) No Residual impacts ❖ No residual impacts are anticipated. Mitigation measures ❖ To limit, as far as reasonably possible, additional pressure on existing infrastructure and services; ❖ To work in partnership with government, industry, and relevant organisations to enhance the existing infrastructure and services; ❖ To liaise openly and frequently with affected stakeholders to ensure they have information about the proposed Project; and ❖ To make available, maintain and effectively implement a grievance/complaint register that is easily accessible to all neighbours and affected stakeholders.

There is also a risk that residents in the area may be exposed to risks and hazards due to the proposed project. According to GDARD (2012), most Mine Residue Areas have an element of lawlessness to them and should be considered as badlands where state penetration is minimal. The absence of security results in theft of equipment and the damage of infrastructure required to mitigate the negative impacts of MRAs. Dust control equipment such as sprayers and pumps are often stolen, which reverts back to environmental issues; while copper theft in the MRAs. These issues pose safety risks for law enforcement, affected land owners and adjacent communities.

Table 10-49: Impacts on safety NATURE OF THE IMPACT: Safety impacts Impact Rating Without Impact Rating with Mitigation Mitigation Impact Status: Negative Negative

Extent Local Local

Duration Long term Long term

Magnitude Moderate - Minor-

Probability Possible Definite

Calculated Significance Rating Medium Medium

Reversibility: Not applicable Irreplaceable loss of resources: Not applicable Can impacts be enhanced: No Residual impacts ❖ Increased perceptions of unsafety Mitigation measures ❖ Mine security patrols should monitor the perimeters of the project site thereby providing an increased security presence; ❖ Consult with the local police branch to establish standard operating procedures for the control and/or removal of loiterers; ❖ Work with local authorities and the police to prevent informal settlement development on private land; ❖ All project infrastructure should be contained in a walled and secured area to prevent unauthorized access and potential health and safety risks; ❖ Develop an effective Grievance Register that can be monitored regularly.

Table 10-50: Impacts on health NATURE OF IMPACT: increased dust levels and rise in associated health impacts

Impact Rating Without Impact Rating With

Mitigation Mitigation

Impact Status: (positive or negative) Negative Negative

Duration Medium term Medium term

Magnitude Moderate- Minor -

Probability (Definite, Possible, Unlikely) Definite Possible

Calculated Significance Rating (Low, Medium Low Medium, High) Reversibility: (Reversible or Irreversible) Irreversible Irreplaceable loss of resources: (Yes or No) Yes Can impacts be enhanced: (Yes or No) No Residual impacts ❖ Compromised quality of life Mitigation measures ❖ Implement effective dust suppression techniques; ❖ It is also essential that dust fallout monitoring must be undertaken for the project. ❖ Make available, maintain and effectively implement a grievance/complaint register that is easily accessible to all neighbours and affected stakeholders; ❖ Liaise openly and frequently with affected stakeholders to ensure they have information about activities that will generate nuisance factors.

The removal of the dumps by means of reclamation process has a positive benefit as the removal of the slimes dams would result in the removal of a water, land and dust pollution source. Although it is perceived a positive benefit, it will represent a significant intrusion into the surrounding physical environment, which could impact on surrounding communities in various ways. The reclamation process might pose negative impacts that change how surrounding communities or business institution perceive their area. For instance the proposed project might increase air pollution and there might be additional vehicles which can be perceived as a nuisance factor.

Table 10-51: Impacts on sense of place NATURE OF IMPACT: Increased nuisance factors and changed sense of place Impact Rating Without Impact Rating With

Mitigation Mitigation Impact Status: (positive or negative) Negative Negative

Extent Local Local

Duration Long term Long term

Magnitude Medium- Minor -

Probability Possible Possible

Calculated Significance Rating (Low, Medium Low Medium, High) Reversibility: (Reversible or Irreversible) Irreversible Irreplaceable loss of resources: (Yes or No) Yes Can impacts be enhanced: (Yes or No) No Residual impacts ❖ Altered sense of place. Mitigation measures ❖ To minimise all nuisance factors such as noise, air quality. ❖ Implement all mitigation measures as specified in the EMPr; ❖ To make available, maintain and effectively implement a grievance/complaint register that is easily accessible to all neighbours and affected stakeholders; ❖ To liaise openly and frequently with affected stakeholders to ensure they have information about activities that will generate nuisance factors.

10.2.2.12 Radioactivity Table 10-52: Radioactivity impacts NATURE OF IMPACT: Impacts of radioactivity on human health Impact Rating Without Impact Rating With

Mitigation Mitigation Impact Status: (positive or negative) Negative Negative

Extent Local Local

Duration Long term Long term

Magnitude Major- Major-

Probability (Definite, Possible, Unlikely) Unlikely Unlikely

Calculated Significance Rating (Low, Medium, Medium Medium High) Reversibility: (Reversible or Irreversible) Irreversible Irreplaceable loss of resources: (Yes or No) No Can impacts be enhanced: (Yes or No) No Residual impacts ❖ None Mitigation measures ❖ Ensure all staff are equipped with appropriate PPE. ❖ Undertake any health test as required by the NNR.

10.2.3 Closure and Decommissioning Phase

This section comprises of the description of potential impacts associated with the closure, decommissioning and rehabilitation activities on the biophysical, socio-economic and heritage and cultural environment. These descriptions are followed by the impact tables which contain the assessment of the significance of each identified impact without, then with mitigation measures.

10.2.3.1 Topography

No significant negative impacts are envisaged during the Closure and Decommissioning Phase. The natural topography of the site will be re-established and the land will become available for more functional uses, such as industry.

Table 10-53: Significance rating of closure and decommissioning impacts on topography. NATURE OF IMPACT 1: There-establishment of the original topography. Impact Rating without Impact Rating with Mitigation Mitigation Impact Status: (positive or negative) Positive Positive Extent (Local, Regional, International) Local Local

Duration (Short term, Medium term, Long term) Long term Long term

Magnitude (Major, Moderate, Minor) Minor Major

Probability (Definite, Possible, Unlikely) Possible Definite

Calculated Significance Rating (Low, Medium, Medium High High)

Reversibility: (Reversible or Irreversible) Yes Irreplaceable loss of resources: (Yes or No) No Can impacts be enhanced: (Yes or No) Yes Residual impacts ❖ None foreseen Mitigation measures ❖ Rehabilitation that must ensure that the site is sloped for its final end use (at present industrial). ❖ Erosion prevention measures must be maintained.

10.2.3.2 Soils, Land Use, Land Capability

No significant negative impacts are envisaged during the Closure and Decommissioning Phase.

10.2.3.3 Biodiversity

The following potential impacts were considered on biodiversity (including flora and fauna):

❖ Further impacts due to the spread and/or establishment of alien and/or invasive species; ❖ If rehabilitation is not done correctly erosion and dust dispersal is a major impact as it can result in habitat loss as well as impact the growth and health of both fauna and flora.

Table 10-54: Significance rating of closure impacts on Biodiversity. NATURE OF IMPACT 1: Decommissioning activities could lead to the loss of habitat and impact on the growth and health of both fauna and flora Impact Rating Without Impact Rating With

Mitigation Mitigation Impact Status: (positive or negative) Negative Negative

Extent (Local, Regional, International) Local Local

Duration (Short term, Medium term, Long Medium term Medium term term)

Magnitude (Major, Moderate, Minor) Moderate Minor

Probability (Definite, Possible, Unlikely) Definite Definite

Calculated Significance Rating (Low, Medium, Medium Medium High) Reversibility: (Reversible or Irreversible) Reversible Irreplaceable loss of resources: (Yes or No) No Can impacts be enhanced: (Yes or No) Yes Residual impacts ❖ No residual impacts are anticipated. Mitigation measures ❖ Dust-reducing mitigation measures must be put in place and must be strictly adhered to. ❖ This includes wetting of exposed soft soil surfaces and not conducting activities on windy days which will increase the likelihood of dust being generated.

Table 10-55: Significance rating of closure impacts on Flora. NATURE OF IMPACT: Decommissioning activities could lead to revegetation of the area after removal of infrastructure and encroachment of alien invasive plant species Impact Rating Without Impact Rating With

Mitigation Mitigation Impact Status: (positive or negative) Negative Negative

Extent (Local, Regional, International) Local Local

Duration (Short term, Medium term, Long Long term Medium term term)

NATURE OF IMPACT: Decommissioning activities could lead to revegetation of the area after removal of infrastructure and encroachment of alien invasive plant species

Magnitude (Major, Moderate, Minor) Moderate Minor

Probability (Definite, Possible, Unlikely) Definite Possible

Calculated Significance Rating (Low, Medium, Medium Low High) Reversibility: (Reversible or Irreversible) Reversible Irreplaceable loss of resources: (Yes or No) No Can impacts be enhanced: (Yes or No) Yes Residual impacts ❖ No residual impacts are anticipated. Mitigation measures ❖ Implementation of alien invasive plant management plan needs to be continued during decommissioning to prevent the growth of invasives on rehabilitated areas; ❖ Rehabilitation of site with indigenous vegetation that occurs in the vicinity of project area.

Table 10-56: Significance rating of closure impacts on Fauna. NATURE OF IMPACT: Decommissioning activities could lead to a loss of species of conservation concern Impact Rating Without Impact Rating With

Mitigation Mitigation Impact Status: (positive or negative) Negative Negative

Extent (Local, Regional, International) Local Local

Duration (Short term, Medium term, Long Medium term Medium term term)

Magnitude (Major, Moderate, Minor) Moderate Minor

Probability (Definite, Possible, Unlikely) Definite Possible

Calculated Significance Rating (Low, Medium, Medium Low High) Reversibility: (Reversible or Irreversible) Reversible Irreplaceable loss of resources: (Yes or No) No Can impacts be enhanced: (Yes or No) Yes Residual impacts ❖ None Mitigation measures ❖ All infrastructure that could have a negative impact on faunal species (powerlines etc) needs to be decommissioned and removed.

10.2.3.4 Wetlands

Table 10-57: Closure Phase Impacts on Wetlands

Without With Activity Aspect Impact Mitigation Measures

Biota Mitigation Mitigation

Severity

Duration

Detection

Likelihood

Legal Issues Legal

Significance

Spatial scale Spatial

Flow Regime Flow

Consequence

(Water Quality) (Water

and Vegetation) and

Habitat (Geomorph (Geomorph Habitat

Frequency of impact of Frequency

Frequency of activity of Frequency Physico and Chemical Chemical and Physico

❖ Impeding hydrology; ❖ Siltation of channels and Vehicles, wetlands; machines ❖ and Erosion of channels 2 2 2 3 2,25 2 2 6,25 2 2 5 2 11 68,75 Moderate Low equipment and wetlands; in use ❖ Loss of indigenous vegetation; ❖ All decommissioning activities and access must make use of ❖ Direct loss of the existing access routes as much as possible. The number of wetland areas; access routes and working areas must be minimised, and the Decommissioning ❖ Decrease in of the proposed footprint area of these must be reduced and demarcated; functionality; pipeline ❖ Temporary stormwater channels should be filled with ❖ Additional water aggregate and/or logs (branches included) to dissipate flows. quality

impairment; Removal of ❖ Altering the pipeline hydromorphic 3 2 2 2 2,25 2 2 6,25 2 3 1 3 9 56,25 Moderate Low (including soils; excavations) ❖ Drainage patterns change; and ❖ Altering overland flow characteristics.

10.2.3.5 Surface Water

It is likely that the sites will be commercially developed once all tailings material has been removed. The activities and impacts that are likely to occur during the closure and rehabilitation phase are summarised in Table 10-58.

Table 10-58: Summary of activities and impacts for the closure phase Activity Impact Description Impact 1: Erosion and consequent increase in TSS of Exposure of soil during the closure and rehabilitation surface water resources leading to deteriorated water phase, once all tailings material has been removed. quality

The ratings and proposed mitigation measures for the impact indicated in Table 10-58, are provided in Table 10-59.

Table 10-59: Significance rating of closure impact 1 NATURE OF IMPACT 1: The exposure of soil once all tailings material has been removed, has the potential to be washed into the downslope streams, impacting on water quality and sedimentation Impact Rating without Impact Rating with Mitigation Mitigation Impact Status: (positive or negative) Negative Negative Extent (Local, Regional, International) Regional Local

Duration (Short term, Medium term, Long term) Short term (less than 18 Short term (less than 18 months) months) Magnitude (Major, Moderate, Minor) Moderate Minor

Probability (Definite, Possible, Unlikely) Possible Possible

Calculated Significance Rating (Low, Medium, Medium Low High)

Reversibility: (Reversible or Irreversible) Irreversible Irreplaceable loss of resources: (Yes or No) No Can impacts be enhanced: (Yes or No) Yes Residual impacts • Possible, unless rehabilitated or commercially developed immediately. Mitigation measures • Stormwater management measures should be left in place until rehabilitation is complete, or until the site has been commercially developed with a specifically designed SWMP for the development; • Temporary erosion control measures that reduce flow velocity (e.g. paddocks and runoff berms) should be implemented at the site; and • Water quality monitoring must continue upstream and downstream until the sites have been fully rehabilitated or commercially developed.

10.2.3.6 Groundwater

Groundwater Quality

Groundwater quantity impacts will be improving as the source of contamination is removed (Table 10-60). The water table mound under the dumps footprint should start to level out. The impact as a result of the reclamation is anticipated to be positive after the dumps material has been removed.

Table 10-60: Decommissioning Phase water quality impacts. NATURE OF THE IMPACT: Water quality impacts when dump has been removed Impact Rating Without Impact Rating with Mitigation Mitigation Impact Status: (positive or negative) Positive Positive Extent (Local, Regional, International) Local Local

Duration (Short term, Medium term, Long Long term Long term term)

Magnitude (Major, Moderate, Minor) Minor + Moderate +

Probability (Definite, Possible, Unlikely) Possible Possible

Calculated Significance Rating (Low, Medium, High) Medium Medium

Reversibility: (Reversible or Irreversible) Reversable Irreplaceable loss of resources: (Yes or No) No Cumulative impacts (yes or no) Yes. Combined impact associated with 4L3, 4L4 and 4L6 TSFs.

Mitigation measures

❖ Monitor groundwater quality in all boreholes. ❖ Maintain sound surface runoff management to ensure that all dirty runoff is contained and diverted to the emergency control dams.

Groundwater Quantity

The proposed dump reclamation will not have any significant impacts on the groundwater quantity during decommissioning . The reclamation activities will have stopped and any form of seepage to the subsurface will reduce and ultimately stop, apart from precipitation.

10.2.3.7 Air Quality

Impacts expected to occur are the generation of nuisance dust during removal of the infrastructure and pipeline. It is proposed to establish a dust management plan in consultation with the environmental manager and include dust suppression as part of the contractor’s responsibility.

Table 10-61: Closure and Decommissioning Phase air quality impacts. NATURE OF THE IMPACT 1: Dust generated from removal of surface infrastructure and rehabilitation activities Impact Rating Without Impact Rating with

Mitigation Mitigation Impact Status: (positive or negative) Negative Negative

Extent (Local, Regional, International) Local Local

Duration (Short term, Medium term, Long Short term Short term term)

Magnitude (Major, Moderate, Minor) Minor - Minor -

Probability (Definite, Possible, Unlikely) Definite Possible

Calculated Significance Rating (Low, Medium Low Medium, High) Reversibility: (Reversible or Irreversible) Yes Irreplaceable loss of resources: (Yes or No) No

Cumulative impacts (yes or no) No Mitigation measures ❖ Strict speed control of 20km/hr on all on-site roads. ❖ Keep cleared surfaces humid when undertaking earth moving rehabilitation activities.

10.2.3.8 Noise

Noise disturbance to surrounding communities are expected to occur during demolition and rehabilitation activities. It is suggested that equipment be switched off when not in use. Demolition and rehabilitation activities should also be limited to daylight hours where possible.

Table 10-62: Closure and Decommissioning Phase noise impacts. NATURE OF THE IMPACT 1: Increased total noise levels in the area, changing existing ambient sound levels at receptors as a result of numerous simultaneous demolition and rehabilitation activities during the day Rural noise district. Acceptable Rating Level Use LReq,D of 45 dBA Impact Rating Without Impact Rating with

Short Term

Daytime noise levels will be less than the acceptable noise rating Magnitude (Major, Moderate, Minor) level for a rural area. Minor negative Ambient sound levels could be low at times and the activities may Probability (Definite, Possible, Unlikely) be audible but it will not be disturbing. Unlikely Calculated Significance Rating (Low, Low Medium, High) Reversibility: (Reversible or Irreversible) Reversible

10.2.3.9 Visual

The impacts anticipated during the closure phase are listed in Table 10-63: Potential Visual Closure Impacts below.

Table 10-63: Potential Visual Closure Impacts Activity Negative Impact Positive Impact Removal of Visual intrusion by working Removal of stockpiled material, Space for future infrastructure decommissioning machinery and development stockpiling of metal rubble before collection Rehabilitation Introduction of alien vegetation Sloping to return original topography (before the creation of the dump) where possible. Landform re-creation to meet land capability commitments.

Table 10-64: Significance rating of closure and decommissioning impact 1. NATURE OF IMPACT 1: Removal of equipment and site infrastructure. Impact Rating Without Impact Rating With

Mitigation Mitigation Impact Status: (positive or negative) Positive Positive

Extent (Local, Regional, International) Site Site

Duration (Short term, Medium term, Long Short-Term Long-Term term)

Magnitude (Major, Moderate, Minor) Major Major

Probability (Definite, Possible, Unlikely) Definite Definite

Calculated Significance Rating (Low, Medium, Medium High High) Reversibility: (Reversible or Irreversible) Reversible Irreplaceable loss of resources: (Yes or No) No Can impacts be enhanced: (Yes or No) Yes Residual impacts ❖ None foreseen Mitigation measures ❖ Ensure that all of the equipment is removed and the site is completely restored to red earth.

Table 10-65: Significance rating of closure and decommissioning impact 2. NATURE OF IMPACT 2: The reclamation process will result in the removal of the dumps and restore the site to red earth. Impact Rating Without Impact Rating With

Mitigation Mitigation Impact Status: (positive or negative) Positive Positive

Extent (Local, Regional, International) Site Site

Duration (Short term, Medium term, Long Short-Term Long-Term term)

Magnitude (Major, Moderate, Minor) Major Major

Probability (Definite, Possible, Unlikely) Definite Definite

During decommissioning, the identified heritage sites might be affected. The following recommendations are made for site CTY004:

❖ A minimum of a 20m buffer zone should be implemented around the site;

While site CTY003 will not be directly impacted by the removal of the pipeline, a 50m buffer should be maintained around the length of the dam as a deterrent.

Table 10-66: Impacts on heritage site CTY004 NATURE OF THE IMPACT 1: Possible destruction of heritage sites. The site comprises the remains of a stone walled structure combined with the remains of a stone walled kraal Impact Rating Without Impact Rating with

Mitigation Mitigation Impact Status: Negative Negative

Extent Local Local

Duration Long term Long term

Magnitude Minor - Minor -

Probability Definite Possible

Calculated Significance Rating Low Low

Table 10-67: Impacts on Rosherville dam wall NATURE OF THE IMPACT 2: Impacts on the Rosherville Dam Wall Impact Rating Without Impact Rating with

Mitigation Mitigation Impact Status: Negative Negative

Extent Local Local

Duration Long term Long term

Magnitude Major - Minor -

Probability Unlikely Unlikely

Calculated Significance Rating Medium Low

Reversibility: Not applicable Irreplaceable loss of resources: Not applicable

Can impacts be enhanced: Yes Cumulative impact: No Residual impacts ❖ None Mitigation measures ❖ Implement 50m buffer around site. ❖ If buffer zone cannot be maintained then appropriate mitigation measures will need to be implemented.

10.2.3.11 Socio-Economic

Closure will involve downscaling and retrenchment of the workforce over a number of years. Although there will be downscaling during this phase, some community members would have worked on the mine, and will constitute a reserve of trained workforce.

Table 10-68: Impact of closure and decommissioning on job security. NATURE OF THE IMPACT: Job security and skills development Impact Rating Without Impact Rating with Mitigation Mitigation Impact Status: Negative Negative

Extent Local Local

Duration Long term Long term

Magnitude Moderate + Major+

Probability Possible Definite

Calculated Significance Rating Medium Medium

Reversibility: Not applicable Irreplaceable loss of resources: Not applicable Can impacts be enhanced: No Residual impacts ❖ The residual impacts associated with the creation of employment and business opportunities and training during the operational phase is that it benefits the local economy; ❖ Acquired transferable skills that could potentially be used with other businesses Mitigation measures ❖ Offer a post retrenchment programme designed to equip those that have been retrenched with knowledge and skills. ❖ Move staff to the next reclamation project.

Closure of the Project is expected to reduce economic development and diversification. Some people will have increased capacity to continue to develop and maintain livelihood strategies while others may

struggle with the transition. Once the LED projects as per the approved SLP are implemented, this should contribute to cushioning the negative impacts of downscaling.

Table 10-69: Impact of closure and decommissioning on economic growth. NATURE OF THE IMPACT: Stimulation of economic growth Impact Rating Without Impact Rating with Mitigation Mitigation Impact Status: Positive Positive

Extent Local Local

Duration Short term Short term

Magnitude Moderate+ Major+

Probability Possible Definite

Calculated Significance Rating Medium Medium

Reversibility: Not applicable Irreplaceable loss of resources: Not applicable Can impacts be enhanced: No Residual impacts ❖ Developed economy; ❖ Increased capacity to develop and maintain livelihood strategies Mitigation measures ❖ Maximise benefits from local skills and economic development; ❖ Consider partnering with local government to work together and set common goals and objectives for the communities; ❖ Ensure that LED projects included in the SLP are sustainable post mining operations-this should reduce the negative impacts post mine closure. ❖ Move staff to the next reclamation project.

Even though there is a low probability of it resulting in severe negative impacts, pro-active mitigation measures should be implemented to address the issue and to avoid possible long term negative impacts such as potential job seekers remaining in the area putting additional pressure on the local infrastructure and services.

Table 10-70: Impact of closure and decommissioning on municipal services. NATURE OF THE IMPACT: Increased pressure on municipal services Impact Rating Without Impact Rating With

Mitigation Mitigation Impact Status: (positive or negative) Negative Negative

Extent Local Local

Duration term Short term

Magnitude Moderate- Low -

Probability (Definite, Possible, Unlikely) Unlikely Unlikely

Calculated Significance Rating (Low, Low Low Medium, High) Reversibility: (Reversible or Irreversible) Partly reversible Irreplaceable loss of resources: (Yes or No) No Can impacts be enhanced: (Yes or No) No Residual impacts ❖ Strain on the existing infrastructure which is already inadequate. Mitigation measures ❖ To limit, as far as reasonably possible, additional pressure on existing infrastructure and services; ❖ To work in partnership with government, industry, and relevant organisations to enhance the existing infrastructure and services; ❖ To liaise openly and frequently with affected stakeholders to ensure they have information about the proposed Project; and ❖ To make available, maintain and effectively implement a grievance/complaint register that is easily accessible to all neighbours and affected stakeholders.

From an environmental and social perspective, the proposed project is a positive impact. The benefit of reclamation projects would not only be to extract the additional economical value from the tailings, but the reclamation projects also provide a second opportunity to process the tailings more responsibly with regard to leaving behind a less toxic, more stable, smaller quantity of tailings whilst making the large areas of land available for use.

Table 10-71: Impact of closure and decommissioning on land use. NATURE OF THE IMPACT: Availability of alternative land uses Impact Rating Without Impact Rating with Mitigation Mitigation Impact Status: Positive Positive

Extent Local Local

Duration Long term Long term

Magnitude Minor + Major+

Probability Possible Definite

Calculated Significance Rating Medium High

Reversibility: Not applicable Irreplaceable loss of resources: Not applicable Can impacts be enhanced: No Residual impacts ❖ Availability of land for development purposes. Mitigation measures ❖ Once the reclamation process has been completed, the area must be rehabilitated and should be made available for alternative sustainable land uses. ❖ Affected parties should be consulted in terms of the agreed end land use.

There is also a risk that residents in the area may be exposed to risks and hazards due to the proposed project. According to GDARD (2012), most mine residue areas have an element of lawlessness to them and should be considered as badlands where state penetration is minimal. The absence of security results in theft of equipment and the damage of infrastructure required to mitigate the negative impacts of mine residue areas. Dust control equipment such as sprayers and pumps are often stolen, which reverts back to environmental issues; while copper theft in the mine residue areas. These issues pose safety risks for law enforcement, affected land owners and adjacent communities.

Table 10-72: Impact of closure and decommissioning on safety. NATURE OF THE IMPACT: Safety impacts Impact Rating Without Impact Rating with Mitigation Mitigation Impact Status: Negative Negative

Extent Local Local

Duration Short term Short term

Magnitude Moderate - Minor-

Probability Possible Definite

Calculated Significance Rating Low Low

Reversibility: Not applicable Irreplaceable loss of resources: Not applicable Can impacts be enhanced: No Residual impacts ❖ Increased perception of unsafety Mitigation measures ❖ Mine security patrols should monitor the perimeters of the project site thereby providing an increased security presence; ❖ Consult with the local police branch to establish standard operating procedures for the control and/or removal of loiterers; ❖ Work with local authorities and the police to prevent informal settlement development on private land; ❖ All project infrastructure should be contained in a walled and secured area to prevent unauthorized access and potential health and safety risks; ❖ Develop an effective Grievance Register that can be monitored regularly.

Once the operational phase has been completed, it is not anticipated that there will be any nuisance factors caused by the project.

10.2.3.12 Radioactivity

Linked to community health, is a concern regarding exposure to radiation and its impacts on human health. During public consultations, concerns with regards to exposure to high levels of radiation and the direct impact on human health was raised. According to existing data, it is not anticipated that there will be any radiation issues on the proposed project site. Ergo has previously conducted walk-over surveys and it was found that the radiation levels are low.

Table 10-73: Radioactivity impacts NATURE OF THE IMPACT: Radioactivity impacts Impact Rating Without Impact Rating with

Mitigation Mitigation Impact Status: Negative Negative

Extent Local Local

Duration short term Short term

Magnitude Major - Minor-

Probability Unlikely Unlikely

Calculated Significance Rating Low Low

Reversibility: Not applicable

Irreplaceable loss of resources: Not applicable Can impacts be enhanced: No Residual impacts ❖ Increased perception of unsafety Mitigation measures ❖ Ensure all tailings material is removed down to red earth. ❖ Test remaining material for radioactivity contamination. If radioactivity persists, remove further material.

10.2.4 Post closure Phase

10.2.4.1 Surface Water

It is unlikely that any negative impacts will occur as a result of reclamation after rehabilitation has taken place, or if the site is commercially developed. The removal of the tailings material is likely to result in a positive impact on the surrounding watercourses.

Table 10-74: Post Closure Phase water quality impacts NATURE OF THE IMPACT: Groundwater quality impacts after dump is removed Impact Rating Without Impact Rating with Mitigation Mitigation Impact Status: (positive or negative) Positive Positive Extent (Local, Regional, International) Local Local

Duration (Short term, Medium term, Long term) Long term Long term

Magnitude (Major, Moderate, Minor) Minor + Moderate +

Probability (Definite, Possible, Unlikely) Possible Possible

Calculated Significance Rating (Low, Medium, High) Medium High Reversibility: (Reversible or Irreversible) Reversable Irreplaceable loss of resources: (Yes or No) No Cumulative impacts (yes or no) Yes. Combined impact associated with 4L3, 4L4 and 4L6 TSFs. Mitigation measures

❖ Monitor surface water quality. ❖ Maintain sound surface runoff management to ensure that all dirty runoff is contained and diverted to the emergency control dam. No pooling of water on surface allowed.

10.2.4.2 Groundwater

Overall, there should be an improvement in the groundwater qualities post closure as the source of contamination will be removed (Table 10-75). Rehabilitation of the soil in the footprint area of the historical TSF is required to stabilise the pH and minimise infiltration of contaminated water.

Table 10-75: Post Closure Phase water quality impacts NATURE OF THE IMPACT: Groundwater quality impacts after dump is removed Impact Rating Without Impact Rating with Mitigation Mitigation Impact Status: (positive or negative) Positive Positive Extent (Local, Regional, International) Local Local

Duration (Short term, Medium term, Long term) Long term Long term

Magnitude (Major, Moderate, Minor) Minor + Moderate +

Probability (Definite, Possible, Unlikely) Possible Possible

❖ Monitor groundwater quality in all boreholes. ❖ Should monitoring results indicate a loss of groundwater to private user, Ergo must supply the user with an equal water resource. ❖ Maintain sound surface runoff management to ensure that all dirty runoff is contained and diverted to the emergency control dams. No pooling of water on surface allowed.

10.2.4.3 Air Quality

Overall, there should be an improvement in the air quality post closure as the source of contamination will be removed (Table 10-75). However, the area will be denuded and dust particles may still be generated.

Table 10-76: Post Closure Phase air quality impacts NATURE OF THE IMPACT: Air quality impacts after dump is removed Impact Rating Without Impact Rating with Mitigation Mitigation Impact Status: (positive or negative) Negative Negative Extent (Local, Regional, International) Local Local

Duration (Short term, Medium term, Long Short term Short term term)

Magnitude (Major, Moderate, Minor) Minor- Minor-

Probability (Definite, Possible, Unlikely) Possible Possible

Calculated Significance Rating (Low, Medium, Low Low High) Reversibility: (Reversible or Irreversible) Reversable Irreplaceable loss of resources: (Yes or No) No Cumulative impacts (yes or no) No Mitigation measures

❖ Monitor dust until site is handed over to landowner for development

10.2.5 Residual Impacts

Residual impacts refer to the net impacts after practicable mitigation, considering the background environmental conditions and impacts from existing and foreseeable future projects. Basically it is the environmental impact that remains with mitigation measures in place.

Potential residual impacts exist for the proposed project, and these are discussed herewith.

10.2.5.1 Topography

No significant residual impacts are envisaged.

10.2.5.2 Soils, Land Use, Land Capability

No significant closure and decommissioning residual impacts are envisaged on the soils land use and land capability. Land will be restored to agriculture, grazing or development land after closure.

10.2.5.3 Fauna and Flora

No significant residual impacts are envisaged. There is a risk of alien invasive vegetation encroaching on the cleared areas.

10.2.5.4 Wetlands

Incomplete removal of infrastructure and waste following mine closure could provide sources of pollutants leading to water quality deterioration. This will affect the downstream water users if not mitigated.

Complete removal of all infrastructure and waste must be ensured following mine closure.

10.2.5.5 Surface Water

Incomplete removal of infrastructure and tailings following mine closure could provide sources of pollutants leading to water quality deterioration. This will affect the downstream water users if not mitigated.

10.2.5.6 Groundwater

10.2.5.7 Air Quality

No significant residual impacts are envisaged.

10.2.5.8 Noise

No significant residual impacts are envisaged.

10.2.5.9 Visual

No significant residual impacts are envisaged.

10.2.5.10 Heritage and Palaeontology

No significant residual impacts are envisaged.

10.2.5.11 Socio-Economic

No significant residual impacts are envisaged.

10.2.6 Cumulative Impacts

A cumulative impact can be defined as an impact on the environment which results from the incremental impact of an action (i.e. mining) when added to other past, present and reasonably foreseeable future actions, regardless of who (i.e. private individual, government agency, industrial business, agricultural business, etc) undertakes such actions.

Cumulative impacts associated with this type of mining development could lead to initial, incremental or augmentation of existing types of environmental degradation, due to existing similar activities in the area, including impacts on the air, soil and water present within available habitat. Pollution of these elements might not always be immediately visible or readily quantifiable, but incremental or fractional increases might rise to levels where biological attributes could be affected adversely on a local or regional scale. In most cases are these effects are not bound but are dispersed, or diluted over an area that is much larger than the actual footprint of the causal factor. Similarly, developments in untransformed and pristine areas

are usually not characterised by visibly significant environmental degradation and these impacts are usually most prevalent in areas where continuous and long-term impacts have been experienced.

The nature of the development is such that pollution and degradation of the surrounding areas are expected to some extent, but this is incredibly difficult to quantify initially and will require monitoring and management throughout the life of the mine. Cumulative impacts are, for this very reason, assessed over the entire lifespan of the project operation. Since the cumulative impacts can occur at any point within any of the identified phases it is preferable to present them separately to understand what aspects will require monitoring and management throughout the life of the project as well as after successful closure and decommissioning (i.e. such as when the area is operated as another functional entity like agricultural practises).

10.2.6.1 Topography

No significant cumulative impacts are envisaged.

10.2.6.2 Soils, Land Use, Land Capability

No significant cumulative impacts are envisaged.

10.2.6.3 Fauna and Flora

No significant cumulative impacts are envisaged.

10.2.6.4 Wetlands

No significant cumulative impacts are envisaged.

10.2.6.5 Surface Water

The dumps are located in a catchment that is highly industrialised and consists of upstream dumps that are currently undergoing reclamation. The water quality results indicated that the quality of water is being impacted upstream of the proposed project. The implementation of a sound SWMP is crucial to contain contaminated runoff on the operational area of the site. The monitoring and maintenance of the implemented SWMP is of utmost importance, to ensure spillages into the downslope watercourses do not occur. Should this not be done, then the proposed project has the potential to cumulatively impact on the already deteriorated water quality of the catchment.

The cumulative impact of the proposed project on the surface water quality of the catchment is rated in Table 10-77.

Table 10-77: Cumulative impact rating for surface water quality NATURE OF IMPACT: The proposed project has the potential to cumulatively impact on the surface water quality of the catchment Impact Rating without Impact Rating with Mitigation Mitigation Impact Status: (positive or negative) Negative Negative Extent (Local, Regional, International) Regional Local

Duration (Short term, Medium term, Long Medium term (project will be Medium term (project will be term) less than 5 years) less than 5 years) Magnitude (Major, Moderate, Minor) Major Minor

Probability (Definite, Possible, Unlikely) Definite Possible

Calculated Significance Rating (Low, Medium Low Medium, High)

Reversibility: (Reversible or Irreversible) Irreversible Irreplaceable loss of resources: (Yes or No No) Can impacts be enhanced: (Yes or No) Yes Residual impacts • None, the tailings material will be removed once the project is finished. Mitigation measures • Effective stormwater management that captures and contains all site runoff as proposed in the EMPr, and in accordance with GN R704 Regulations; • Water quality monitoring upstream and downstream of the proposed project.

10.2.6.6 Groundwater

The 4L3, 4L4 and 4L6 dumps are in close proximity to each other. The City Deep area is an industrial area and many pollution sources do exist that can contribute to groundwater contamination. It will be difficult to pinpoint the source unless very detailed assessments are undertaken at each facility in the City Deep area. Land use surrounding the City Deep study area is comprised of residential and industrial activities.

A gold slimes dump/TSF can potentially add sulphate, chloride, calcium, magnesium, manganese and aluminium to the local groundwater system if the management of contaminated water on site is not effective, but also through seepage from the slimes dump/TSF. Metals like cobalt, copper, nickel and zinc can also be elevated.

The outcome of the 4L3, 4L4 and 4L6 reclamation groundwater assessment indicates that the reclamation activities will have an overall positive impact on the receiving environment.

Establishing monitoring boreholes around the City Deep dumps footprint area is required to assess the implications that TSF reclamation will have on the aquifers and to identify if poor quality groundwater reach a sensitive receptor. The monitoring data recorded as reclamation operations progress must be used to update the monitoring programme.

10.2.6.7 Air Quality

Emissions from the reclamation of the City Deep dumps are predicted to only produce a limited increase in ambient concentrations of PM10 and PM2.5. In the long term, removal of the dumps will ameliorate the air quality of the surrounding areas.

10.2.6.8 Noise

No significant cumulative impacts are envisaged.

10.2.6.9 Visual

No significant cumulative impacts are envisaged.

10.2.6.10 Heritage and Palaeontology

No significant cumulative impacts are envisaged.

10.2.6.11 Socio-Economic

From a social perspective, some of the most significant cumulative impacts relate to the following aspects:

❖ The cumulative impacts associated with the influx of job seekers; ❖ An influx of job-seekers may lead to increased pressure on infrastructure and services and an increase in social pathologies; ❖ An increase in direct project nuisance factors; namely, noise, air pollution and increased number of vehicles could further impact negatively on the sense of place for some receptors. ❖ Implementation of suitable mitigation measures will be proposed to reduce and manage these nuisance factors.

10.3 Summary of Specialist Reports 10.3.1 Biodiversity

It is clear from the regional ecological overview, as well as the baseline data collected to date that the project area has been altered (historically and currently) predominantly by mining activities, there are however still some natural areas around.

The following further conclusions were reached based on the results of this assessment:

❖ A portion of the project area is identified as either CBAs or ESAs; ❖ The project area was superimposed on the terrestrial ecosystem threat status. According to this, the Project area, overlap with ecosystems that are listed as Critically Endangered; ❖ Project area was superimposed on the ecosystem protection level map to assess the protection status of terrestrial ecosystems associated with the development. Based on this the majority of the terrestrial ecosystems associated with the development are rated as not protected; ❖ Based on the SANBI (2010) Protected Areas Map and the NPAES the project area does not overlap with any formally or informally protected area; ❖ The project area does overlap with certain wetland areas and a river. However, neither the river nor the wetlands are classified as NFEPAs; ❖ The project area is situated within one vegetation type; namely the Soweto Highveld Grassland (EN) Mucina & Rutherford (2006); ❖ Based on the Plants of Southern Africa (BODATSA-POSA, 2016) database, 134 plant species are expected to occur in the area. Of these, two species are listed as being SCC, however none were recorded during the field visit but may potentially occur in the remaining natural vegetation; ❖ Based on the South African Bird Atlas Project, Version 2 (SABAP2) database, 422 bird species are expected to occur in the vicinity of the project area. Of these 37 species are listed as SCC and the majority are considered moderately likely to occur within the project area; ❖ Eighteen alien and/or invasive plants were recorded on the project area; ❖ Twenty-five avifaunal species were recorded in the project area, none of them were SCCs; and ❖ One mammal species was recorded in the project area during the November 2018 surveys.

Considering the above-mentioned conclusions, it is the opinion of the specialist that the project (as is), can be favourably considered. It is recommended that the mitigation and rehabilitation measures for the decommissioning phase be strictly adhered to so that the area can be successfully rehabilitated.

10.3.2 Wetlands

It is evident from the buffer’s extent that some of the proposed stormwater units and roads are located within the wetland and the associated buffer zone. Therefore, according to the mitigation hierarchy, avoiding wetlands will not be possible. The next step therefore will be to minimise the expected impacts.

Most of the expected impacts are expected to have “Moderate” significance ratings prior to mitigation with the exception of “Removal of vegetation” and “Ablution facilities”. These significance ratings are all expected to be decreased by applying all of the recommended mitigation measures and adhering to recommendations except for two impacts, namely “Excavations” and “Construction of the pipeline” of which both are part of the construction phase. Additionally, the wetland units identified are modified by altered water inputs from the surrounding dumps. It is expected that these wetland areas will improve in overall health and functionality. Therefore, as per the mitigation hierarchy, given the fact that the level of risks associated with the proposed activity cannot be minimised, rehabilitation of all affected areas must be undertaken for the proposed activity.

Due to the moderate post-mitigation significance ratings, the next step according to the mitigation hierarchy is to rehabilitate all of the affected areas. Therefore, it is recommended that a rehabilitation

plan should be set-up after the construction of the proposed pipeline aimed at rehabilitating all affected areas relevant to the pipeline. It therefore is the specialist’s opinion that if all recommendations and mitigation measures be implemented, no fatal flaws persist and that the project may proceed.

10.3.3 Surface Water

The most important aspect to prevent negative impacts from a surface water perspective, is to ensure that a sound stormwater management plan is implemented prior to the commencement of reclamation activities, in accordance with the conditions stipulated in GN R704. Maintenance of stormwater measures is of utmost importance and should be conducted as outlined in the EMPr.

Should the mitigation measures and recommendations provided in this report be implemented, then from a surface water perspective, the proposed project can commence.

The following is a summary of the recommendations provided in the report:

❖ The current stream crossing position for the proposed pipeline is relocated either slightly north or south, as it currently traverses a large section of the floodline. This will result in less disturbance to the floodplain and channel; ❖ The proposed pipeline should be constructed above the 1:100 year floodline. Any supporting pipeline structures proposed within the floodline, should be constructed to withstand a 1:100 year flood; ❖ Any proposed infrastructure should as far as possible be located outside of the 1:100 year floodline and 100 m watercourse buffer, whichever is the greatest between the two. Dumps 4L4 and 4L6 fall within the 100 m watercourse buffer, and exemption from Regulation 4 (a) and (b) of GN R704 should be obtained, prior to reclamation activities. It must be noted that these are historical dumps that were created prior to GN R704. Furthermore, construction works within the 1:100 year floodline is likely to trigger a water use in terms of section 21 (c) and (i) of the NWA, and should be included in the WULA; ❖ The SWMP detailed in the EMPr is implemented, and that all conditions specified in GN R704 are taken into account; ❖ It is recommended that any water in the emergency stormwater dams, as a result of spills or rainfall, is re-used for reclamation activities at the site. This will ensure that the water levels within the emergency stormwater dams are kept at a minimum at all times; ❖ The impact mitigation measures provided are implemented; ❖ The mine’s current water quality monitoring programme should be continued, with an additional monitoring point added downstream of dump 4L3 and 4L4, at the bridge where the stream crosses the N17 road. The purpose of this monitoring point will be to monitor any impacts on water quality from reclamation activities from the dumps. It is further recommended that trend analysis is added to the current reporting, and that the water quality at upstream monitoring points, is compared to downstream monitoring points; and ❖ Stormwater measures are monitored and maintained on a regular basis. The stormwater monitoring plan specified in the EMPr should be implemented.

10.3.4 Groundwater

Ergo must ensure that an effective surface water collection and retention system is in place to ensure that all flow and collected water is directed towards the emergency control dams and not allowed to freely drain away from the dump area. Pooling of water must not be allowed on open surfaces, except if lined.

The following specific measures are recommended to minimise and/or eliminate the impacts on groundwater quality:

❖ Ensure that clean and dirty water is separated, and that dirty water is contained. ❖ All dirty water being pumped from the reclamation areas should be stored and re-used to prevent unnecessary discharge into the natural environment. ❖ To limit the volume of dirty water to be managed, clean surface runoff must be directed around the mining areas. Should the water need to be discharged into the natural environment, the RWQO should be met, prior to discharge. ❖ Updated contaminant transport simulations must be undertaken once extra information is available (e.g. soil quality in footprint under TSF, geochemistry of dump material before and shortly after water jetting), to improve the confidence levels in long-term predictions. These simulations must be completed at least five years prior to site closure to ensure that effective measures are developed to manage long-term impacts.

Ensure that emergency control dams are designed to contain all dirty water generated during the reclamation process to prevent overflows and spillages.

It is the opinion of GWA that the reclamation of the 4L3, 4L4 and 4L6 tailings dumps can proceed, if good surface water / storm water management is in place and maintained. In the short term there could be water quality impacts (AMD) if water on the surface is not managed effectively. Overall, the project will deliver a positive impact if the dump is removed and subsequently a source of contamination.

10.3.5 Air Quality

An air quality impact assessment was undertaken for the reclamation of the three City Deep dumps called

4L3, 4L4 and 4L6. PM2.5 and PM10 represent the main criteria pollutants of concern. The following conclusions can be made from the modelling results:

❖ Increased PM emissions from the area being reclaimed can be expected to increase ambient air concentrations of PM10 and PM2.5, particularly in the areas within the first 1 000 m. ❖ Dustfall caused by the reclamation process decreases rapidly with distance from the area being worked on. ❖ The removal of the City Deep dumps as a permanent pollution source will, in the long term, ameliorate the air quality of the surrounding areas, and reduce the health risk of fine particulate matter inhalation for the surrounding communities.

The three City Deep dumps lie in an industrial area and in close proximity to a residential area. Furthermore, the impacts of the reclamation process will be adding to ambient concentrations which are already elevated. It is, therefore, essential that emissions be monitored and if the increase in emissions from the reclamation activities cause the NAAQS or the National Dustfall Regulation limits to be exceeded, the mitigation programme will have to be increased until compliance is achieved.

10.3.6 Noise

Construction Phase: The information available is adequate to conclude that there will be a low potential for a noise impact during the construction phase due to:

It is the opinion of the author that the potential of a noise impact would be of a low significance, but, should any potential and relevant stakeholder have a concern regarding noise during the public participation process, a Scoping level Noise Assessment is recommended.

Operation Phase: There are no potential noise-sensitive receptors within 200m from the area where hydraulic mining activities may take place. It is the opinion of the author that there exist a low potential for a noise impact and that no further Scoping or other acoustical studies (with regards to operational noises) would be required.

There is a high confidence in the findings, and, considering the low significance of the noise impact, it is the opinion of the author that the reclamation of the City Deep slime dumps be authorized from an acoustic perspective.

10.3.7 Visual

The proposed reclamation processes proposed for the City Deep Dumps will result in the lowering of the visual intrusion present on the current site. Before the reclamation occurs, the proposed site will have a moderate visual impact on motorists, nearby workers and residents. The impact of the site will remain moderate throughout the construction and the operational phase.

Once the reclamation of the dumps has been completed the proposed site will have a lowered and more positive visual impact on the surrounding areas. This is due to the removal of the dumps through the reclamation process, which will result in the removal of the visual intrusion and restoring the proposed site to the original red earth.

10.3.8 Heritage and Palaeontology

It is the specialist’s considered opinion that overall impact on heritage resources is LOW and after the implementation of the recommended mitigation measures is acceptably low or can be totally mitigated to the degree that the project can be approved from a heritage perspective.

10.3.9 Socio-Economic

There are significant positive impacts associated with the proposed project, notably job security, skills training, stimulation of economic growth and the main positive impact is removal of the pollution source, the dumps. There are however several potential negative socio-economic impacts of the proposed project that may affect surrounding businesses and residential areas. In light of the SIA findings the following recommendations should be considered:

❖ It is recommended that the mitigation and management measures as contained in this SIA report be actively pursued and incorporated in the EMP where applicable; ❖ Regular internal and external monitoring should be undertaken to ensure compliance with the Environmental Management Plan.

In conclusion, it is recommended that the proposed project is approved based on the assurance that potential negative impacts on the receiving socio-economic environment will be mitigated and managed as far as possible, and that potential positive impacts are enhanced to ensure the greatest value.

10.3.10 Radioactivity

Due to the low radiation levels recorded for dumps in the central basin, and based on the experience of the reclamation projects in the area, no radiation impacts are anticipated and the project can be approved.

10.4 Unplanned Events, Risks and Management Measures 10.4.1 Surface Water

Unplanned events and risks are unexpected incidents that may occur and are not planned for, resulting in an impact e.g. an extreme flood (1:200 year flood). These are Project risks which are not rated as impacts. These are indicated in Table 10-78.

Table 10-78: Unplanned events, risks and management measures Potential Project Risk Aspect Potentially (Unplanned Mitigation / Management / Monitoring Impacted Occurrences) ❖ Hydrocarbons and hazardous materials must be stored in bunded areas that are sized according to legislated Hydrocarbon spills Hydrocarbon requirements; from vehicles and contamination of ❖ Refuelling must take place on lined and contained areas; heavy machinery or surrounding surface ❖ Ensure that silt, oil traps and sumps are in good working hazardous materials or water resources condition and are serviced regularly; and waste storage through surface ❖ Vehicles and heavy machinery should be serviced and facilities. water runoff. checked on a regularly basis to prevent leakages and spills. Spill/leaks from the Contamination of proposed slurry surface water ❖ Regular inspections of the pipeline for any leaks. pipeline resources. Construction of the ❖ Ensure that the pipeline is constructed above the 1:100 proposed pipeline Pollution of surface year floodline and that any supporting structures within below the 1:100 year water resources the floodline are constructed to withstand a 1:100 year floodline. flood. Sedimentation and Overflow of dirty erosion of storm water ❖ Regular inspections of stormwater management water contaminating management infrastructure, especially after large storm events. clean areas. infrastructure.

10.5 Environmental Impact Statement

A detailed description of the methodology utilised to determining the environmental impacts and their respective probability, magnitude and severity is provided in Subchapter 10.1 as well as in the specialist reports contained in Appendix D.

During the risk assessment process, it was found that the negative impacts of the proposed project with mitigation would be mostly medium to low in nature, and the positive impacts medium to high. See Table 10-79.

Table 10-79: Key Findings. Rating Pre- Rating Post Impact Construction Operation Decommissioning Post closure Construction Operation Decommissioning Post closure Mitigation Mitigation ❖ Topography ❖ Visual (removal of ❖ Groundwater ❖ Water quality ❖ Visual (removal of dumps) Positive (+) Major (high) Major (high) quantity ❖ Groundwater dumps) ❖ Job security ❖ Visual quality ❖ Economic growth ❖ Land use ❖ Topography ❖ Groundwater quality ❖ Water quality ❖ Groundwater Moderate ❖ Job security ❖ Groundwater Moderate ❖ Job security Positive (+) ❖ Job security ❖ Groundwater ❖ AMD removal quality (medium) ❖ Economic growth quantity (medium) ❖ Economic growth quality ❖ Economic growth ❖ Visual ❖ Economic growth ❖ Land use Positive (+) Minor (low) ❖ Economic growth Minor (low) ❖ Topography ❖ Topography No Impact No Impact No Impact ❖ Soil ❖ Soil ❖ Topography ❖ Soil ❖ Biodiversity ❖ Wetlands ❖ Topography ❖ Water Quality ❖ Flora ❖ Soil ❖ Groundwater ❖ Wetlands ❖ Fauna ❖ Groundwater Quality ❖ Water Quality ❖ Wetlands quality ❖ Noise ❖ Air quality ❖ Noise ❖ Noise ❖ Water quality ❖ Noise ❖ Safety ❖ Noise ❖ Heritage ❖ Heritage ❖ Air quality Negative (-) Minor (low) ❖ Heritage ❖ Influx of Job ❖ Air quality Minor (low) ❖ Visual ❖ Air quality ❖ Influx of Job ❖ Health ❖ Noise ❖ Safety seekers ❖ Heritage seekers ❖ Sense of place ❖ Influx of Job ❖ Sense of place ❖ Radioactivity ❖ Heritage (dam ❖ Influx of Job seekers ❖ Influx of Job wall) seekers ❖ Safety seekers ❖ Safety ❖ radioactivity ❖ Radiation ❖ Health ❖ Sense of place ❖ Influx of Job seekers ❖ Radiation ❖ Impacts of AMD ❖ Alien vegetation on biodiversity spread ❖ Biodiversity ❖ Biodiversity ❖ Alien vegetation ❖ Loss of habitat ❖ Wetlands ❖ Flora spread ❖ Wetlands ❖ Water quality ❖ Fauna ❖ Loss of habitat ❖ Water quality Moderate ❖ Air Quality ❖ Wetlands Moderate ❖ Impacts of AMD ❖ Biodiversity Negative (-) ❖ Air quality (medium) ❖ Visual ❖ Water quality (medium) on groundwater ❖ Job security ❖ Visual (mining) ❖ Heritage (dam ❖ Air quality quality ❖ Safety wall) ❖ Job security ❖ Air quality ❖ Health ❖ Health ❖ ❖ Visual(mining) ❖ Sense of place ❖ Safety ❖ Radioactivity ❖ Radioactivity ❖ Nuisance to Biodiversity ❖ Impacts of AMD ❖ Nuisance to Negative (-) Major (high) Major (high) on biodiversity Biodiversity and groundwater quality

The EAP and environmental consultants responsible for the compilation of this document recommend that the City Deep Project should be approved, on condition that the mine implements all identified management measures and implements the monitoring plan.

11 Information for Consideration and Inclusion

11.1 Assumptions, Uncertainties and Gaps in Knowledge

The following assumptions and limitations are applicable to this EIA report:

11.1.1 Biodiversity

❖ As per the scope of work, the fieldwork component of the assessment comprised of one assessment only, which was conducted during the early wet season. This study has not assessed any temporal trends for the respective seasons; and ❖ Taking into account these limitations, the comprehensive desktop study was conducted, in conjunction with the wet season survey, and as such there is a moderate confidence in the information provided.

11.1.2 Wetlands

❖ Only wetlands that were likely to be impacted upon by proposed development activities were assessed in the field. Wetlands located within a 500 m radius of the sites but not in a position within the landscape to be measurably affected by the developments were not considered as part of this assessment; ❖ Areas characterised by external wetland indicators have been the focus for this study. Areas lacking these characteristics, i.e. disturbed areas, sport fields etc. have not been focussed on; ❖ It has been assumed that the proposed pipeline will not traverse the container yard but rather be amended to pass the container yard to the east of the container yard; ❖ Wetland areas identified on the waste dumps have been excluded from this assessment given the artificial influence; and ❖ The GPS used for water resource delineations is accurate to within five meters. Therefore, the wetland delineation plotted digitally may be offset by at least five meters to either side.

11.1.3 Surface Water

The following are key assumptions and limitations for the conceptual Surface Water Management Plan (SWMP):

❖ The SWMP and associated calculations are based on the project description provided. Should the project description or infrastructure layout change, then the SWMP will need to be revised; and ❖ The channels were sized to take the maximum flow calculated at the downstream end of the contributing catchment, and it is assumed that the channel sizing will be uniform along the entire length.

11.1.4 Air Quality

❖ Heavy construction is a source of dust emissions that may have a substantial temporary impact on local air quality. However, there will be minimal construction activities associated with the City Deep reclamation process. As this is an existing facility, some of the infrastructure is already in place, and others will be of a temporary nature e.g. mobile change houses and mobile offices. The pipelines which will need to be constructed will join into existing pipelines to and from the Ergo Plant. Emissions to the air from the laying of the pipelines are likely to be of relatively short duration and are deemed to be of low significance. ❖ Vehicles travelling across parts of the tailings could cause significant instantaneous emissions from exposed areas of tailings material. However, it was assumed that the total amount of traffic and hence the total emissions from this source would be insignificant. Furthermore, it is recommended that a strict speed restriction of 20 km/hr be implemented for all vehicles travelling on site. This will substantially reduce possible instantaneous emissions. ❖ The National Pollutant inventory (NPi) emission factor for TSFs does not account for differences in vegetation cover, moisture content, salt concentration, surface structure (structural & textural cracks & inhomogenity), nor weathering of the tailings (NPi, 2006). For this reason, it was assumed that in the 15-metre-wide bands where all vegetation is removed for the mining process, the emission rates predicted by the NPi will increase by a factor of 10. ❖ The Marticorena and Bergametti equations (1995) indicate that once the threshold velocity of a particle size is exceeded, the emission rate and therefore ambient concentrations increase very

rapidly. This means that large amounts of PM10 and PM2.5 may be emitted from the TSF on gusty days. However, the absence of meteorological data at the level of instantaneous wind gusts means that the frequency and duration of this occurring could not be assessed. ❖ It was assumed that the face being mined by the jets of high-pressure water will be wet on a regular basis, therefore emissions will not be increased from this area, even though the tailings material is ‘disturbed’. ❖ In line with the mandate for regulatory modelling ‘worst-case’ scenarios were modelled. Because the order of mining within each tailings area was not known, modelling was undertaken for areas where the tailings are closest to most sensitive receptors. For each of these modelling runs it was also assumed that the area modelled was the starting point for that TSF, i.e. the remainder of the tailings would still be emitting particulates as if it hadn’t been disturbed. This means that the cumulative emissions would be lower if the areas closest to residential areas were mined later in the schedule. Furthermore, the modelling results presented are based on a period of three years of meteorological data. This means that, if the areas modelled were mined in January to March, the increased moisture and lower wind speeds at that time of the year could also lead to a decrease in the predicted emissions. ❖ The order of reclamation was taken to be 4L3, 4L4 and then 4L6. It was assumed that each one will be removed to ‘red earth’ before the next is started in terms of the cumulative emissions included in the modelling. The results would be different if the order were to be changed, or if the previous area was not completed before mining of the next tailings area was started. ❖ Areas over which the slurry runs can be expected to have no emissions while they are wet. Furthermore, these areas tend to form a crust as they dry out. With the methodology of modelling

areas as the start of mining the TSF, this was not included. Furthermore, the position and extent of these areas was not known, and therefore the decrease in emissions from these areas could not have been included in the models. ❖ For the ‘denuded land’ scenario, it was assumed that all tailings material will have been removed. If any of this fine tailings-material is left behind, the predicted emissions from these areas could be substantially different. ❖ It should be noted that isopleth plots reflecting the 24-hour averaging periods contain only the fifth highest predicted ground level concentrations for that averaging period, over the entire three-year period for which simulations were undertaken. This is in line with the NAAQS which allows for four exceedances per year. It is therefore possible that, even though a high average daily concentration is predicted to occur at certain locations, this may only be true for five days a year.

11.1.5 Visual

❖ A preliminary mine layout was available. Detailed dimensions, such as the vertical offset of proposed surface infrastructure above ground level, were however not available, and were assigned based on consultation with the Environmental Project Manager and experience from similar infrastructure in previous projects. All viewsheds were based off terrain level. As such these viewsheds do not incorporate distractive views in the form of vegetation or land use (infrastructure, buildings, etc.). ❖ The validity of third-party data, such as elevation, land use and vegetation cannot be guaranteed as no ground-truthing or data validation procedures were used. This level of assessment excludes surveys to establish viewer preference and thereby their sensitivity. For example, localized visual perceptions of the economically depressed communities may be influenced rather by the short term economic and job opportunities that will exist rather than the direct visual perception of the project; and the major limitation of this study is the unavoidable subjectivity relating to the assessment of the visual impact. Findings will also be restricted to information on hand, as well as the quality of spatial data.

11.1.6 Social

❖ The study is based on data obtained from the community survey, 2016, which may not reflect accurate information; ❖ Not every individual in the community could be interviewed therefore only key people in the community were approached for discussion; ❖ It should be noted that the social environment is a dynamic, constantly changing entity. It is therefore not always possible to predict all social impacts to a very high level of accuracy. Care has been taken to identify the most likely and significant impacts in the most appropriate way for the current local context; ❖ Social impacts can be experienced by affected communities on an actual or a perceptual level. It is therefore not always possible to quantify social impacts properly; ❖ It should be noted that predictions concerning the characteristics of the receiving socio-economic environment at the time of decommissioning are subject to a large margin of error, thus

significantly reducing the accuracy of impact assessment- the specialist has attempted to assess (where possible) the impact during the decommissioning phase.

11.2 Aspects for Inclusions as Considerations of the Environmental Authorisation

Should the DMR grant an EA for this project, it should be subject to the following conditions:

❖ The project may not commence prior to the EA being issued; ❖ The project should remain in full compliance with the requirements of the EMPr and with all regulatory requirements; ❖ The EMPr should be implemented by qualified environmental personnel who have the competence and credibility to interpret the requirements of the EMPr. Such persons must be issued with a written mandate by Ergo management to provide guidance and instructions to employees and contractors; ❖ Ergo should conduct annual internal auditing of environmental performance and annual reporting to the DMR; ❖ Ergo must undertake external auditing of the environmental performance as per the timeframe provided in the Environmental Authorisation and provide the DMR with a copy of the auditing report; ❖ Stakeholder engagement must be maintained during the construction, operational and closure/rehabilitation phases of the project, with the emphasis on the continuing provision of information; and ❖ All necessary authorisation must be in place prior to commencement of the project activities. ❖ Annual update of the Closure & Rehabilitation Plan. ❖ Compilation of an Alien and Invasive Species Plan to be implemented for the duration of the life of mine; ❖ Compilation of a Storm Water Management Plan (SWMP)during the life of mine; ❖ A spill containment plan is required to be in place prior to construction; ❖ Water Quality Monitoring programme should be implemented before construction to assess the impact on the surrounding water bodies; and ❖ A Chance Find procedure for heritage resources and artefacts needs to be in place.

11.3 Proposed Management Objectives and Outcomes for Inclusion in the EMPr

The EMPr is compiled with the aim of achieving a required end state that, as far as possible, ensures that environmental quality is maintained. The impact management objectives and outcomes for the City Deep Project are as follows:

❖ To minimise the negative environmental impacts as far as feasible; ❖ To maximise the positive and minimise the negative socio-economic impacts; ❖ To capture, contain, treat and recycle all contaminated water arising from the mining operations on site and to prevent the discharge of contaminated water to the environment; and ❖ To maintain cordial relationships with local residents, authorities and other stakeholders via sustained open communication.

The EMPr describes how activities that have, or could have, an adverse impact on the environment will be mitigated, controlled and monitored. Moreover, the EMPr will address the environmental impacts during the construction, operational, decommissioning (where applicable post-closure) phases of the Project. Due regard must be given to environmental protection during the entire City Deep Project, and a number of environmental recommendations are made in this regard. These recommendations are aimed at ensuring that the contractor maintains adequate control over the Project to:

❖ Minimise the extent of an impact during the life of the City Deep Project; ❖ Maintain a state of Environmental Quality following completion of the City Deep Project; ❖ Ensure appropriate restoration of areas affected by the City Deep Project; and ❖ Prevent long term environmental degradation.

11.4 Rehabilitation Requirements

Final rehabilitation will be carried out once the City Deep Project goes into its closure phase. This final rehabilitation will be carried out within the context of the closure plan.

The principles for proper rehabilitation, which should be followed, are:

❖ Preparing a comprehensive rehabilitation plan prior to the commencement of the mining area footprint; ❖ Landform design (levelling, top-soiling) and seeding; and ❖ Maintenance management and eradication of invader species.

The objective of the final rehabilitation, decommissioning and mine closure plan, which must be measurable and auditable, is to identify a post-mining land use that is feasible through:

❖ Providing the vision, objectives, targets and criteria for final rehabilitation, decommissioning and closure of the project; ❖ Outlining the design principles for closure; ❖ Explaining the risk assessment approach and outcomes and link closure activities to risk rehabilitation; ❖ Detailing the closure actions that clearly indicate the measures that will be taken to mitigate and/ or manage identified risks and describes the nature of residual risks that will need to be monitored and managed post closure; ❖ Committing to a schedule, budget, roles and responsibilities for final rehabilitation, decommissioning and closure of each relevant activity or item of infrastructure; ❖ Identifying knowledge gaps and how these will be addressed and filled; ❖ Detailing the full closure costs for the life of project at increasing levels of accuracy as the project develops and approaches closure in line with the final land use proposed; and ❖ Outlining monitoring, auditing and reporting requirements.

11.5 A Reasoned Opinion: Should the City Deep Project be Approved?

This opinion holds provided all the recommendations proposed in the specialist studies and the EIA and EMPr as well as legislative requirements are implemented and adhered to.

An impact assessment has been undertaken using qualified specialists, which has incorporated extensive consultation with and participation of interested and affected parties. Applying the hierarchical approach to impact management, alternatives were firstly considered to avoid negative impacts, but where avoidance was not possible, to better mitigate and manage negative impacts. Where impacts were found to be potentially significant, various mitigation measures to manage and monitor the impacts of the project have been proposed.

11.6 Period for which Environmental Authorisation is required

The EA is required for a period of 15 years.

11.7 Other information requirements

These have been discussed throughout the EIA report. For each additional information requirement, the applicable Chapter and/or Subchapter will be referenced.

11.8 Oath Undertaking

The EAP hereby confirms:

❖ The correctness, to the best of his knowledge, of the information provided in the specialist reports and on information provided by Ergo. The information was accepted as being as reliable as information generated during an EIA and a feasibility study, and provided in good faith, can be; ❖ The inclusion of comments and inputs from stakeholders and I&APs; ❖ The inclusion of inputs and recommendations from the specialist reports where relevant; and

❖ The acceptability of the project in relation to the finding of the assessment and level of mitigation proposed.

KONGIWE ENVIRONMENTAL (PTY) LTD Company Name

GERLINDE WILREKER Name of the Environmental Assessment Practitioner Signature

26 March 2019 Date

12 Financial Provision

The Rehabilitation, Decommissioning and Mine Closure Report is included in Appendix D12.

12.1 Closure Cost methodology

The closure cost calculation has been performed in accordance with NEMA GN R1147 of 2015 Financial Provision Regulations. The methodology employed to calculate the closure costs is detailed in Section 12.1.3. Section 12.1.3.1 presents the potential unplanned closure costs (worst case scenario) for year 1 of the Project. Rehabilitation spend (excluding concurrent rehabilitation) will be greatest during the latter part of the mine lifecycle (decommissioning phase) as this is when infrastructure will be demolished, the area rehabilitated and the entire mining footprint prepared for the submission of a closure certificate.

Due to the current uncertainty surrounding the change in the Financial Provision Regulations, this report has utilised the current existing regulations and has determined a provision for Year 1 of the potential operations as well as year 10. The financial provision will require updating annually.

It must be noted that the amounts presented in this section are nominal and undiscounted, the calculation does not include the time-value of money.

To ensure that the site is up to standards for the proposed land use, the following activities need to take place:

All surface plants, buildings and equipment needs to be removed from site, foundations will also need to be removed to a metre below the surface. After all the infrastructure has been removed the surface will need to be levelled and revegetated and, all haul and other activity roads will need to be ripped and vegetated. Pollution control dams will also need to be removed along with powerlines and other electrical infrastructure.

12.2 Concurrent Annual Environmental Cost

Concurrent annual environmental costs will included into the operating budget of the mine. The operation has not been initiated and a Zero (R 0.00) rand concurrent annual environmental cost is reported.

12.3 Closure Cost Year 1

The closure costs of the aspects linked with the project are based solely on the premature closure of the project, as this would be the only area that would have been impacted upon within one year of operation.

The approach to calculating the closure quantum a is summarised as follows:

❖ Step 1: Determine the closure components and associated rates. Table 12-1 details the rates which have been used. The components include: o Removal of infrastructure and hydraulic mining equipment;

o Removal of pipelines; o Rehabilitation and removal of paddocks and stormwater systems; o Rehabilitate reclamation station- Removal of pumps and permanent steel and other structures; o Rehabilitation of collection sump area; o Maintenance and aftercare; and o Post-closure maintenance and monitoring costs. ❖ Step 2: Determine the unit rates for closure components. T ❖ Step 3: Identify areas of disturbance. Table 12-1 details the areas of disturbance measured for proposed infrastructures, as disturbed in Year 1 of operation. Note that the areas have been calculated based on the mine plan; however, opinions of the EAP have been taken to adequately calculate mining structures and infrastructure associated with similar operating mines. Therefore, areas covered hereunder may not correspond with the areas as detailed in the mine plan for the Project. Additionally, this cost is based on Year 1, which is in the ramp-up period and consists of site infrastructure and pipeline installations. ❖ Step 4: Proposed closure costs for the Project.

Table 12-1: Rates associated with Closure Components at Year 1

Main Description Rate 2019 Comment

Demolish Infrastructure Pump Stations

Site Establishment R9 097,92 size of 4L2 infrastructure used Breaking of concrete R284,31 size of 4L2 infrastructure used Bury concrete 1m under ground R68,23 size of 4L2 infrastructure used Motors, pump and steel tanks R796,10 size of 4L2 infrastructure used

Pipelines Decommissioning of pipelines (slurry) R92,04 3 500m Decommissioning of pipelines (process water) R92,04 3 500m

Table 12-2: Year 1 Unplanned Closure Cost Master Rate Main Description Units Quantity Amounts 2019 Demolish Infrastructure Pump Stations

Site Establishment item 1 R9 097,92 R9 097,92 Breaking of concrete m3 595 R284,31 R169 164,45 Bury concrete 1m under ground m3 595 R68,23 R40 596,85 Motors, pump and steel tanks tons 70 R796,10 R55 727,00

Pipelines Decommissioning of pipelines (slurry) m 3 500 R92,04 R322 140,00 Decommissioning of pipelines (process water) m 3 500 R92,04 R322 140,00

Sub Total 1 R918 866,22 VAT @ 15% R137 829,93 Grand Total R1 056 696,15

12.4 Year 10 Closure Cost

The approach to calculating the closure quantum is the same as for year 1. The closure components for year 10 include:

❖ Shaping of the reclaimed footprint area; ❖ Removal of infrastructure and hydraulic mining equipment; ❖ Removal of pipelines; ❖ Rehabilitation of access roads and roads on site; ❖ Rehabilitation and removal of paddocks and stormwater systems; ❖ Rehabilitate reclamation station- Removal of pumps and permanent steel and other structures; ❖ Rehabilitation of collection sump area; ❖ Maintenance and aftercare; ❖ Radiation clearance for each rehabilitated footprint; and ❖ Post-closure maintenance and monitoring costs.

Table 12-3: Rates associated with Closure Components at Year 10

Main Description Rate 2019 Comments

Demolish Infrastructure Pump Stations

Pipelines

Main Description Rate 2019 Comments

Decommissioning of pipelines (slurry) R92,04 Decommissioning of pipelines (process water) R92,04

Rehabilitation Shaping of footprint area - to ensure site drainage R28 567,53 110ha Radiation clearance R41 572,44 110ha Radiation clearance Soil samples R33 650,56 110ha

Stormwater management R5 117,58 20% of total project area

The closure provision required for Year 10 of the project is detailed in the Table 12-4 below.

Table 12-4: Total Closure Provision at Year 10

Main Description Units Quantity Rate 2019 Amounts

Demolish Infrastructure Pump Stations Site Establishment item 1 R9 097,92 R9 097,92 Breaking of concrete m3 595 R284,31 R169 164,45 Bury concrete 1m under ground m3 595 R68,23 R40 596,85 Motors, pump and steel tanks tons 70 R796,10 R55 727,00

Pipelines Decommissioning of pipelines (slurry) m 3500 R92,04 R322 140,00 Decommissioning of pipelines (process water) m 3500 R92,04 R322 140,00

Rehabilitation Shaping of footprint area - to ensure site drainage ha 110,27 R28 567,53 R3 150 141,53 Radiation clearance item 1 R41 572,44 R41 572,44 Radiation clearance Soil samples item 1 R33 650,56 R33 650,56

Stormwater management ha 30 R5 117,58 R153 527,40

Sub Total 1 R4 297 758,15 VAT @ 15% R644 663,72 Grand Total R4 942 421,88

12.5 Total Closure Costs

The total closure provision required for the project is detailed in the

Table 12-5 below. Ergo already has a financial provision of R 3 230 396 in place for the dumps. Therefore an additional amount of R1 067 362.15 for closure will be required.

Table 12-5: Total Closure Provision Mining Right Closure Cost after YR1 of Operation Closure Cost after YR10 of Operation (Excl. VAT) (Excl. VAT) 185 MR R918 866.22 R4 297 758.15 Total Closure Provision R4 297 758.15

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