The Marievale Tailings Reclamations Project

ERGO MINING (PTY) LTD: THE MARIEVALE TAILINGS RECLAMATIONS PROJECT.

FINAL ENVIRONMENTAL IMPACT ASSESSMENT REPORT

25 June 2020

DMRE Reference Number: GP 30/5/1/1/2 (000007BP) BAR

FINAL ENVIRONMENTAL IMPACT ASSESSMENT REPORT

FOR LISTED ACTIVITIES ASSOCIATED WITH THE MARIEVALE TAILINGS RECLAMATION PROJECT NEAR NIGEL, EKURHULENI METROPOLITAN MUNICIPALITY, GAUTENG PROVINCE.

APPLICATION FOR ENVIRONMENTAL AUTHORISATION (EA):

SUBMITTED FOR ENVIRONMENTAL AUTHORISATIONS IN TERMS OF THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT (ACT 107, 1998) (AS AMENDED), THE NATIONAL ENVIRONMENTAL MANAGEMENT WASTE ACT (ACT 59, 2008) (AS AMENDED), AND THE NATIONAL WATER ACT (ACT 36, 1998) (AS AMENDED).

Name of Applicant: Ergo Mining (Pty) Ltd Tel No: +27 11 248 9000 Postal Address: PO Box 12442, Selcourt, Springs, 1567 Physical Address: 1 Sixty Jan Smuts Building, 2nd Floor – North Tower, 160 Jan Smuts Avenue, Rosebank, 2196. Document prepared by: Kongiwe Environmental (Pty) Ltd Document Date: 25 June 2020 DMRE Reference Number: GP 30/5/1/1/2 (000007BP) BAR

FINAL ENVIRONMENTAL IMPACT ASSESSMENT

PROJECT: MARIEVALE PROJECT

Report Title: THE MARIEVALE TAILINGS RECLAMATION PROJECT IN NIGEL, EKURHULENI METROPOLITAN MUNICIPALITY, GAUTENG PROVINCE Applicant: Ergo Mining (Pty) Limited Project No: DRDG#005 Compilation Date: 25 June 2020 Status of Report: Final EIA and EMP reports for Public and Authority review

Verification Capacity Name Signature Date

By Author The Report Compiler Ashleigh Blackwell 16 April 2020

Technical Director Reviewed by Gerlinde Wilreker 01 June 2020 and EAP

Reviewed by: Legal Director Michael Hennessy 10 June 2020

Authorised by Chief Executive Bradly Thornton 22 June 2020

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

SECTION 1:

ENVIRONMENTAL IMPACT ASSESSMENT REPORT OVERVIEW

Important Notice

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.

Executive Summary

Kongiwe Environmental (Pty) Ltd (‘Kongiwe’) has been appointed as the Independent Environmental Service Provider, tasked with conducting the Scoping and Environmental Impact Assessment (S&EIA) process which is aimed at critically evaluating the potential environmental and social impacts of the proposed Marievale Project (hereafter the Proposed Project).

The Application for Environmental Authorisation was submitted to the Department of Mineral Resources and Energy (DMRE), who are the Competent Authority (CA), on Tuesday, 15 October 2019. The Draft Scoping Report (DSR) was made available for public review from 23 October 2019 to 21 November 2019. The Final Scoping Report (FSR) was submitted to the DMRE for its consideration and comment on the 28 November 2019.

The CA’s 43-day review and decision making period on the FSR ran until 31 January 2020. Acceptance of the Scoping Report was received by the DMRE on the 27 January 2020.

In accordance with Regulation GN R439 of 31 March 2020, the Minister of Forestry, Fisheries and the Environment, acting in terms of the Regulations issued in terms of section 27(2) of the Disaster Management Act, 2002, has extended the timeframes prescribed in terms of the Environmental Impact Assessment Regulations 2014, the National Environmental Management: Waste Act, 2008 and National Environmental Management: Air Quality Act, 2004, by the number of days of the duration of the lockdown period of the national state of disaster declared for the COVID-19 pandemic, including any extensions to such duration, with effect from 27 March 2020 until the termination of the lockdown period.

Considering the above, the Draft EIA/EMPr reports for the proposed Marievale project were made available for an additional 21 days for public review and comment until Thursday, 14 May 2020. An extended lockdown was then announced by the President on the Thursday 9 April 2020. In view of this, the public review and comment was further extended until Thursday, 28 May 2020.

Notification letters announcing the extensions of the public review and comment period were emailed to all stakeholders on the database on Wednesday, 1 April 2020 and Thursday, 16 April 2020, respectively.

Project Intentions

Ergo Mining (Pty) Limited (hereafter Ergo) intends to reclaim and reprocess gold residues from the Marievale tailings storage facilities (TSFs) Nos. 7L5, 7L6 and 7L7. These TSFs are historical mineral deposits (slimes dams), situated approximately 6 km north-east of Nigel and 10 km south-east of Springs, in the Ekurhuleni Metropolitan Municipality (EMM). These TSFs were created prior to the promulgation of the Mineral and Petroleum Resources Development Act, 2002 (Act No 28 of 2002) (MPRDA) and are accordingly not regulated by the MPRDA.

Ergo intends to conduct the project in accordance with the summary flow diagram below:

Figure 0. 1: A short summary of the Proposed Project Process

Before reclamation can commence, the sites will be prepared to prevent unwanted material from entering the slurry. Suitable aggregate will be stockpiled for reuse and cleared vegetation could be sold locally or disposed of at a licenced facility.

A baseline radiological assessment will be undertaken by a registered professional once the site has been cleared of vegetation. Temporary and mobile (park home) site infrastructure will be established at the reclamation sites with existing connections to the power grid and potable water sources. As part of construction and site preparation activities, the existing Marievale paddocks and stormwater systems will be reinstated and upgraded for capturing and managing dirty water around the site.

Once site preparation and construction are completed, hydraulic reclamation can begin. To remove unconsolidated tailings material within the TSFs, a movable high pressure water monitor (or cannon) will be directed onto the face of the TSF. Reclamation will take place in predetermined benches (or ‘cuts’) and will move unidirectionally until the entire TSF has been reclaimed. Generally, 30 m – 40 m cuts are made as reclamation progresses. The water from the monitor mixes with the tailings and forms a slurry with a high solid content. The slurry then flows under gravity, along the base of the TSF, to a collection sump which is positioned at the lowest elevation of the bench being reclaimed. The collection sump is then able to filter and screen appropriately sized slurry, and direct it into pipelines which will pump the slurry to the existing Ergo Plant for gold recovery. Residual slurry will then be pumped to the licenced Brakpan/Withok TSF. The water which accumulates atop the Brakpan/Withok TSF is pumped to and reused at Ergo’s various operations.

Project Rehabilitation and Future Land use

Once reclamation is completed, the project will be decommissioned. During this phase, all project infrastructure will be removed, a final radiological survey will be undertaken, and rehabilitation can commence. The rehabilitation should invariably be evaluated in view of the future land use. The primary aim of rehabilitation is to:

❖ Reduce the actual or potential environmental risks to acceptable levels. ❖ Protect the future value of the land by re-establishing a sustainable land use as similar to its pre-mining condition as possible.

Kongiwe’s suggested end land use is the extension of the Marievale Bird Sanctuary and the Blesbokspruit wetland, however, this would be at the discretion and approval of the end landowner. To achieve this preferred end land use, the land must be levelled, and remnants of contaminated slime removed. Dust generation will be minimised by planting appropriate plant and grass species. Lastly, paddocks will remain as a short-term method of containing the potential surface migration of contaminants towards the Blesbokspruit and will be removed and rehabilitated once rehabilitation has proven successful. Since the TSFs lie within close proximity to the wetland system, it is expected that the flat lying areas directly adjacent to the Blesbokspruit may fill with water once again, thereby extending the Marievale Bird Sanctuary and contributing to ecological success and sustainability.

Project Background and Motivation

The following points below summarise the project motivations:

❖ Ergo makes use of sophisticated metallurgical processes which make it viable to retreat the historic Marivale TSFs and extract the residual gold, having retreated millions of tonnes of material since its inception in December 1977. With the upturn of the gold price, the grade in the Marivale TSFs has become economically viable to extract. Although gold will be the main mineral for extraction, the concentrations of uranium, nickel and silver will also be investigated in conjunction with the availability of stone, gravel and waste rock. ❖ Although there is a strong economic case for the project, the removal of these TSFs also forms part of DRDGold Limited’s broader strategy to clean-up and remove the remaining TSFs across Gauteng and contain them in two mega facilities known as the Brakpan/Withok TSF and the Regional TSF (RTSF – still to be constructed). It is envisioned that the Brakpan/Withok TSF will hold tailings removed and re-treated by Ergo from the East Rand and other parts of the Central Rand, and the RTSF will hold tailings treated and removed on the West Rand. ❖ Ergo Mining will align to the National Environmental Management Act (Act 109 of 1998) EIA Regulations, in accordance with the One Environmental System for the reclamation of historic mine residue tailings. ❖ Ergo intends to remove a historic pollution point-source and rehabilitate the land to a state that is sustainable, functioning and represents a pre-mining landscape.

Project Alternatives

The following sections below provide a short summary of the project alternatives that were assessed within this EIA.

The location of the proposed project:

The Proposed Project is the reclamation of already existing TSFs (7L5, 7L6 and 7L7). Therefore, there are no alternative sites.

The type of activity to be undertaken:

The only optional activity for Ergo is to reclaim and reprocess the existing Marievale TSFs. Therefore, there are no alternative activities undertaken by Ergo.

The technology to be used:

The reclamation of the Marievale TSFs is the “Preferred Activity” and there are no alternatives. The dumps will be reclaimed using Hydraulic Mining.

The Design and Layout of the Activity:

The current layout plan alternatives for the Proposed Project are considered as the preferred layout plan. The layout plan is dictated by independent specialist study recommendations, the existing location of the TSFs, their associated infrastructure and the routes of the proposed pipelines. The routes of these pipeline are limited to existing surface right permits (SRPs) that are held by Ergo. Where Ergo does not hold an SRP, a new servitude, right of way or wayleave will be sought.

Operational Alternatives:

The Proposed Project will investigate various pipeline routes to convey slurry from the TSFs to the Ergo Plant for reprocessing; and return process water to the project site for reclamation.

❖ Pipeline Route 1: There will be a 600 mm pipeline from the Trans-Caledon Tunnel Authority (TCTA) AMD treatment project towards the Daggafontein plant. This pipeline will continue on the alignment of Ergo’s existing Surface Right Permits to the Ergo Plant, and hence to the Brakpan/Withok TSF where the brine will be deposited. ❖ Pipeline Route 2: There will be three 600 mm pipelines, with two transporting slurry and the other process water, that will run between 7L7, 7L6 and 7L5 north towards the Daggafontein plant. These pipes will then continue along Ergo’s existing Surface Right Permit to the Ergo Plant, where resultant process residue will be disposed on the Brakpan/Withok TSF via existing and authorised pipelines. ❖ Pipeline Route 3 (alternative to Pipeline Route 2): This route will also consist of the same pipeline configuration as Route 2 but is proposed to run south of 7L5, 7L6 and 7L7 and then north westerly to

the Ergo Plant. This route is approximately 19 km long. Residue will be disposed on the Brakpan/Withok TSF via existing and authorised pipelines.

These options are all preferred pipeline options for the transport of slurry and return water.

The proposed reclamation site will be situated in Zone 3 of the Gauteng Provincial Environmental Management Framework (GPEMF) (2018); and even though some parts of the proposed pipelines may be laid in Zones 1 and 5, they may require authorisation in terms of the National Water Act (Act No. 36 of 1998) (NWA) for Section 21 water uses. An Integrated Water Use Licence Application (IWULA) will 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 will be supported by a Technical Report and other necessary supplementary reports.

Two locations for temporary site infrastructure will be assessed:

❖ Alternative 1: Temporary site administration, ablution and contractors’ yard to be located at the Marievale TSFs. Grid connection and portable water connection would need to be established. ❖ Alternative 2: Temporary site administration, ablution and contractors’ yard to be located at the Daggafontein TSF. Grid connection and portable water connection would not need to be established

The No-Go Alternative:

Environmental Impacts of the Marievale 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 and post-decommissioning. Post decommissioning, the following positive benefits are expected:

❖ Job Security for staff and contractors currently contracted or employed by Ergo; ❖ Skills Development for those employed for the project; ❖ Economic growth and contribution to the economy; ❖ Improved surface water quality over time; ❖ Improved groundwater quality over time; and

❖ Improved ecosystem health and functioning over time.

Table 0. 1: Risk Matrix of Assessed Project Impacts

❖ Improved water ❖ Improved water ❖ Improved water ❖ Groundwater quality ❖ Improved water Moderate ❖ Increased ❖ Increased quality quality Moderate ❖ Job security and quality ❖ Health impacts quality Positive (+) (medium) economic revenue economic revenue ❖ Availability of land (medium) skills development ❖ Job security and from dust use skills development Ecosystem services ❖ Dust ❖ Improved water ❖ Improved water ❖ Reduction in quantity quantity ❖ Job security and aquifer yield ❖ Health impacts ❖ Reduction in Positive (+) Minor (low) Minor (low) ❖ Disruption of skills development ❖ Job security and from dust aquifer yield movement skills development ❖ Ecosystem services patterns

❖ Noise clearance for ❖ Loss of CBA and development and ❖ Increased traffic pipelines outside ESA areas land use ❖ Vehicle impacts wetlands ❖ Flooding of ❖ Noise ❖ Impact on operation groundwater ❖ Water quantity quality reduction ❖ Damage to ❖ Leaks from heritage structures pipelines ❖ Ecosystem ❖ Damage to services impacts heritage structures ❖ Disruption of ❖ Ecosystem

RATING PRE- POST RATING POST POST IMPACT CONSTRUCTION OPERATION DECOMMISSIONING CONSTRUCTION OPERATION DECOMMISSIONING MITIGATION DECOMMISSIONING MITIGATION DECOMMISSIONING movement services impacts patterns ❖ Disruption of ❖ Creation of movement informal patterns settlements ❖ Creation of ❖ Noise informal ❖ Increased traffic settlements ❖ Traffic congestion ❖ Daytime Noise ❖ Vehicle impacts ❖ Nighttime noise ❖ Habitat ❖ Loss of CBA and disturbance ESA areas ❖ Fauna ❖ Disturbance of displacement habitat ❖ Loss of migration ❖ Fauna corridors displacement ❖ Loss of floral ❖ Loss of migration species ❖ Alien vegetation corridors ❖ Alien vegetation encroachment ❖ Loss of biodiversity ❖ Surface water encroachment ❖ Faunal ❖ Loss of habitat for ❖ Alien vegetation runoff ❖ Erosion displacement protected species encroachment ❖ Damage to graves ❖ Vegetation ❖ Dust ❖ Dust from ❖ Erosion and burial sites clearance ❖ Damage to vegetation ❖ Vegetation ❖ Safety impacts ❖ Damage to graves ❖ Dust heritage structures stripping Moderate clearance Moderate ❖ Land use impacts and burial sites Negative (-) ❖ Loss of CBA and ❖ Economic revenue ❖ Damage to graves (medium) ❖ Dust from (medium) ❖ Job security and ESA areas ❖ Disruption of and burial sites vegetation skills development ❖ Water quantity movement ❖ Safety impacts stripping ❖ Creation of reduction patterns ❖ Land use impacts ❖ Damage to informal ❖ Damage to ❖ Spatial ❖ Exposure to dust heritage structures settlements heritage structures development and fallout ❖ Ecosystem services ❖ Safety impacts ❖ Ecosystem services land use impacts impacts ❖ Disruption of ❖ Disruption of movement movement patterns patterns ❖ Creation of ❖ Creation of informal informal settlements settlements ❖ Traffic congestion ❖ Nighttime noise ❖ Loss of habitat for ❖ Loss of avifauna ❖ Erosion protected species due to powerlines ❖ Damage to graves ❖ Damage to graves ❖ Surface water and burial sites Negative (-) Major (high) and burial sites runoff Major (high) ❖ Creation of ❖ Safety impacts ❖ Flooding of informal ❖ Land use impacts operation settlements ❖ Exposure to dust ❖ Leaks from

Conclusions

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, 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 Marievale Project would conclusively result in certain negative impacts during the operational phase to the environment, however, none of the specialist studies objected to the project. Impacts are largely Moderate (negative) in significance, being mitigated to Low (negative) Significance. During the decommissioning and post-decommissioning phases, most of the impact are expected to be Moderate – High (positive) in significance after mitigation.

The specialist mitigations measures have been included into this EIA and EMPr report to reduce the significance of all the identified negative impacts. Most of the negative impacts from the proposed project can be reduced through the implementation of mitigation measures. Based on the information contained in this report, it is the opinion of the EAP that the negative environmental impacts resulting from the Marievale Project can be mitigated to within acceptable limits and that the project should be authorised, provided all the recommendations proposed in the specialist studies and the EIA and EMPr report as well as legislative requirements are implemented and adhered to.

The water quality in the Blesbokspruit is already impacted, and there is a possibility of some temporary contamination of downstream watercourses during operation of the Marievale project. If authorised, Ergo will need to minimise such contamination by following the prescribed mitigation stipulated in this EIA / EMPr, the water use licence and all relevant best practice guidelines and legislation regarding the rehabilitation of contaminated land. It is anticipated that through carefully planned reclamation efforts, the Blesbokspruit could expand to a state where it represents a viable and functioning pre-mining land use.

In conclusion, the EAP is of the reasoned opinion that the project should be authorised to proceed provided that the conditions of this EIA and the mitigation measures and objectives proposed by the EMPr are implemented by Ergo. Given that the Ramsar site is directly adjacent to 7L5, 7L6 and 7L7, extra care and diligence is required by Ergo to minimise negative impacts and maintain the status quo of the Marievale Bird Sanctuary and Blesbokspruit through the construction and operation of the project. An improvement of the functioning of the wetland is expected following decommissioning and rehabilitation.

Table of Contents

CHAPTER 1: INTRODUCTION ...... 1

1.1 Historical Project Background ...... 1

1.2 The Origin of Mine Dumps in Johannesburg ...... 2

1.3 Marievale Project Introduction ...... 3

Project Rehabilitation and Future Land Use ...... 5

1.4 Description of the Project Location ...... 7

1.5 Known Mining Rights held in the Area ...... 12

1.6 Details of the Independent Environmental Assessment Practitioner (EAP) ...... 13

Contact Person and Corresponding Address ...... 13 Expertise of the EAP ...... 13 Summary of the EAP’s Past Experience ...... 13 Independent Specialist Team Members ...... 14

1.7 Structure of this Environmental Impact Assessment report (EIA) ...... 15

CHAPTER 2: PROJECT DETAILS ...... 19

2.1 Requirements for Environmental Authorisation ...... 19

2.2 Overview of the Environmental Impact Assessment (EIA) Process...... 19

Overview of the Environmental Impact Assessment (EIA) Process ...... 19 Methodology applied to conducting the Scoping Process ...... 20 S&EIA Timeframes ...... 20 Public Participation Process ...... 22 Requirements for Environmental Authorisation ...... 23

2.3 Description of Project Activities ...... 26

Method of Reclamation ...... 26 Pipelines 27 Access 28 Power Supply and Process Water ...... 29 Stormwater Containment ...... 30

Technical Details ...... 30 Life-Cycle Phases of the Project ...... 31 Health and Safety ...... 35

2.4 Conclusions from the Scoping Phase ...... 37

Potential Impacts Identified in the Scoping Phase ...... 37 Main issues arising in the Scoping Phase ...... 40 Scoping Phase Conclusions and Recommendations ...... 41 Deviation from the Scoping Report ...... 42 CHAPTER 3: CONSIDERATION OF ALTERNATIVES ...... 46

3.1 The property on which or location where it is proposed to undertake the activity ...... 46

3.2 The type of activity to be undertaken ...... 46

3.3 The Design and Layout of the Activity ...... 47

3.4 The Technology to be Used in the Activity ...... 49

Recycling, potable water use and electricity reliance...... 49

3.5 The Operational Aspects of the activity ...... 50

Pipeline route options and Rehabilitation ...... 50 Infrastructure placement ...... 50

3.6 The “No-Go” option ...... 50

CHAPTER 4: POLICY AND LEGISLATIVE CONTEXT ...... 51 CHAPTER 5: THE NEED AND DESIRABILITY OF THIS PROJECT ...... 72

5.1 Environmental Pollution ...... 72

5.2 Safety and Security ...... 73

5.3 The Limitation of Spatial Development ...... 73

5.4 The Gold Industry of South Africa ...... 73

5.5 Conclusion: Need and Desirability ...... 74

CHAPTER 6: APPROACH TO UNDERTAKING THE EIA PROCESS ...... 75

6.1 Relevant Legislative Permitting Requirements ...... 75

National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA)6F6F ...... 75 National Heritage Resources Act, 1999 (Act No. 25 of 1999) (NHRA) ...... 75 National Water Act, 1998 (Act No. 36 of 1998) (NWA) ...... 76

6.2 Overview of the Scoping and EIA process being undertaken ...... 76

Tasks completed during the EIA phase ...... 77 Public Participation Process ...... 77 Key Commenting Authorities that have received copies of the DSR are as follows: ...... 83

6.3 Consultation Undertaken as part of the Final Scoping Phase ...... 85

6.4 Consultation with stakeholders during the Impact Assessment Phase ...... 85

Availability of the Draft EIA and EMP for public comment ...... 85 The Public Open Day ...... 86 The Public Open Day Cancellation – COVID-19...... 86

6.5 Public Participation Materials: EIA phase ...... 87

6.6 Availability of the Final Environmental Impact Assessment Report / Final Environmental Management Programme (DEIR/EMPr) for public review and comment ...... 89

6.7 Consultation during the decision-making phase ...... 90

CHAPTER 7: THE BASELINE ENVIRONMENT AND SPECIALIST FINDINGS ...... 91

7.1 Climate ...... 91

Rainfall 91 Storm Rainfall Depths ...... 92 Evaporation ...... 92 Temperature ...... 93 Wind Direction ...... 94

7.2 Geology and Soils ...... 96

Geology of the Project Area ...... 96 Soils of the Project Area ...... 97

7.3 Biodiversity ...... 101

The Habitat Assessment ...... 101 Gauteng Biodiversity Conservation Plan ...... 105 Designated Ramsar site ...... 106

National Biodiversity Assessment ...... 107 National Freshwater Ecosystem Priority Area (NFEPA) Status ...... 108 Wetlands 111 Flora 112 Fauna 117

7.4 Wetlands ...... 123

Wetland Classification ...... 123 Functional Description of the HGM Units ...... 125 Wetland Ecological Functional Assessment ...... 126 The Wetland Health Assessment ...... 127 The Ecological Importance and Sensitivity Assessment...... 130 Buffer Requirements ...... 130

7.5 Biodiversity and Wetlands Sensitivity Assessment ...... 131

Regional Catchments and Drainage ...... 134

7.6 Surface Water ...... 135

Regional Catchments and Drainage ...... 135 Surface Water Quality ...... 136 Surface Water Runoff ...... 137 Peak Flows ...... 142 Floodline Determination ...... 142 Conceptual Stormwater Management Plan ...... 145 Recommendations ...... 150 The Water Balance ...... 150

7.7 Groundwater ...... 153

Available Surface and Groundwater Monitoring Data ...... 153 The Marievale 2019 Hydrocensus ...... 156 Geochemistry ...... 165 Comment on the Risk Associated with Uranium ...... 165 Aquifer Characterisation ...... 166 Groundwater Modelling ...... 167 Impact Prediction ...... 172

7.8 Air Quality ...... 181

Health Effects of Particulate Air Pollutants ...... 181 Ambient Air Quality ...... 183

Emission Scenarios Modelled ...... 185 Evaluation of the STATUS QUO Modelling Results ...... 185 Evaluation of the SOUTH CUT modelling results ...... 188 Evaluation of the POST RECLAMATION modelling Results ...... 191 Conclusions drawn from the modelling results ...... 193

7.9 Heritage and Palaeontology ...... 194

Site Description in terms of Heritage Resources ...... 194 Previous Archaeological and Heritage Studies in and around the Study Area ...... 194 Marievale Fieldwork Findings ...... 194 Defined Heritage Impacts ...... 214 Defined Paleontological Impacts ...... 215

7.10 Social ...... 215

Project Area Demographics and Population characteristics ...... 216 Housing and Household Demographics ...... 216 Education ...... 217 Economy and Livelihoods...... 217 Service Delivery in the Project Area ...... 219 Vulnerable Groups ...... 219 Anticipated Social Impacts ...... 220 Identified Social Risks ...... 224 Cumulative Impacts ...... 224

7.11 Noise Impact Assessment ...... 225

The current Environmental Sound Character ...... 225 Ambient Sound Measurements ...... 225 Ambient Sound Findings ...... 229 Potential Noise Sources ...... 229 Project Noise Rating Levels for Marievale ...... 232 Conclusions of the Noise Impact Study ...... 238

7.12 Traffic Statement ...... 239

The current road networks ...... 239 Existing Traffic Demand ...... 240 Future Traffic Demand ...... 241 Trip Generation Conclusions ...... 241 Proposed Sites Access: ...... 241 Access Safety (For all Sites) ...... 245 CHAPTER 8: IMPACT ASSESSMENT ...... 246

8.1 Methodology for assessing the significance of Environmental Impacts ...... 246

Part A: Defining Consequence in Terms of Magnitude, Duration and Spatial Scale ...... 246 Part B: Determining Consequence Rating ...... 247 Part C: Determining Significance Rating ...... 248

8.2 Impacts and Cumulative Impacts Identified ...... 248

Construction Phase ...... 248 Operational Phase ...... 276 Decommissioning Phase ...... 298 Post-Decommissioning Impacts ...... 319 Cumulative Impacts ...... 320

8.3 Specialist Studies Conclusions and Recommendations ...... 326

Biodiversity and Wetlands ...... 327 Surface Water ...... 328 Groundwater ...... 329 Air Quality ...... 332 Heritage 332 Social Impacts ...... 334 Noise 335 Traffic Statement ...... 336

8.4 Summarised Environmental Risk Matrix ...... 337

CHAPTER 9: INFORMATION FOR CONSIDERATION ...... 341

9.1 Assumptions, Uncertainties and Gaps in Knowledge ...... 341

Biodiversity and Wetlands ...... 341 Surface Water ...... 342 Groundwater ...... 342 Air Quality ...... 344 Heritage and Palaeontology ...... 345 Social 346 Noise 347

9.2 Aspects for Inclusions as Considerations of the Environmental Authorisation ...... 347

9.3 Proposed Management Objectives and Outcomes for Inclusion in the EMPr ...... 348

9.4 Rehabilitation Requirements ...... 349

9.5 Should the Marievale Reclamation and Reprocessing Project be Approved? ...... 350

Conclusions of the report ...... 350 CHAPTER 10: OATH UNDERTAKING ...... 352 CHAPTER 12: REFERENCING ...... 353

Figures

Figure 1-1: Historic mining activities within the Johannesburg area...... 1 Figure 1-2: Mine workers at Comet Gold Mine 1903 (left) and Simmer and Jack Mine 1939 (right) ...... 2 Figure 1-3: A short summary of the Proposed Project Process ...... 4 Figure 1-4: Marievale Land use Map ...... 6 Figure 1-5: Marievale Land Tenure Map ...... 11 Figure 2-1: Methodology applied to conducting a S&EIA process ...... 20 Figure 2-2: S&EIA Timeframes ...... 22 Figure 2-3: Mobile tracked hydraulic monitor on a tailing’s facility in South Africa ...... 26 Figure 2-4: Typical mining widths proposed for a gold reclamation project (Source: www.drdgold.com/investors-and-media/circulars/cpr-samrec-wrtrp-26022018.pdf)...... 27 Figure 2-5: Proposed access for the Marievale Project ...... 29 Figure 2-6: Project Process ...... 31 Figure 2-7: Marievale Project Infrastructure Map ...... 36 Figure 3-1: Preferred layout for the Marievale Project ...... 48 Figure 6-1: The Phases of the EIA process ...... 75 Figure 6-2: Pictures from the Open Day held on Saturday, 9 November 2019 ...... 82 Figure 7-1: Average monthly rainfall totals for the project area...... 91 Figure 7-2: Minimum, average and maximum monthly temperature for the project (Source: HydroSpatial,2018) ...... 93 Figure 7-3: Wind rose of the average winds produced by the WRF model for the Marievale reclamation site, for the years 2015-2017 ...... 94 Figure 7-4: Seasonal wind roses produced by the WRF model for the Marievale Project site for the years 2016- 2018 ...... 95 Figure 7-5: Diurnal wind roses predicted by the WRF model for the Marievale Project site for the years 2016- 2018 ...... 96 Figure 7-6: Marievale Geology ...... 97 Figure 7-7: Example of a Wasbank soil form, (SASA, 1999) ...... 98 Figure 7-8: Example of a Katspruit soil form, (SASA, 1999)...... 98 Figure 7-9: Example of a Kroonstad soil form (SASA, 1999) ...... 99 Figure 7-10: Example of a Dresden soil form, (SASA, 1999) ...... 99 Figure 7-11: Hydromorphic soil forms. A: Mottling within an Orthic topsoil. B: Dresden soil form. C: Unspecified material without signs of wetness. D: Oxidation/reduction processes within hydromorphic soil. E: Gleyic horizon ...... 100 Figure 7-12: Soils classified for the project area ...... 100 Figure 7-13: Habitats identified within the Marievale Project area ...... 102 Figure 7-14: Habitats identified within the Marievale Project area...... 103 Figure 7-15: Habitats identified within the Marievale Project ‘initial development area’...... 103 Figure 7-16: The habitats observed within the project area; A) Transformed B) Degraded Grassland ...... 104 Figure 7-17: Examples of some of the habitats observed within the project area; A) Secondary Grassland B) Wetlands...... 105

Figure 7-18: Gauteng C-Plan...... 106 Figure 7-19: The project area in relation to the Blesbokspruit Ramsar site...... 107 Figure 7-20: The project area showing the ecosystem threat status of the associated terrestrial ecosystems (NBA, 2018)...... 108 Figure 7-21: The project area in relation to the NBA Rivers (BGIS, 2018)...... 109 Figure 7-22 Marievale project area in relation to NFEPA wetlands ...... 110 Figure 7-23: The project area in relation to the NBA wetlands (BGIS, 2018) ...... 111 Figure 7-24: Map showing the grid drawn to compile an expected species list (BODATSA-POSA, 2016)...... 114 Figure 7-25: Hydrophytic plants identified within the delineated wetlands. A: Phragmites australis. B: Schoenoplectus spp. C: Kylinga erecta. D: Juncus kraussii. E: Paspalum dilatatum. F: Verbena spp. G: Juncus rigidus. H: Agrostis lachnantha...... 115 Figure 7-26: Plant species recorded during the survey: A) Walafrida densiflora, B) Pelargonium luridum, C) Monopsis decipiens, D) Hypoxis rigidula, E) Hypoxis iridifolia and F) Hibiscus aethiopicus...... 116 Figure 7-27: Some invasive plant species recorded in the project area: A) Hibiscus trionum, B) Verbena bonariensis, C) Eucalyptus sp., and D) Campuloclinium macrocephalum...... 117 Figure 7-28: Avifaunal species recorded during the survey: A) Pied kingfisher (B) Southern Red Bishop (C) Cape Longclaw, D) Grater flamingo, E), Red-billed teal , F) White throated sparrows, G) White-faced ducks, H) Yellow-billed ducks, I) Reed Cormorant and J) Red-knobbed Coot...... 120 Figure 7-29: Some of the amphibians recorded in the project area: A) Common sand frog (Tomopterna cryptotis) and B) Giant Bullfrog (Pyxicephalus adspersus) froglet ...... 123 Figure 7-30: Delineation of wetlands and within the 500 m regulated area ...... 124 Figure 7-31: Some of the impacts observed. A) Building rubble, B & F) Litter, C) Cattle, D & E) Existing mining infrastructure and pipelines, G) Roads, E) Agriculture and F) Erosion...... 127 Figure 7-32: Buffer zones assigned to proposed components (tailings facilities and pipelines) ...... 131 Figure 7-33: Habitat sensitivity within Marievale project area...... 132 Figure 7-34: Habitat sensitivity within the project area...... 132 Figure 7-35: Habitat sensitivity within the adjusted project area footprint ...... 133 Figure 7-36: Location of the SCCs in the project area ...... 134 Figure 7-37: Some of the impacts observed: A) Building rubble, B & F) Litter, C) Cattle, D & E) Existing mining infrastructure and pipelines, G) Roads, E) Agriculture and F) Erosion ...... 135 Figure 7-38: Ergo surface water quality monitoring locations ...... 138 Figure 7-39: 1:100 year floodline ...... 144 Figure 7-40: Existing trench running along the northern side of Dumps 7L5 and 7L6 ...... 146 Figure 7-41: Proposed channel and berm design ...... 146 Figure 7-42: Proposed conceptual stormwater management plan for Dumps 7L5 and 7L6 ...... 147 Figure 7-43: Proposed conceptual stormwater management plan for Dump 7L7 ...... 148 Figure 7-44: Silted toe paddocks at Dump 7L5 ...... 149 Figure 7-45: Dump 7L5 monthly water balance (m³/month) ...... 151 Figure 7-46: Dump 7L6 monthly water balance (m³/month) ...... 152 Figure 7-47: Dump 7L7 monthly water balance (m³/month) ...... 152 Figure 7-48: Historical borehole locality map ...... 155 Figure 7-49: Hydrocensus boreholes ...... 158 Figure 7-50: Correlation between surface and groundwater elevations in hydrocensus BHs ...... 159

Figure 7-51: Trace metal and batch leach tests for Marievale soil sample (Coetzee et al, 2005)...... 166 Figure 7-52: Cross section through the aquifers present ...... 168 Figure 7-53: Tailings seepage quality for the Daggafontein TSF ...... 170 Figure 7-54 Scenario 3: Sulphate concentrations in the weathered aquifer if reclamation includes footprint soil rehabilitation ...... 177 Figure 7-55 Scenario 3: Sulphate concentrations in the fractured aquifer above the Green Sill if reclamation includes footprint soil rehabilitation ...... 178 Figure 7-56. Scenario 3: Iron concentrations in the weathered aquifer if reclamation includes footprint soil rehabilitation ...... 179 Figure 7-57. Scenario 3: Iron concentrations in the fractured aquifer above the Green Sill if reclamation includes footprint soil rehabilitation ...... 180 Figure 7-58: Sensitive receptors within a radius of approximately 10 km from the Marievale Project area. 183 Figure 7-59: Large sources of airborne particulate matter and monitoring stations in the vicinity of the Marievale Project area ...... 184

Figure 7-60: Daily average PM10 concentrations for the Diepkloof air quality monitoring station (SAAQIS, 2019)...... 185

Figure 7-61: Modelled prediction of highest 24-hour average PM10 concentrations resulting from the undisturbed 7L5, 7L6 and 7L7 TSFs...... 186

Figure 7-62: Modelled prediction of the annual average PM10 concentrations resulting from the undisturbed 7L5, 7L6 and 7L7 TSFs...... 187

Figure 7-63: Modelled prediction of the highest 24-hour average PM2.5 concentrations resulting from the undisturbed 7L5, 7L6 and 7L7 TSFs...... 187

Figure 7-64: Modelled prediction of annual average PM2.5 concentrations resulting from the undisturbed 7L5, 7L6 and 7L7 TSFs...... 188

Figure 7-65: Modelled prediction of the highest 24-hour average PM10 concentrations resulting from starting reclamation at the 7L7 southernmost area...... 189

Figure 7-66: Modelled prediction of the highest 24-hour average PM2.5 concentrations resulting from starting reclamation at the 7L7 southernmost area ...... 190

Figure 7-67: Modelled prediction of the highest 24-hour average PM10 concentrations resulting from starting reclamation at both the 7L7 and 7L6 southernmost areas...... 190

Figure 7-68: Modelled prediction of the highest 24-hour average PM2.5 concentrations resulting from starting reclamation at both the 7L7 and 7L6 southernmost areas...... 191

Figure 7-69: Modelled prediction of the highest 24-hour average PM10 concentrations resulting from the Marievale Project area after reclamation is completed...... 192 Figure 7-70: Modelled prediction of the highest 24-hour average PM2.5 concentrations resulting from the Marievale Project area after reclamation is completed...... 193 Figure 7-71: Tracklogs of the fieldwork undertaken (red line) ...... 196 Figure 7-72: Type of dwelling within the project area ...... 217 Figure 7-73: Population by employment status (Source: Census 2011) ...... 218 Figure 7-74: Measurement Localities ...... 227 Figure 7-75: Aerial image indicating potentially noise-sensitive developments close to proposed reclamation activities ...... 234

Figure 7-76: Projected conceptual daytime construction noise levels – Pump station infrastructure at Dump 7L7 ...... 235 Figure 7-77: Projected conceptual daytime operational noise rating levels – Reclamation at Dump 7L7 ..... 236 Figure 7-78: Projected conceptual night-time operational noise rating levels – Reclamation at Dump 7L7 . 237 Figure 7-79: Future roads planned for the project area ...... 240 Figure 7-80: Key plan and road sign locations ...... 243 Figure 7-81: Proposed access road details ...... 244 Figure 8-1: Impact prediction model...... 246 Figure 8-2: The mitigation hierarchy as described by the DEA (2013) ...... 304 Figure 8-3: Wetland systems located within the assigned buffer proximity of the proposed reclamation sites ...... 305 Figure 8-4: Wetland systems located within the assigned buffer proximity of the proposed pipeline areas (northern portion of the project area) ...... 306 Figure 8-5: Wetland systems located within the assigned buffer proximity of the proposed pipeline areas (south-eastern portion of the project area) ...... 307 Figure 8-6: Wetland systems located within the assigned buffer proximity of the proposed pipeline areas (western portion of the project area) ...... 308 Figure 9-1: Regulated Buffer Area of 500 m ...... 342

Tables

Table 1-1: Description of the Directly Affected Properties ...... 7 Table 1-2: Property Details ...... 8 Table 1-3: 21-digit Surveyor General Code for each Farm Portion (Directly Affected) ...... 9 Table 1-4 : Proposed Environmental Authorisations (EAs) within the project vicinity ...... 12 Table 1-5: Details of the EAP ...... 13 Table 1-6: Details of the Kongiwe Project Team ...... 14 Table 1-7: Details of the Specialist Team ...... 14 Table 1-8: Structure of the Final EIA Report in line with the Appendix 2 of the EIA 2014 Regulations ...... 15 Table 2-1: Listed Activities Triggered by the Proposed Project...... 24 Table 2-2: Project perspective and technical details...... 30 Table 2-3: Estimated timeframes and deadlines of the different phases associated with the Marievale Project ...... 32 Table 2-4: Summary table of the Activities associated with the different phases of the proposed project .... 32 Table 2-5: Potential identified impact because of the Proposed Project...... 38 Table 2-6: Potential identified environmental and social impact of the Proposed Project...... 40 Table 2-7: A summary of the deviations from Scoping Phase to EIA Phase...... 43 Table 3-1: The advantages and disadvantages of the Marievale Project operations ...... 46 Table 3-2: The advantages and disadvantages of hydraulic reclamation ...... 49 Table 4-1: Applicable National Legislation and Guidelines ...... 52 Table 4-2: Applicable Provincial and Local Policies, Guidelines and By-Laws ...... 64 Table 6-1: Activities undertaken and to be undertaken during the public participation process ...... 77 Table 6-2: Public places where the Draft Scoping Report can be accessed ...... 82 Table 6-3: Summary of PP activities during the Draft Scoping Phase ...... 83 Table 6-4: Summary of PPP activities undertaken during the Final Scoping Phase ...... 85 Table 6-5: Public places where the Draft EIA/EMPr reports could be accessed ...... 85 Table 6-6: Details of the Open Day ...... 86 Table 6-7: Summary of PPP activities -Draft Environmental Impact Assessment Phase ...... 87 Table 6-8: Summary of the PPP activities-Final EIA phase ...... 89 Table 6-9: Summary of the PPP activities-Final EIA phase ...... 90 Table 7-1: Storm rainfall depths for the Project ...... 92 Table 7-2: Symons Pan and open water evaporation for the project ...... 93 Table 7-3: Summary of Desktop spatial features examined ...... 101 Table 7-4: Plant Species of Conservation Concern (SCC) expected to occur in the project area (BODATSA-POSA, 2016) ...... 114 Table 7-5: List of bird species of regional or global conservation importance that are expected to occur in pentads 2610_2820; 2610_2825; 2610_2830; 265_2820; 2615_2825; 2615_2830; 2620_2820; 2620_2825; 2620_2830...... 118 Table 7-6: A list of the avifauna species recorded in the project area ...... 120 Table 7-7: List of mammal species of conservation concern that may occur in the greater project area as well as their global and regional conservation statuses (IUCN, 2017; SANBI, 2016) ...... 121

Table 7-8: List of amphibian species of conservation concern that may occur in the project area as well as their global and regional conservation statuses (IUCN, 2017; SANBI, 2016)...... 122 Table 7-9 Wetland classification as per SANBI guideline (Ollis et al. 2013) ...... 124 Table 7-10: The ecosystem services being provided by the identified HGM unit 1 – 16...... 126 Table 7-11: Summary of the scores for the Wetland PES ...... 128 Table 7-12: The Ecological Importance and Sensitivity results...... 130 Table 7-13: Summary of Ergo’s surface water quality monitoring locations on the Blesbokspruit...... 136 Table 7-14: Surface water quality results for the Marievale Project where limits are tolerable or exceeded...... 139 Table 7-15: Catchment parameters and calculated 1:100 year peak flows ...... 142 Table 7-16: Parameters and assumptions/sources used in the water balance calculations ...... 150 Table 7-17. Daggafontein TSF monitoring sites - Ergo ...... 153 Table 7-18: NGA boreholes - DHSWS ...... 153 Table 7-19: Council for Geosciences sampling sites ...... 156 Table 7-20. 2019 Hydrocensus data ...... 160 Table 7-21: Marievale water quality – December 2019 ...... 164 Table 7-22. Aquifer parameters used during the assessment (after AGES, 2006) ...... 168 Table 7-23: Daggafontein TSF seepage, surface water and groundwater qualities ...... 169 Table 7-24. Water balance calculations (pers. comm. Mr Andy Pirie) ...... 171 Table 7-25. Pathways and receptors ...... 172 Table 7-26. Applicable In-stream Water Quality Guidelines for the Blesbokspruit Catchment ...... 173 Table 7-27. Quantification of impacts if reclamation does not include footprint rehabilitation ...... 175 Table 7-28: Short-term and long-term health effects associated with exposure to PM (WHO, 2004)...... 182 Table 7-29: Medium to High Significance Heritage sites identified during the Marievale fieldwork ...... 197 Table 7-30: Anticipated Social Impacts of the proposed project ...... 220 Table 7-31: Equipment used to gather data ...... 226 Table 7-32: Summary of ambient sound levels measured onsite ...... 228 Table 7-33: Potential maximum noise levels generated by construction equipment ...... 230 Table 7-34: Potential equivalent noise levels generated by various equipment ...... 230 Table 7-35: Surrounding Road Network ...... 239 Table 7-36: Development Peak Hour Generated Trips ...... 241 Table 7-37: Site parking requirements ...... 245 Table 8-1: Consequence rating definitions...... 246 Table 8-2: Consequence rating methodology...... 247 Table 8-3: Significance rating methodology...... 248 Table 8-4: Summary table of the Activities associated with the construction phase of the project ...... 248 Table 8-5: Assessment of significance of potential construction impacts on Biodiversity ...... 249 Table 8-6: Assessment of significance of potential construction impacts on Biodiversity ...... 250 Table 8-7: Assessment of significance of potential construction impacts on Biodiversity ...... 251 Table 8-8: Assessment of significance of potential construction impacts on Biodiversity ...... 252 Table 8-9: Assessment of significance of potential construction impacts on Biodiversity ...... 253 Table 8-10: Assessment of significance of potential construction impacts on Biodiversity ...... 254 Table 8-11: Assessment of significance of potential construction impacts on Biodiversity ...... 255

Table 8-12: Potential risk posed by the reclamation activities (including pipelines) ...... 257 Table 8-13: DWS Risk Impact Matrix for the proposed project ...... 259 Table 8-14: DWS Risk Impact Matrix for the proposed project continued ...... 260 Table 8-15: Summary of activities and impacts for the construction phase ...... 262 Table 8-16: Significance rating of construction impact 1...... 262 Table 8-17: Construction Phase water quality impacts...... 263 Table 8-18: All project Phases - Air Quality impacts...... 264 Table 8-19: Impacts on possible heritage resources during the construction phase: Historical Structures – Mining ...... 266 Table 8-20: Impacts on possible heritage resources during the construction phase: Burial Grounds and Graves ...... 267 Table 8-21: Impacts on Job security and skills development ...... 268 Table 8-22: Impacts of stimulating economic growth...... 269 Table 8-23: Safety impacts for employees and communities ...... 269 Table 8-24: Town planning and residential interface ...... 270 Table 8-25: Exposure to dust fallout and health impacts...... 271 Table 8-26: Ecosystem Services impacts ...... 271 Table 8-27: Impacts on movement patterns ...... 272 Table 8-28: Informal settlements ...... 273 Table 8-29: Numerous simultaneous construction activities during the day ...... 274 Table 8-30: Potential construction, maintenance and repair activities during the day ...... 274 Table 8-31: Construction and Operation Traffic Impacts ...... 275 Table 8-32: Construction and operation traffic impacts ...... 275 Table 8-33: Construction and operation traffic impacts ...... 276 Table 8-34: Summary table of the Activities associated with the operational phase of the project ...... 277 Table 8-35: Significance rating of operational impacts on Biodiversity during operation ...... 277 Table 8-36: Significance rating of operational impacts on Biodiversity during operation ...... 278 Table 8-37: Significance rating of operational impacts on Biodiversity during operation ...... 279 Table 8-38: Significance rating of operational impacts on Biodiversity during operation ...... 280 Table 8-39: Significance rating of operational impacts on Biodiversity during operation ...... 280 Table 8-40: Significance rating of operational impacts on Biodiversity during operation ...... 281 Table 8-41: Potential risk posed by the reclamation activities (including pipelines) ...... 283 Table 8-42: DWS Risk Impact Matrix for the proposed project ...... 283 Table 8-43: Summary of activities and impacts for the operational phase ...... 285 Table 8-44: Significance rating of operational impact 1...... 286 Table 8-45: Significance rating of operational impact 2 ...... 286 Table 8-46: Significance rating of operational impact 3 ...... 287 Table 8-47: Significance rating of operational impact 4 ...... 288 Table 8-48: Significance rating of operational impact 5 ...... 288 Table 8-49: Operational Phase water quality impacts...... 290 Table 8-50: Operational Phase water quantity impacts...... 291 Table 8-51: Impacts on Job security and skills development ...... 292 Table 8-52: Impacts of stimulating economic growth...... 293

Table 8-53: Safety Impacts for employees and communities ...... 293 Table 8-54: Town planning and residential interface ...... 294 Table 8-55: Exposure to dust fallout and health impacts...... 295 Table 8-56: Ecosystem Services impacts ...... 295 Table 8-57: Impacts to movement ...... 296 Table 8-58: Informal Settlements ...... 297 Table 8-59: Numerous simultaneous operational activities during the day ...... 297 Table 8-60: Numerous simultaneous operational activities during the night ...... 298 Table 8-61: Summary table of the Activities associated with this decommissioning phase of the project .... 299 Table 8-62: Assessment of significance of potential decommissioning of the development pre- and post- mitigation ...... 299 Table 8-63: Assessment of significance of potential decommissioning of the development pre- and post- mitigation ...... 300 Table 8-64: Assessment of significance of potential decommissioning of the development pre- and post- mitigation ...... 300 Table 8-65: Potential risk posed by the reclamation activities (including pipelines) ...... 302 Table 8-66: DWS Risk Impact Matrix for the proposed project ...... 302 Table 8-67: Summary of activities and impacts for the decommissioning phase...... 310 Table 8-68: Significance rating of decommissioning impact 1 ...... 311 Table 8-69: Decommissioning Phase water quality impacts...... 312 Table 8-70: Impacts on Job security and skills development ...... 313 Table 8-71: Impact on economic revenue ...... 314 Table 8-72: Impacts on the availability of alternative land uses ...... 315 Table 8-73: Creation of informal settlements ...... 315 Table 8-74: Safety impacts ...... 316 Table 8-75: Impacts on movement patterns ...... 317 Table 8-76: Town planning and residential interface ...... 317 Table 8-77: Intrusive impacts ...... 318 Table 8-78: Ecosystem Services impacts ...... 318 Table 8-79: Summary table of the Activities associated with this post-decommissioning phase of the project ...... 319 Table 8-80: Post Decommissioning Phase water quality impacts ...... 320 Table 8-81: Cumulative impact rating for surface water quality...... 321 Table 8-82: Cumulative impact rating for surface water quality...... 322 Table 8-83: Cumulative impact rating for groundwater ...... 324 Table 8-84: Cumulative impacts on heritage resources in the area ...... 324 Table 8-85: Cumulative impacts on heritage resources in the area: Historical Structures - Mining ...... 325 Table 8-86: Cumulative impacts on heritage resources in the area: Burial grounds and graves ...... 325 Table 9-1: Literature-based aquifer parameters considered ...... 343 Table 9-2: Model water balance ...... 344

Appendices

Appendix A: EIA Project Team CV’s

Appendix B: Maps

❖ Appendix B1: Locality Map ❖ Appendix B2: Land Tenure ❖ Appendix B3: Project Infrastructure map ❖ Appendix B4: Project Land use Map ❖ Appendix B5: Gauteng C-Plan ❖ Appendix B6: NEFEPA Wetlands ❖ Appendix B6: Site Photographs

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 and Wetlands ❖ Appendix D2 – Surface Water ❖ Appendix D3 – Groundwater ❖ Appendix D4 – Air Quality ❖ Appendix D5 – Heritage and Palaeontology ❖ Appendix D6 – Social ❖ Appendix D7 – Traffic Statement ❖ Appendix D8 - Noise Report

Appendix E: The Environmental Management Plan report (EMPr)

Abbreviations

ABBREVIATION/ SYMBOL DESCRIPTION AMD Acid Mine Drainage BID Background Information Document CA Competent Authority/Authorities CARA Conservation of Agricultural Resources Act, 1983 (No. 43 of 1983) CBA Critical Biodiversity area CR Critically Endangered CRG Central Rand Group CRR Comments and Response Report CSIR Council for Scientific and Industrial Research dBA Decibels DEFF Department of Environment, Forestry and Fisheries DMRE Department of Mineral Resources and Energy DALRRD Department of Agriculture, Land Reform and Rural Development DSR Draft Scoping Report DHSWS Department of Human Settlements, 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 HGM1 Channelled valley bottoms HGM2 Hillslope seeps 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 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 mg/m2/day Milligram per cubic metre per day Mg/L Milligrams per litre MPRDA Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002)

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 NPi National Pollutant inventory 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 Particulate Matter 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 S&EIA Scoping, Environmental Impact Assessment and Environmental Management 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

CHAPTER 1: INTRODUCTION

Kongiwe Environmental (Pty) Ltd (‘Kongiwe’) has been appointed as the Independent Environmental Assessment Practitioner (EAP), tasked with conducting the Scoping and Environmental Impact Assessment (S&EIA) process which is aimed at critically evaluating the potential environmental and social impacts of the proposed Marievale Project (hereafter the Proposed Project).

1.1 Historical Project Background

Gold was first discovered in the project area (on the Farm Varkensfontein) in 1887 by a group of prospectors on their way to Johannesburg. The owner of the farm, Mr. Johannes Petrus Marais, subsequently started the Nigel Gold Mining Company (Davenport 2013; Erasmus 2014). Around the same time, low quality coal was being mined, and in 1891 the first railway line in the Transvaal (the ‘Rand Tram’) was built. The Rand Tram transported coal from the newly discovered coal fields on the East Rand to the gold mines on the Central Witwatersrand. It was the construction of this line that resulted in the rapid development of the coal mining industry in present-day Springs and surrounding areas (Erasmus, 2014). It was not until 1908 that gold mining expanded rapidly in Springs. A requirement for more residential land lead to the proclamation of Nigel, as a township, in 1912.

Figure 1-1: Historic mining activities within the Johannesburg area.

The Marievale Gold Mine & Estates Company and the Nigel East Gold Mining Company were the first two companies to commence gold prospecting and mining in 1896 on the three main affected farms of the Marievale Project: Vogelstruisbult 127 IR, Vlakfontein 281 IR and Marievale 282 IR. With news of successful prospects, gold mining thrived in Springs and Nigel and by 1933, there were several companies involved in extraction operations. These additional companies included the Marievale Nigel Gold Mine and Estates company, East Nigel and Consolidated Goldfields, Lydenburg Gold Farms, Vogelstruisbult Proprietary Limited, Vogelstruisbult Gold Mining Areas Limited and the Daggafontein Gold Mining Company.

The Marievale Nigel Gold Mines & Estate ceased mining on Farm Marievale 282 IR in 1911 but continued to derive a revenue from claim licences and mynpachts (Skinner, 1911). A reduction plant was constructed on Vogelstruisbult 127 IR in 1936, and the associated mill-house was believed to be the first all-concrete mill building on a Reef mine. Rudd (1995) notes that Vogelstruisbult closed down its gold operations in 1968 and in August 1969, the headgear at No. 3 shaft was taken down. In 1967, the old uranium plant situated at No. 1 shaft area of Vogelstruisbult was used for the construction of an electrolytic zinc plant as part of the formation of a new company, the Zinc Corporation of SA, by Gold Fields SA, Iscor and Vogelstruisbult. It is believed that the Lydenburg Gold Farms Company operated on Vlakfontein 281 IR and was associated with the Johannesburg Consolidated Investment Company. This company abandoned operations in 1910.

By 1960, approximately 14 gold mines between Nigel and Springs existed. Although not operational today, the success of gold mining is represented by the numerous historic TSFs along the Witwatersrand Goldfields. From the above, it is assumed that the Marievale 7L5, 7L6 and 7L7 are approximately 47 to 63 years old and are landscape representations of mining infrastructure associated with the historical mining townscapes and settlements of the East Rand.

Figure 1-2: Mine workers at Comet Gold Mine 1903 (left) and Simmer and Jack Mine 1939 (right)

1.2 The Origin of Mine Dumps in Johannesburg

In laymen’s terms the phrase ‘mine dump’ refers to an area where excess material, containing forms of mineral(s) that are either valuable or not, is left by the person who has won the minerals from the earth in

accordance with his/her right or entitlement to mine. Prior to the enacting of legislative controls such as the Mines And Works Act, 1956 and its Regulations and later still the Minerals Act, 1991 and finally, the Mineral and Petroleum Resources Development Act, 2002 (No. 28 of 2002) (“the MPRDA“), which came into effect on 1 May 2004, mine dumps were placed in convenient positions adjacent to mining operations. This was often along fault lines, or within wetland areas. It is the legacy of these mine dumps within sensitive areas that has caused the environmental and health effects that are felt today.

As the mines in the project area began to close down during the 1970’s, technological advances enabled the extraction of valuable gold resources and other minerals from the dumps. In 1978 the East Rand Gold and Uranium Company (Ergo) began to reclaim some of these dumps to gain access to the residues of gold, uranium and pyrite. Over the last two decades there have been further advances in mining and metallurgical technologies and an evolution in the country’s environmental policy and legislation. This, as well as increasing gold prices, has further incentivised the reclamation of TSFs.

1.3 Marievale Project Introduction

Ergo will make use of its sophisticated metallurgical processes which make it viable to retreat the historic Marivale TSFs and extract the residual gold, having retreated millions of tonnes of material since its inception in December 1977. Sampling in Marievale concluded that the dumps contain approximately 51.6Mt at an average grade of 0.289 g/t. With the upturn of the gold price, the grade and tonnage in the Marivale TSFs has become economically viable to exploit. Although gold will be the main mineral prospected for, the concentrations of uranium, nickel and silver will also be investigated in conjunction with the availability of stone, gravel and waste rock.

Although there is a strong economic case for the project, the removal of these dumps also forms part of DRDGold Limited’s broader strategy to align to the National Environmental Management Act (Act 109, 1998) EIA Regulations, in accordance with the One-Environmental system for the reclamation of historic mine residue tailings. Incorporated in this strategy is the need to clean-up and remove pollution point-sources across Gauteng and contain them in two mega facilities known as the Brakpan/Withok TSF and the Regional TSF (RTSF – to still be constructed). It is envisioned that the Brakpan/Withok TSF will hold tailings retreated and removed on the East Rand, and the RTSF will hold tailings treated and removed on the West Rand. Following the removal of the Marievale TSFs, Ergo intends to rehabilitate the land to a state that is sustainable, functioning and represents a pre-mining landscape.

Ergo intends to conduct the project in accordance with the summary flow diagram and description in the figure below.

Figure 1-3: A short summary of the Proposed Project Process

Before reclamation can commence, the sites will be prepared to prevent unwanted material from entering the slurry. Suitable aggregate will be stockpiled and cleared vegetation may be sold locally or disposed at a licenced facility.

A baseline radiological assessment will be undertaken by a registered professional once the site has been cleared of vegetation. Temporary and mobile (park home) site infrastructure will be established either at the reclamation sites or at the Daggafontein plant with existing connections to the power grid and potable water sources. As part of construction and site preparation activities, the existing Marievale paddocks and stormwater systems will be reinstated and upgraded for capturing and managing dirty water around the site.

Once site preparation and construction are completed, hydraulic reclamation can begin. To excavate unconsolidated tailings material within the TSFs, a high pressure water monitor (or cannon) will be directed onto the face of the TSF. Reclamation will take place in predetermined benches (or ‘cuts’) and will move unidirectionally until the entire TSF has been reclaimed. Generally, 30 m – 40 m cuts are made as reclamation progresses. The water from the monitor mixes with the tailings and forms a slurry with a high solid content. The slurry then flows under gravity, along the base of the TSF to a collection sump which is positioned at the lowest elevation of the bench being reclaimed. The collection sump is then able to filter and screen appropriately sized slurry, and direct this into pipelines which will pump the slurry to the existing Ergo Plant for gold recovery. Residual slurry will then be pumped to the licenced Brakpan/Withok TSF. The water which accumulates atop the Brakpan/Withok TSF will be pumped and reused for various Ergo operations.

Project Rehabilitation and Future Land Use

1.3.1.1 The Blesbokspruit wetland system and the Marievale Bird Sanctuary

The current land uses of the surrounding areas are typified by mining and agricultural activities, dispersed settlements, sensitive areas (i.e. the Marievale Bird Sanctuary Nature Reserve and Blesbokspruit Wetland System) and sections of TSFs.

The Ramsar Convention on Wetlands of International Importance especially as Waterfowl Habitat is an international treaty for the conservation and sustainable use of wetlands (Ramsar, 2014). South Africa currently has 29 Ramsar sites with a combined surface area of about 558 000 Ha. In the 1980s the Blesbokspruit wetland was used as a refuge for at least 20 000 waterbirds, which contributed to the declaration of this site as a Ramsar Wetland of International Importance in 1986. The Blesbokspruit Ramsar site is the only one found in Gauteng.

The Blesbokspruit wetland area comprises approximately 2 000 ha of privately and state owned land and is located to the East of Springs. This area covers approximately a 20 km section of the Blesbokspruit, which stretches from Grootvlei in the North to Marievale in the South. The wetland is one of the “Important Bird Areas of Gauteng” and includes both the Springs Bird Sanctuary and the Marievale Bird Sanctuary. This wetland system is home to 230 species, of which 65 waterbird species can be exclusively found in the Marievale portion. Species of conservation concern in this area include African Grass Owl, Lesser- and Greater Flamingos, and White-bellied Korhaan. The Spotted-necked Otter has also been found in this habitat.

Figure 1-4: Marievale Land use Map

1.4 Description of the Project Location

The Marievale project will be confined to farms Vogelstruisbult 127 IR and Vlakfontein 281 IR, as well as all farms to be affected by the final pipeline route.

This is a “Brownfield Project" as it is the reclamation of historical tailings deposits with partly existing infrastructure. The potential negative and positive impacts of the Proposed Project on the environmental and social aspects will be objectively considered though studies undertaken by specialist professionals during the EIA phase.

Dumps 7L5 and 7L6 are both located on Portion 0 (RE) of the farm Vogelstruisbult 127 IR; while dump 7L7 is located on Portion 0 (RE) of Vlakfontein 281 IR farm. Other properties have been identified as directly and indirectly affected landowners due to the pipeline alternatives of the project. See Table 1-1 and Table 1-3.

Table 1-1: Description of the Directly Affected Properties

Farm Names Farm Name: Farm ID Portion Landowner

Vogelstruisbult 127 IR 0 (RE) Ekurhuleni Metropolitan Municipality

Vogelstruisbult 127 IR 3 Ekurhuleni Metropolitan Municipality

Kwa Thema 210 IR 35 Kwa- Thema Ext3 Kwa Thema 210 IR 4 Kwa Thema Township Kwa Thema 210 IR 33 Ekurhuleni Metropolitan Municipality Kwa Thema 210 IR 28 Ekurhuleni Metropolitan Municipality

Daggafontein 125 IR 1 (RE) STI Consulting Services (Pty) Ltd Daggafontein 125 IR 104 Struisbult Ext 1 Township Daggafontein 125 IR 108 WMG Estates (Pty) Ltd Daggafontein 125 IR 110 To be determined Daggafontein 125 IR 112 I&W Van Der Merwe Boerdery (Pty) Ltd Daggafontein 125 IR 114 Fondagtuin Landgoed CC Daggafontein 125 IR 117 (RE) CLPF Prop Inv (Pty) Ltd Daggafontein 125 IR 122 Daggafontein Ext 2 Daggafontein 125 IR 123 Struisbult Ext 1 Township Daggafontein 125 IR 126 STI Consulting Services (Pty) Ltd Daggafontein 125 IR 127 (RE) Palmkuilen (Pty) Ltd Daggafontein 125 IR 128 EBM Project (Pty) Ltd Daggafontein 125 IR 137 Transnet Ltd Daggafontein 125 IR 146 Greater East Rand Metro Daggafontein 125 IR 151 (RE) East Rand Water Care Company Daggafontein 125 IR 154 (RE) EBM Project (Pty) Ltd Daggafontein 125 IR 159 Rappa Resources (Pty) Ltd

Daggafontein 125 IR 180 C L P F PROP INV PTY LTD (T12648/1992) Daggafontein 125 IR 181 EAST RAND WATER CARE COMPANY Daggafontein 125 IR 184 South African National Roads Agency Ltd Daggafontein 125 IR 196 STI CONSULTING SERVICES PTY LTD Daggafontein 125 IR 197 STI CONSULTING SERVICES PTY LTD Daggafontein 125 IR 199 STI CONSULTING SERVICES PTY LTD

Witklip (Vulcania) 279 IR 0 (RE) IPROP (Pty) Ltd

Grootvaly 124 IR 1 (RE) GROOTVALY-AH

Marievale 282 IR 282 Marievale Nature Reserve

Vlakfontein 130 IR 10 Eskom Vlakfontein 130 IR 92 First Trade & Invest 4 (Pty) Ltd Vlakfontein 130 IR 96 Shell Downstream South Africa (Pty) Ltd Vlakfontein 130 IR 85 First Trade & Invest 4 (Pty) Ltd Vlakfontein 281 IR 0 (RE) Scarlet Sun 33 (Pty) Ltd Vlakfontein 281 IR 9 Ilangabi

Grootfontein 165 IR 0 (RE) Gauteng Provincial Government Grootfontein 165 IR 10 Transnet Ltd Grootfontein 165 IR 29 Inyanga Trading 102 ((Pty)) Ltd Grootfontein 165 IR 82 Nigel Municipality Grootfontein 165 IR 85 Greater Nigel Transitional Local Council Grootfontein 165 IR 99 GAUTENG PROVINCIAL GOVERNMENT (T102481/2015)

Rietfontein 128 IR 0 (RE) MUN Springs Rietfontein 128 IR 81 (RE) Vereeniging Properties & Investment (Pty) Ltd Rietfontein 128 IR 175 Ekurhuleni Metropolitan Municipality

Witpoortje 117 IR 1 (RE) Witpoort Estate Witpoortje 117 IR 183 Ergo Mining (Pty) Ltd) Witpoortje 117 IR 150 Vulcania Suid Ext 2

Table 1-2: Property Details

Application Area The Proposed Project site covers a combined area of approximately 140 Ha. (ha) Magisterial Ward 88 of Ekurhuleni Metropolitan Municipality (EMM). District Distance and The site is located approximately 6 km north-east from Nigel, 10 km south-east of Springs and falls

Direction from within the Ekurhuleni Metropolitan Municipality district. Nearest Town

Table 1-3: 21-digit Surveyor General Code for each Farm Portion (Directly Affected)

Farm Names Farm Name: Farm ID Portion SG Code

Vogelstruisbult 127 IR 0 (RE) T0IR00000000012700000

Vogelstruisbult 127 IR 3 T0IR00000000012700003

Kwa Thema 210 IR 35 T0IR00000000021000035 Kwa Thema 210 IR 4 T0IR00000000021000004 Kwa Thema 210 IR 33 T0IR00000000021000033 Kwa Thema 210 IR 28 T0IR00000000021000028

Daggafontein 125 IR 1 (RE) T0IR00000000012500001 Daggafontein 125 IR 104 T0IR00000000012500104 Daggafontein 125 IR 108 T0IR00000000012500108 Daggafontein 125 IR 110 T0IR00000000012500110 Daggafontein 125 IR 112 T0IR00000000012500112 Daggafontein 125 IR 114 T0IR00000000012500114 Daggafontein 125 IR 117 (RE) T0IR00000000012500117 Daggafontein 125 IR 122 T0IR00000000012500122 Daggafontein 125 IR 123 T0IR00000000012500123 Daggafontein 125 IR 126 T0IR00000000012500126 Daggafontein 125 IR 127 (RE) T0IR00000000012500127 Daggafontein 125 IR 128 T0IR00000000012500128 Daggafontein 125 IR 137 T0IR00000000012500137 Daggafontein 125 IR 146 T0IR00000000012500146 Daggafontein 125 IR 151 (RE) T0IR00000000012500151 Daggafontein 125 IR 154 (RE) T0IR00000000012500154 Daggafontein 125 IR 159 T0IR00000000012500159 Daggafontein 125 IR 180 T0IR00000000012500180 Daggafontein 125 IR 181 T0IR00000000012500181 Daggafontein 125 IR 184 T0IR00000000012500184 Daggafontein 125 IR 196 T0IR00000000012500196 Daggafontein 125 IR 197 T0IR00000000012500197 Daggafontein 125 IR 199 T0IR00000000012500199

Witklip (Vulcania) 279 IR 0 (RE) T0IR00000000027900000

Grootvaly 124 IR 1 (RE) T0IR00000000012400001

Marievale 282 IR 282 T0IR00000000028200000

Vlakfontein 130 IR 10 T0IR00000000013000010 Vlakfontein 130 IR 92 T0IR00000000013000092 Vlakfontein 130 IR 96 T0IR00000000013000096 Vlakfontein 130 IR 85 T0IR00000000013000085 Vlakfontein 281 IR 0 (RE) T0IR000000000281000RE Vlakfontein 281 IR 9 T0IR00000000028100009

Grootfontein 165 IR 0 (RE) T0IR00000000016500000 Grootfontein 165 IR 10 T0IR00000000016500010 Grootfontein 165 IR 29 T0IR00000000016500029 Grootfontein 165 IR 82 T0IR00000000016500082 Grootfontein 165 IR 85 T0IR00000000016500085 Grootfontein 165 IR 99 T0IR00000000016500099

Rietfontein 128 IR 0 (RE) T0IR00000000012800000 Rietfontein 128 IR 81 (RE) T0IR00000000012800081 Rietfontein 128 IR 175 T0IR00000000012800175

Witpoortje 117 IR 1 (RE) T0IR00000000011700001 Witpoortje 117 IR 183 T0IR00000000011700183 Witpoortje 117 IR 150 T0IR00000000011700150

Figure 1-5: Marievale Land Tenure Map

All outstanding landowner information was actively sourced through one-on-one consultations, the Deeds Office and the Surveyor-General’s Office.

1.5 Known Mining Rights held in the Area

This EIA concluded that there are two proposed solar development projects within 30 km of the project site (Environmental Screening Tool, 2019). A solar photovoltaic (PV) and concentrated solar power (CSP) development, with approved EA applications, under consideration. The EIA reference numbers for the developments are 14/12/16/3/3/1/569 and 14/12/16/3/3/2/706 respectively. In addition to this, there are several authorisations proposed for the immediate areas surrounding the Marievale TSFs. These projects are indicated in Table 1-4:

Table 1-4 : Proposed Environmental Authorisations (EAs) within the project vicinity

COMMODITY TYPE OF APPLICANT LOCATION AUTHORISATION MINERAL RIGHT STATUS Clay Prospecting GP 30/5/1/1/2 (10064) On a portion of Portion 85 of the (General), Right PR Farm Grootfontein 165 IR and a Coal and Silica Brikor Limited portion of the Remainder of the Sand (GP 30/5/1/2/2 (10059) Farm Vogelstruisbult 12. (General) MR) Mining Right Ilangabi GP 30/5/1/2/2 (219) MR Stone, Coal Investments 12 RE Vlakfontein 281 IR and Clay (Pty) Ltd Approved Stone Mining Right A portion of Portion 7 of the Farm GP 30/5/1/2/2 (230) MR Ilangabi Aggregate Vlakfontein 281 IR Investments 12 (from Waste Approved (Pty) Ltd Rock) Diamond Prospecting Ilangabi Portion 9 of The Farm Vlakfontein GP/30/5/1/1/2 (10613) Right Investments 12 281 IR PR (Pty) Ltd Coal Mining Right Anglo Operation Farm Palmietkuilen 241 IR, Appealed (Pty) Ltd Coal Mining Right Portions 1, 3, 4, 5, 6, 9, 10, 11, 12, GP30/5/1/2/2/10071MR 13, 14 and 16 of the Farm Bloemendal 283 IR, Portion 3 and the Remaining

Extent of the Farm Rietfontein Totapix (Pty) Ltd 276 IR, Portions 4, 5, 9, 12, 22, 28 and the Remaining Extent of the Farm Nooitgedacht 286 IR,

Portions 1, 2 and the Remaining Extent of the Farm Potfontein 285

COMMODITY TYPE OF APPLICANT LOCATION AUTHORISATION MINERAL RIGHT STATUS IR, and Portions 2 and 7 of the Farm Vlakfontein 281 IR,

1.6 Details of the Independent Environmental Assessment Practitioner (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. 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.

Contact Person and Corresponding Address

Details of the Environmental Assessment Practitioner (EAP) who prepared the report are presented below

Table 1-5: Details of the EAP

NAME OF PRACTITIONER Gerlinde Wilreker

TEL NO +27 (10) 140 6508

FAX NO 086 476 6438

E-MAIL ADDRESS [email protected]

Expertise of the EAP

Gerlinde Wilreker has an M.Sc. in Environmental Management from the Rand Afrikaans University is SACNASP (Registration No: 400261/09) and EAPASA (registration No: 2019/1589) registered. She has 14 years’ work experience, predominantly in the mining industry. Her qualifications can be found in Appendix A.

Summary of the EAP’s Past Experience

Gerlinde is an Environmental Consultant with over twelve years’ work experience, 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 phases through to implementation. She is adept at working in different contexts, and problem-solving with her team to meet client needs. She has particular expertise in relation to Environmental Authorisation Processes in terms of the South African legal regime. Additional Project Team Members that have been integral in the successful production of this Environmental Impact Assessment and Environmental Management Programme (EIA/EMPr) are represented below.

Table 1-6: Details of the Kongiwe Project Team

TEAM MEMBER POSITION IN THE COMPANY ROLE AND RESPONSIBILITIES High-Level project management and Bradly Thornton Chief Executive report review. Gerlinde Wilreker Technical Director (Pr.Sci.Nat) Report review and Authorisation Michael Hennessy Legal Director Legal review of report documentation Ashleigh Blackwell Environmental Consultant EIA report compilation Stakeholder Engagement and all other Public Participation Stakeholder Engagement and Social Sibongile Bambisa requirements Consultant

Social Impact Assessment Assistance with Stakeholder Vanessa Viljoen Social Consultant Engagement and all other Public Participation requirements Nokuthula Ndala GIS Consultant GIS Mapping Compilation of the IWULA and Water Siphesihle Dambuza Environmental Consultant Use Licence process and Scoping phase report compilation.

Independent Specialist Team Members

Several independent specialist consultants have been appointed as part of the S&EIA team to adequately identify and assess potential impacts associated with the proposed project. The specialist consultants have provided input into this EIAr as well as EMPr (Refer to Appendix D).

Table 1-7: Details of the Specialist Team

SPECIALIST STUDY SPECIALIST COMPANY SPECIALIST NAME PEER REVIEWER Biodiversity (Fauna, Andrew Husted (Pr.Sci.Nat) Flora, Wetlands and The Biodiversity Company Ivan Baker (Pr.Sci.Nat) Aquatics) Surface Water HydroSpatial Andy Pirie (Pr.Sci.Nat) Sivan Daher (Pr.Sci.Nat) Groundwater Groundwater Abstract Lucas Smith (Pr.Sci.Nat) Irene Lea (Pr.Sci.Nat) Gondwana Environmental Dr Martin van Nierop Air Quality Anja van Basten Solutions Wouter Fourie (APASA) Jaco van der Walt (ASAPA) Heritage PGS Heritage (APHP) (SAHRA) (AMAFA)

SPECIALIST STUDY SPECIALIST COMPANY SPECIALIST NAME PEER REVIEWER Social Kongiwe Environmental Sibongile Bambisa Gerlinde Wilreker (Pr.Sci.Nat) Traffic EDL Consulting Engineers John van Rooyen Eben D. Kotze (Pr.Tech.Eng) Visual Statement Kongiwe Environmental Foord Ceronio Gerlinde Wilreker (Pr.Sci.Nat) Noise EnviroAcoustic Morne de Jager Morne de Jager

1.7 Structure of this Environmental Impact Assessment report (EIA)

The nature and extent of the proposed project, as well as the potential environmental impacts associated with the construction, operation and decommissioning is assessed and presented in this EIA/EMPr. This EIA has been compiled in terms of the provisions of Appendix 3 and Appendix 4 of the EIA Regulations 2014, as amended, and the Directive set out in the template prescribed by the DMRE. Table 1-8 cross-references the various sections in this report with these requirements.

Table 1-8: Structure of the Final EIA Report in line with the Appendix 2 of the EIA 2014 Regulations

REPORT NEMA REGULATION REQUIREMENT SECTION (a) Details of - (iii) The EAP who prepared the report; and Chapter 1.6 (iv) The expertise of the EAP, including a CV Appendix A

The location of the development footprint of the activity on the approved site as (b) contemplated in the accepted scoping report, including:

(i) The 21-digit Surveyor General code of each cadastral land parcel Chapter 1.1

(ii) Where available, the physical address and farm name Chapter 2 Where the required information in terms of (i) and (ii) is not available, the coordinates (iii) of the boundary of the property or properties A plan which locates the proposed activity or activities applied for as well as the (c) associated structures and infrastructure at an appropriate scale, or, if it is – (i) A linear activity, a description and coordinates of the corridor in which the proposed Appendix B activity or activities is to be undertaken

On land where the property has not been defined, the coordinates within which the (ii) activity is to be undertaken (d) A description of the scope of the proposed activity, including – (i) All listed and specified activities triggered and being applied for Chapter 2.1 Chapter 2.3 to (ii) A description of the associated structures and infrastructure related to the development 2.5

A description of the policy and legislative context within which the development is (e) located and an explanation of how the proposed development complies with and Chapter 4 responds to the legislation and policy context

a motivation for the need and desirability for the proposed development, including the (f) Chapter 5 need and desirability of the activity in the context of the preferred development

REPORT NEMA REGULATION REQUIREMENT SECTION footprint within the approved site as contemplated in the accepted scoping report A motivation for the preferred development footprint within the approved site as (g) Chapter 3 contemplated in the accepted scoping report A full description of the process followed to reach the proposed development footprint (h) Chapter 3 within the approved site as contemplated in the accepted scoping report, including - (i) Details of the development footprint alternatives considered Chapter 3 (ii)

Details of the public participation process undertaken in terms of regulation 41 of the Chapter 2.2.4 Regulations, including copies of the supporting documents and inputs

Appendix C (iii) Chapter 3 A summary of the issues raised by interested and affected parties, and an indication of the manner in which the issues were incorporated, or the reasons for not including them. Appendix C9 (iv) The environmental attributes associated with the development footprint alternatives focusing on the geographical, physical, biological, social, economic, heritage and cultural Chapter 7 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 –

(aa) can be reversed; Chapter 8

(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 potential environmental impacts and Chapter 8.1 risks (vii) Positive and negative impacts that the proposed activity and alternatives will have on the environment and on the community, that may be affected focusing on the Chapter 8.2 geographical, physical, biological, social, economic, heritage and cultural aspects (viii) The possible mitigation measures that could be applied and level of residual risk Chapter 8.3 (ix) If no alternative development footprints for the activity were investigated, the Chapter 3 motivation for not considering such (x) A concluding statement indicating the location of the preferred alternative development Chapter 3 footprint within the approved site as contemplated in the accepted scoping report. A full description of the process undertaken to identify, assess and rank the impacts the activity and associated structures and infrastructure will impose on the preferred (i) Chapter 8.1 development footprint 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 during the (i) Chapter 8.2 environmental impact assessment process an assessment of the significance of each issue and risk and an indication of the extent Chapter 8.2 (ii) to which the issue and risk could be avoided or addressed by the adoption of mitigation

REPORT NEMA REGULATION REQUIREMENT SECTION measures Chapter 8.3 (j) An assessment of each identified potentially significant impact and 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; Chapter 8.3 (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 Regulations and an indication as to how (k) Chapter 8.4 these findings and recommendations have been included in the final assessment report (l) an environmental impact statement which contains- (i) a summary of the key findings of the environmental impact assessment: Chapter 8.4 a map at an appropriate scale which superimposes the proposed activity and its Figure 3.4 associated structures and infrastructure on the environmental sensitivities of the (ii) preferred development footprint on the approved site as contemplated in the accepted Appendix B scoping report indicating any areas that should be avoided, including buffers; and a summary of the positive and negative impacts and risks of the proposed activity and (iii) Chapter 8.4 identified alternatives; Based on the assessment, and where applicable, recommendations from specialist reports, the recording of proposed impact management outcomes for the (m) Chapter 8.3 development for inclusion in the EMPr as well as for inclusion as conditions of authorisation The final proposed alternatives which respond to the impact management measures, (n) Chapter 3 avoidance, and mitigation measures identified through the assessment; Any aspects which were conditional to the findings of the assessment either by the EAP (o) Chapter 9.2 or specialist which are to be included as conditions of authorisation A description of any assumptions, uncertainties and gaps in knowledge which relate to (p) Chapter 9 the assessment and mitigation measures proposed A reasoned opinion as to whether the proposed activity should or should not be (q) authorised, and if the opinion is that it should be authorised, any conditions that Chapter 9.5 should be made in respect of that authorisation Where the proposed activity does not include operational aspects, the period for which (r) the environmental authorisation is required and the date on which the activity will be Chapter 9.6 concluded, and the post construction monitoring requirements finalised

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

(i) the correctness of the information provided in the reports (ii) the inclusion of comments and inputs from stakeholders and I&APs (iii) the inclusion of inputs and recommendations from the specialist reports where relevant Chapter 9.6 any information provided by the EAP to interested and affected parties and any (iv) responses by the EAP to comments or inputs made by interested or affected parties

REPORT NEMA REGULATION REQUIREMENT SECTION Where applicable, details of any financial provision for the rehabilitation, closure, and (t) N/A ongoing post decommissioning management of negative environmental impacts; an indication of any deviation from the approved scoping report, including the plan of (u) study, including- any deviation from the methodology used in determining the significance of potential (i) Chapter 3.1 environmental impacts and risks; and (ii) a motivation for the deviation; (v) Any specific information that may be required by the competent authority Chapter 9.3 (w) Any other matters required in terms of section 24(4)(a) and (b) of the Act N/A

CHAPTER 2: PROJECT DETAILS

This chapter of the EIA provides a description of the requirements for authorisation, the EIA process, project methodologies, infrastructure, life-cycle, layout selection for the Marievale Project.

2.1 Requirements for Environmental Authorisation

The Department of Environmental Affairs Forestry and Fisheries (DEFF), in consultation with the Department of Mineral Resources and Energy (DMRE) identified the need for the alignment of Environmental Authorisations (EAs) and promulgated a single environmental system under the National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA). 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, 2014 (Act No. 25 of 2014) (NEMLAA). In line with the One Environmental System the Environmental Impact Assessment Regulations (EIA 2014 Regulations) were promulgated and came into force on 8 December 2014. The EIA 2014 Regulations have subsequently been amended on the 7th of April 2017. With reference to the aforementioned, this S&EIA, prepared in support of the EA application, will comply with the requirements of the EIA 2014 Regulations, as amended.

The Proposed Project therefore requires an EA in terms of the NEMA and the NEM:WA and will follow a S&EIA process in terms of the EIA 2014 Regulations, as amended. The aforesaid regulations enforce a strict timeframe and require a decision by the competent authority, the DMRE, within 300 days from submission of the EA application.

The nature and extent of the Proposed Project, as well as the potential environmental impacts associated with the construction, operation, decommissioning and rehabilitation of a facility of this nature is assessed and presented in this Environmental Impact Assessment Report (EIAr).

2.2 Overview of the Environmental Impact Assessment (EIA) Process

Overview of the Environmental Impact Assessment (EIA) Process

The following applications will be made to the DMRE for the Proposed Project:

1 1. Application for EA for listed activities triggered in Listing Notices GN R983, GN R984 and GN R9850F0F published pursuant to the EIA Regulations 2014 (as amended), promulgated in terms of the National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA); and

1 These Listing Notices have been amended by GN R327, GN R325 and GN R324 of 7 April 2017

2. Application for a waste management licence (WML) authorising waste management activities listed in GN R921 of 29 November 2013 published in terms of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) (as amended) (NEM:WA).

In addition, the following applications will be made to the relevant Competent Authorities:

❖ An Integrated Water Use Licence Application (IWULA) in terms of the National Water Act, 1998 (Act No. 36 of 1998) (NWA) will be submitted to the Department of Human Settlements, Water and Sanitation (DHSWS) for any potential impact to water resources by the Proposed Project.

The period of the EA applied for is 20 years.

The EIA findings, including specialist findings, are used by the EAP, Applicant and Authorities to obtain an objective view of the potential environmental and social impacts that could arise during reclamation and operation of the Marievale Project. Measures for the avoidance or mitigation of negative impacts will be proposed and positive impacts will be enhanced.

Methodology applied to conducting the Scoping Process

The outcome of the first phase of the S&EIA is the Scoping Report, which provides the terms of reference for undertaking the EIA Phase of the project. The figure below indicates the methodology that is applied in conducting the S&EIA process.

Decision-Making Phase: EIA Phase: EIA and EMPr Reports: Authority makes a Scoping Phase: Studies done on the Consolidate the findings decision, based on the Identify potential potential positive and of the impact assessment findings of the EIA and positive and negative negative impacts studies done during the EMPr Reports, if the issues to focus the EIA identified during the EIA Phase project is to proceed or Scoping Phase not.

Figure 2-1: Methodology applied to conducting a S&EIA process

S&EIA Timeframes

❖ The Draft Scoping Report (DSR) was made available for a 30-day public review period. The comments received during this period were captured in a Comments and Responses Report (CRR) that was submitted with the Final Scoping Report.

❖ The Final Scoping Report (FSR) was submitted to the DMRE. The Department had 43 days to either accept or reject the Scoping Report. Once confirmation of acceptance was received from the DMRE, the EIA Phase commenced and ran for a period of 106 days, in which time stakeholders were afforded a 30-day period in which to review and comment on the S&EIR documentation. ❖ Upon submission of the Environmental Impact Assessment / Environmental Management Programme (EIA/EMPr) document, the Competent Authority will have 107 days to reach a decision on the project (Record of Decision (RoD)). The RoD is otherwise referred to as the EA which authorises the activities to proceed. The decision to grant the EA may be appealed (within 20 days) by any party, including the Applicant, following the process outlined in the National Appeal Regulations (GNR 993 of 8 December 2014) published in terms of the NEMA. ❖ If significant changes to the EIA/EMPr are required where significant changes were not consulted on during the initial public participation process, a notice may be submitted to the DMRE stating that the EIA/EMPr will be submitted within 156 days from date of acceptance of the Scoping Report. During the aforesaid 156-day period, stakeholders will be afforded a further 30-day period in which to review the amended EIA/EMPr documentation.

S&EIA Process For a NEMA Application

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Figure 2-2: S&EIA Timeframes

Public Participation Process

The Public Participation Process (PPP) has been designed to comply with the regulatory requirements set out in the EIA Regulations of 2014 (as amended). The PPP provides the opportunity for communication between agencies making decisions and the public. This communication can be an early warning system for public concerns, a means through which accurate and timely information can be disseminated, and can contribute to sustainable decision-making (IAP2, 2006).

Kongiwe encourages stakeholders to provide input into the S&EIA. The sharing of information forms the basis of PPP, with an aim to encourage the public to have meaningful input into the decision-making process from the onset of the project. Stakeholders can become involved in the project in the following ways:

During the Scoping Phase:

Identify issues of concern and Contribute relevant local Verify that issues have been Assist in identifying reasonable suggestions for enhanced information and knowledge to accurately recorded alternatives, where required benefits the environmental assessment

During the EIA Phase:

Contribute relevant local information and Verify that issues have been considered in Comment on the findings of the knowledge to the environmental the environmental investigations as far as environmental assessments assessment possible

During the Decision-Making Phase:

Be advised of the outcome of the Competent Authorities decision, and how and by when the decsion can be appealed

Requirements for Environmental Authorisation

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

Table 2-1 below contains all the listed activities identified in terms of NEMA, 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 DMRE will act as the CA on the project. The Commenting Authorities for the Marievale Project are:

❖ Gauteng Department of Agriculture and Rural Development (GDARD); ❖ The Department of Environment, Forestry and Fisheries (DEFF); ❖ Department of Human Settlements, Water and Sanitation (DHSWS); ❖ Department of Public Works and Infrastructure (DPWI); ❖ National Nuclear Regulator (NNR); ❖ Department of Health (DoH); ❖ South African Heritage Resource Agency (SAHRA), and; ❖ City of Ekurhuleni Metropolitan Municipality (EMM)

Table 2-1: Listed Activities Triggered by the Proposed Project.

Name of activity Aerial extent of the Listed activity Applicable listing notice as Waste management Water use licence 2 3 activity (ha)1F1F amended authorisation authorisation2F2F Mining (E.g. Excavations, blasting, Mark with an X stockpiles, discard dumps or dams, Ha or m2 where GNR 983 as amended by GNR (Indicate whether an Loading, hauling and transport, Water applicable or 327, GNR 984 as amended by authorisation is required in supply dams and boreholes, Expressed in m2 unless affected. GNR 325 or GNR 985 as terms of the Waste accommodation, offices, ablution, otherwise stated amended by GNR 324 Management Act). stores, workshops, processing plant, stormwater control, berms, roads (Mark with an X) pipelines, power lines, conveyors, etc.) Access roads routed from existing entry X GNR 983 – 24 points. GNR 985 – 4 Temporary Site infrastructure (offices, change house, workshops). •Satellite pump station / Reclamation X GNR 984 – 6 X 21(c) & (i) Station • slurry receiving facility X GNR 983 – 12; 13 X

GNR 984 – 6

GNR 985 – 2; 14

2 The total area of the mining and associated areas is approximately 140 hectares.

3 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

Name of activity Aerial extent of the Listed activity Applicable listing notice as Waste management Water use licence 2 3 activity (ha)1F1F amended authorisation authorisation2F2F Mining (E.g. Excavations, blasting, Mark with an X stockpiles, discard dumps or dams, Ha or m2 where GNR 983 as amended by GNR (Indicate whether an Loading, hauling and transport, Water applicable or 327, GNR 984 as amended by authorisation is required in supply dams and boreholes, Expressed in m2 unless affected. GNR 325 or GNR 985 as terms of the Waste accommodation, offices, ablution, otherwise stated amended by GNR 324 Management Act). stores, workshops, processing plant, stormwater control, berms, roads (Mark with an X) pipelines, power lines, conveyors, etc.) • screening facility at the pump station X GNR 984 – 6 X • storage X GNR 984 – 6 X • transfer pumps in series X GNR 984 – 6 X Stormwater systems, including: 21(c) & (i) Process water pipelines X GNR 983 – 9; 19 21(c) & (i) Overland slurry pipelines X GNR 983 – 10; 19 21(c) & (i)

GNR 985 - 7

2.3 Description of Project Activities

Ergo will reclaim the Marievale TSFs via a method known as hydraulic reclamation. This process works in such a way that water from hydraulic reclamation mixes with the unconsolidated material of the TSFs, resulting in a slurry. This slurry will be pumped to the Ergo Processing Plant (hereafter Ergo Plant) for reprocessing using a newly constructed pipeline. Final deposition of the reprocessed slurry residue will be on the licenced Brakpan/Withok TSF (Figure 2-7).

Method of Reclamation

Slimes dams are a result of older treatment methods, although they are more recent than sand dumps, and contain lower grades of gold. However, this material has become economically more viable to process owing to improved treatment methods and a higher gold price. The proposed mining method is referred to as top- down hydraulic reclamation. This technique uses water monitors (or water cannons) to deliver a high-pressure water jet to hydraulically excavate unconsolidated tailings material within the TSFs. The water from the cannon mixes with the tailings and forms a slurry with a high solid content. The slurry then flows under gravity along trenches at the base of the TSF to a collection sump, which is positioned at the lowest elevation of the bench being reclaimed.

At the sump, finger screens remove any 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 the reclamation progresses. To control the volume of water reporting to the reclamation station, flapper valves are used to hold, and release slurry contained in the collection sump. This slurry is then pumped via new and existing pipelines to one of the three alternative processing plants where the slurry is prepared and treated for gold extraction and beneficiation.

Figure 2-3: Mobile tracked hydraulic monitor on a tailing’s facility in South Africa

Reclamation will take place in predetermined benches (or ‘cuts’) and will move unidirectionally until the entire TSF has been reclaimed. Generally, 30 m – 40 m cuts are made for reclamation as per Figure 2-4 below.

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

Pipelines

The Proposed Project will investigate various pipeline routes to convey slurry from the TSFs to the Ergo Plant for reprocessing; and return process water to the project site for reclamation.

These options are all preferred pipeline options for the transport of slurry and return water.

for Section 21 water uses. An Integrated Water Use Licence Application (IWULA) will 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 will be supported by a Technical Report and other necessary supplementary reports.

Access

Major routes around the TSFs are the N17 which runs parallel to and north of the dumps and the R51 which runs west of and perpendicular to the dumps. The following access position is proposed:

❖ Proposed access to Site 1 (TSF 7L5 and 7L6) are is proposed by means of an existing small gravel access road from the Zincor Plant Access Road, this road will need to be widened to 10m with a 2% camber. This road will have to be realigned when the construction of the K135 is started, to comply with the minimum access spacing of 600m required by Gautrans for class 2 roads. ❖ Proposed access to Site 2 (TSF 7L7) are is proposed by means of a proposed access road from the Marievale Sanctuary Road, as indicated on Drawing 19059/KP/01. Traffic from the main road and established mining activities will have the right of way and a ‘STOP’ condition will be implemented for the proposed access road.

Intersections will be properly designed to provide safe entry and exit in and out of the project area. Approvals from the provincial roads’ authorities will be obtained where necessary.

Figure 2-5: Proposed access for the Marievale Project

Power Supply and Process Water

Power will be supplied by Eskom and potable water will be purchased from Rand Water or the Ekurhuleni Municipality, with a contingency for portable JoJo tanks or connection to existing water pipeline infrastructure.

In terms of water make-up and process water use, Ergo will make use of its Centralised Water Distribution System to recycle process water in a closed circuit. Where water makeup is required, this could be from TCTA, the Strubenvale Water Treatment Plant (WTP), the Daggafontein TSF or possibly mine shaft water (refer to Table 2-2). The Central Water Distribution System was commissioned during the last quarter of 2017 to store and distribute water emanating from the Rondebult wastewater treatment works, treated AMD water from Trans-Caledon Tunnel Authority (TCTA) and recycled water from the Brakpan/ Withok Tailings Deposition Facility. The centrally located water facility allows Ergo to distribute water more efficiently throughout the operations. Further improvements have been initiated and implemented to increase pumping capacity from the Brakpan/ Withok Tailings Deposition Facility so that more recycled water can be delivered to the Central Water Distribution System and better utilised from there. An example of improvements is the installation of an inline booster pump station to improve pumping efficiencies and volume from the Brakpan/Withok TSF and the Central Water Distribution System. The Central Water Distribution System continues to perform as planned with significant reductions in potable water consumed.

Stormwater Containment

Dirty storm water will be contained in existing paddocks. The term paddocking refers to the containment of precipitation and operational fluids within the confined space of the residue deposit, thereby creating a scenario where maximum infiltration of fluids into the polluted area are being allowed. Paddocks are typically 15 to 20 m long and 5 m wide. Water entering the paddocks will be controlled by the flapper valves of the collection sump that will hold and release water where necessary.

Technical Details

The following infrastructure will be utilised on site:

❖ Two overland slurry pipelines of 600 mm in diameter; ❖ An overland return water pipeline of 600 mm in diameter; ❖ Overland Brine pipeline of 600 mm in diameter; ❖ Reclamation pump stations/Collection Sump; ❖ Water infrastructure, stormwater systems and spillage handling systems; ❖ Electricity reticulation; ❖ Temporary Administration buildings, including change houses and ablution facilities; ❖ Existing Emergency Stormwater Dams; ❖ Access roads, routed from existing entry points; and ❖ Construction contractors’ yards (temporary facilities).

The life of mine for the Proposed Project is expected to be 20 years. An estimated amount of 500 000 tons/month ramping up to 1.2 million tons/month of slurry is expected to be pumped from the Marievale TSFs to Ergo Plant for beneficiation.

It is anticipated that reclamation will begin at 7L7, starting in the south eastern corner of the TSF and moving in a north westerly direction (i.e. from the lowest point to the highest point, into the prevailing wind direction). It is anticipated that operational reclamation will continue for approximately 2 years. Ergo will then proceed to 7L6 (starting at the lowest point on the dump) and then move to 7L5.

Information that provides perspective on the scale of the Proposed Project is presented in Table 2-2 below.

Table 2-2: Project perspective and technical details.

GROUP SPECIFIC DETAILS Mining Target Mineral ❖ Primary: Gold ❖ Secondary: nickel, silver, pyrites and all associated minerals in mine tailings dams and dumps.

Minable Area ❖ A total of 140 Ha.

GROUP SPECIFIC DETAILS Processes ❖ Water Source: Centralised water distribution system, ❖ Water Make up: TCTA, Daggafontein TSF, Strubenvale water treatment works, abstraction of water from Blesbokspruit at 5ML per day (only if required) ❖ Hydraulic reclamation of slims dams ❖ Disposal of residue slurry at the Brakpan/Withok TSF ❖ Gold extraction at the Ergo Plant

Extent of area for ❖ 2.5 ha for temporary buildings, admin offices, parking, generators, infrastructure within the ablution facilities, change houses, equipment storage. dump footprint boundary ❖ Total of 2.5 ha total development footprint

Pumping ❖ Up to 1.2 million tons per month of slurry ❖ Pumping of water from the TSFs to the water treatment works, Brakpan/Withok.

Resource use Water demand ❖ > 30 ML per day

Power demand ❖ Eskom ❖ Generator back-up

Employment Staff allocation: ❖ 45 to 50 Employees construction ❖ Continual Development

Operating Times ❖ 7 days a week 24 hours a day

Life-Cycle Phases of the Project

The reclamation method is divided into a number of stages, as shown in Figure 2-6 below.

Stage 1 Stage 2 Stage 3 Stage 4 Stage 5

Site Processing and Site Design Reclamation Rehbilitation Preparation recovery

Figure 2-6: Project Process

2.3.1.1 Estimated Project Timeframes

The anticipated life span of the project is approximately 20 years maximum. The proposed project could potentially start immediately (should all Environmental Authorisation be granted) in 2020 and continue to 2040 following a 5 year period of post-decommissioning environmental monitoring.

Table 2-3 gives an indication of the estimated timeframes in relation to the implementation of the actions, activities or processes of the mining phases (construction, operation and decommissioning) for the proposed project.

Table 2-3: Estimated timeframes and deadlines of the different phases associated with the Marievale Project

PHASE TIMEFRAME YEAR START DATE Pre-Construction and Construction for all sites. This includes borehole 2 year 2020 - 2022 monitoring and other pre-construction monitoring requirements Operations starting at 7L7 2 years 2021 - 2023 Decommissioning, post-decommissioning, Rehabilitation and Ongoing 2023 - 2030 monitoring of the initial development area Operations continuing to 7L6 2 years 2023 - 2025 Operations continuing to 7L5 1 year 2025 - 2026 Decommissioning of 7L6 and 7L5 2 years 2027 - 2029 Rehabilitation at all sites 2 years 2028 - 2030 Post-decommissioning at all sites 2 year 2030 - 2032 Post-Decommissioning monitoring at all sites Monitoring 5 years 2032 - 2037

2.3.1.2 Life-Cycle Phases of the Project

The following table is summary of the activities that will occur at the different phases of this project.

Table 2-4: Summary table of the Activities associated with the different phases of the proposed project

ACTIVITY DESCRIPTION Pre-Construction 1 Conduct a further pre-construct baseline Radiation walk-over survey 2 Removal of vegetation and site clearance 3 Preparation of access roads should this be required 4 Initiation of a community forum for engagement throughout the project life cycle Construction Phase 5 Employment of workers (minimal) 6 Operation of construction machinery and vehicles 7 Installed Pump Station 8 Construction of Pipelines 9 Instatement of waste management and dust control measures on site

ACTIVITY DESCRIPTION 10 Desilting of existing facilities 11 Instatement of traffic signage, access, parking bays Operational Phase 11 Reclamation Activities (including concurrent rehabilitation) 12 Operation of pipes 13 Operation of Pump Station 14 Community Engagement Decommissioning 15 Decommissioning and Rehabilitation activities: Demolition of temporary infrastructure such as: screens, the pump station and pipelines, and Rehabilitation of the project area. 16 Closure forum to be established with key stakeholders. Post-Decommissioning 17 Post- Decommissioning Monitoring.

2.3.1.3 Pre-Construction Activities

Prior to the initiation of construction, a radiation survey will be undertaken to determine the radioactive baseline. In addition, the sites will be cleared of vegetation, and access will be prepared for construction. The existing paddocks will be desilted prior to commencing with construction. Before reclamation can commence, the sites will be prepared to prevent unwanted material from being screened and blended with slurry. Suitable aggregate will be stockpiled and there is a possibility for cleared vegetation to be sold locally and where this is not possible, disposed of at a licenced facility.

2.3.1.4 Construction Phase Activities

The construction phase will be short as most of the site infrastructure already exists. Employment will be allocated for the project and communities will be engaged regarding the commencement of activities on site. Access roads will be prepared, and Ergo are expected to erect traffic signage, construct turnings, as well as parking bays as read in the Traffic Impact Statement (TIS). In addition to this, Ergo will appoint security guards and fence off the reclamation pump stations that will be used for the Marievale project. During construction, temporary and mobile (park home) site infrastructure will be established either at the reclamation sites or at the Daggafontein plant with existing connections to the power grid and potable water sources. As part of construction and site preparation activities, the existing Marievale paddocks and stormwater systems will be upgraded/reinstated for capturing and managing dirty water around site.

2.3.1.5 Operational Phase Activities

Once site preparation and construction are completed, hydraulic reclamation can begin. To excavate unconsolidated tailings material within the TSFs, a high pressure water monitor (or cannon) will be directed onto the face of the TSF. Reclamation will take place in predetermined benches (or ‘cuts’) and will move unidirectionally until the entire TSF has been reclaimed. Generally, 30 m – 40 m cuts are made as reclamation progresses. The water from the hose mixes with the tailings and forms a slurry with a high solid content. The slurry then flows under gravity, along the base of the TSF, to a collection sump which is positioned at the lowest elevation of the bench being mined. The collection sump is then able to filter and screen appropriately

sized slurry, and direct this into pipelines which will pump the slurry to the existing Ergo Plant for gold recovery. Residual slurry will then be pumped to the licenced Brakpan/Withok TSF. The water which accumulates atop the Brakpan/Withok TSF is pumped and reused for various Ergo operations.

It is proposed that before the activity enters the decommissioning phase of the Project, the Applicant should establish a Decommissioning Forum. This forum will encompass the following:

❖ Discuss and develop joint action plans and strategies with key stakeholders to achieve sustainable closure; ❖ Identification and analysis of problems and challenges impacting the operations during the closure phase of the Project; ❖ Accountability for the implementation of action plans and strategies; ❖ Review of current economic trends and programmes within the province to ensure that the strategies in place are best suited; ❖ Generating awareness around the decommissioning and post-decommissioning of the project; and, ❖ Alignment with the Ergo Business Development Academy (EBDA).

During the operational phase, it is advised that continual monitoring of both surface and ground water is conducted. This information needs to be collected and used to update specific water models, and to monitor and evaluate the impact of the operation.

2.3.1.6 Decommissioning Phase Activities

The TSF 7L7 will be the first TSF to be reclaimed. Reclamation of 7L6 and 7L5 are likely to commence before 7L7 is fully reclaimed. Not all the infrastructure will be removed from 7L7 initially, the pipelines installed may be used to service the operations of the other two TSFs.

may fill with water once again, thereby extending the Marievale Bird Sanctuary and contributing to ecological success and sustainability.

2.3.1.7 Post-Decommissioning Activities

Post-decommissioning activities will entail the assessment of rehabilitation and will address any further rehabilitation requirements. Monitoring must occur for at least five years after decommissioning and rehabilitation, or until satisfactory results are achieved.

2.3.1.7.1 Maintenance and Aftercare

Maintenance will specifically need to focus on the rehabilitated areas. Furthermore, groundwater and surface water monitoring will have to take place in the Blesbokspruit. It has been recommended that the groundwater be monitored for at least a period of two years on a quarterly basis after decommissioning. The monitoring process will be used to assess whether the rehabilitation process has been successful or not and to indicate that no further deterioration on groundwater quality is foreseen.

Maintenance will specifically focus on the rehabilitated areas in accordance with the approved EMPr. Continuous erosion monitoring of rehabilitated areas and slopes should be undertaken and zones with excessive erosion should be identified. The cause of the erosion should be identified, and rectified. Zones with erosion will need to be repaired with topsoil. In addition, infiltration of contaminated water will be contained within paddocks.

Health and Safety

Regarding the safety of both the public and the employees, Ergo is updating a workers’ safety assessment as well as a public safety assessment for all of the Ergo operations. This is being done in relation to the requirements of the National Nuclear Regulator (NNR).

Figure 2-7: Marievale Project Infrastructure Map

2.4 Conclusions from the Scoping Phase

The Scoping study for the Marievale Project, which commenced in October 2019, was undertaken in accordance with the EIA Regulations of 2014 (as amended), promulgated in terms of Section 24 (5) of the NEMA. The Scoping report was aimed at detailing the nature and extent of the project, detailing the possible project risks and mitigation measures as well as the plan going forward into the EIA phase.

The baseline environmental information provided in the Scoping report was compiled as a high-level desktop investigation, and the project information is sourced from existing background information, relevant to the Proposed Project. A site visit was undertaken by Kongiwe on the 17th September 2019 and photographs were taken by the project team to illustrate the current site conditions. Refer to Appendix B for photographic evidence of the site visit.

Potential Impacts Identified in the Scoping Phase

Preliminary environmental impacts were determined and have been populated in Table 2-5. As part of the Plan of Study for the EIA phase, these impacts have been further refined, calculated and assessed for all the feasible alternatives identified. Mitigation and management measures have been suggested by the specialists for all impacts identified.

Table 2-5: Potential identified impact because of the Proposed Project.

ENVIRONMENTAL COMPONENT TYPE POTENTIAL IMPACT SPECIALIST STUDY PLANNED FOR EIA COMPONENT Physical Environment (non- Hydrology (including ❖ Potential for further acid mine drainage (AMD), increased heavy Surface Water Impact Assessment living) wetlands, surface metal concentrations and increased sulphate concentrations in water and ground the adjacent Blesbokspruit and local groundwater if runoff from Groundwater Impact Assessment water) operations is not adequately managed through efficient storm water management structures; Wetland Impact Assessment ❖ Water and ground contamination due to pipeline leaks/spillages if inadequate preventative measures are not implemented; ❖ Improved surface and ground water quality around the project area due to the removal of the TSFs; ❖ Changes in natural surface water flow parameters due to the removal of the TSFs; ❖ Potential impact on drainage lines from access runoff during the operational phase of the project; ❖ Improved visual aesthetics of the area after the removal of the TSFs. Biological Environment Ecology and ❖ Disturbance of sites and species of ecological importance; Biodiversity Impact Assessment (living) Biodiversity ❖ Loss of migration corridors, and access to nesting and refuge (including fauna and areas, watering points, food supplies for faunal species by flora) removing the TSFs; ❖ Displacement of animal habitat by removing the TSFs; ❖ Removal of invasive species from the TSFs; ❖ Improvement of species diversity in the Blesbokspruit Wetland System by removing a pollution source in the form of the TSFs; ❖ Long-term improvement of ecosystem health and functioning of the project area following rehabilitation.

ENVIRONMENTAL COMPONENT TYPE POTENTIAL IMPACT SPECIALIST STUDY PLANNED FOR EIA COMPONENT Cultural Environment Heritage Resources ❖ Should heritage resources be present in the area, the reclamation Heritage Impact Assessment project could potentially impact these; ❖ Destruction of a heritage resource, if the TSFs are older than 60 years, by reclaiming the TSFs. Social and Economic Employment ❖ Continued employment and job security; Social Impact Assessment Environment ❖ Continued investment in local economy; ❖ Removal of the dumps could eliminate the attraction of illegal/informal miners who seek gold. Land-use ❖ Land use will change to an active reclamation site; Social Impact Assessment ❖ Restoration and unlocking of land for future land uses. The removal of TSFs could result in the extension of the Blesbokspruit Wetland System footprint; ❖ Better management and control of the area against illegal/informal mining. Noise ❖ Increase in ambient noise levels during the operational phase; Noise Impact Assessment ❖ Disturbances to faunal species during the operational phase. Air Quality ❖ Possible increase in dust levels in some areas during operations; Air Quality Impact Assessment ❖ Overall removal of an air pollution source after the removal of the TSFs; ❖ Health impacts on livestock and people in proximity to the project site due to fine particulate emissions during construction and operational phases.

Main issues arising in the Scoping Phase

During the Scoping phase of the project, issues and concerns were raised by various Interested and Affected Parties (I&APs) and Organs of State. This section provides a summary of the main issues raised during the Scoping Phase and provides an indication of where in this EIA these issues have been addressed.

The main issues raised have been sourced from the Comments and Responses Report (CRR) included as part of the Final Scoping Report (FSR) (dated 28 November 2019), which was submitted to the DMRE for their consideration.

Table 2-6: Potential identified environmental and social impact of the Proposed Project.

PROJECT STAKEHOLDER MAIN ISSUE RAISED REFERENCE IN THE EIA REPORT ❖ The impact of the project on the water quality of the Chapter 8 JM Property and Mineral Blesbokspruit Rights Consultants ❖ The impact of the project on farming activities Ilangabi Investments 12 ❖ Handling of spillages on site EMPr (Pty) Ltd Vereeniging Property and ❖ Concerned that the pipelines will impact its Appendix B Investment (Pty) Ltd proposed shopping centre applications City of Ekurhuleni ❖ Concerned about impacts on groundwater Chapter 8 Metropolitan Municipality ❖ Concerned about the capacity of the N/A Brakpan/Withok TSF ❖ Handling of spillages on site EMPr ❖ Concerned that the collection sump is located close EMPr to the wetland and that there may be spillages into the wetland. Chapter 8, Section 7.6.6 ❖ Concerned about the risks of moving slurry from N/A – No risk other than Ergo Plant to the Brakpan/Withok TSF stealing of pipes and spillage. This is dealt with in the EMPr. ❖ Concerned that the berms and walls around the TSF EMPr may not be sufficient to prevent contaminated water from entering into the Blesbokspruit. Chapter 8 and Section 7.6 DHSWS ❖ The DHSWS support the plans proposed by Kongiwe N/A for rehabilitation. ❖ The DHSWS are concerned that some species can Chapter 8, Section 7.3 and become invasive if your wetland is expended. 7.4

EMPr – Invasive species management. DEFF ❖ The proposed pipeline in Kwa-Thema Phase 1, Kwa - Section 7.3 Thema and Struisbult areas is located in proximity to woody vegetation.

PROJECT STAKEHOLDER MAIN ISSUE RAISED REFERENCE IN THE EIA REPORT ❖ Concerned about the pipeline placement south, and N/A – Pipelines are above ESKOM its impact on current Eskom infrastructure. ground. No impacts. Other: I&AP Written ❖ Impact of the project on the surrounding value of N/A – No impact expected comments private property. ❖ Impact on water levels and bird life in the reserve. Section 7.6 and 7.7 ❖ Concerned that the project will be abandoned and Mandated according to this left incomplete due to the lack of funding or EIA and EMPr downturn in the gold price. ❖ Concerned about the possible contribution of Section 7.6 and 7.7 tailings reclamation activities on surface to acid mine drainage Appendix D - Specialist reports ❖ Concern about the risks associated with the Section 7.6 and 7.7 remobilization of metal bound cyanides, the possible contribution to ingress and AMD; the Appendix D - Specialist residual radioactivity in the footprints of the reports reclaimed TSFs and the future sustainable land use of these areas; and whether the Applicant is of the intention to remine(remove) the entire TSFs and to plough back some of the profits into the rehabilitation of the entire mining area. ❖ Concerned about impacts on Species of Section 7.3 Conservation Concern. Appendix D - Specialist reports ❖ Concerned about the impact of illegal miners Section 7.10

Appendix D - Specialist reports ❖ Local procurement and employment opportunities. Section 7.10

Appendix D - Specialist reports

Scoping Phase Conclusions and Recommendations

The Scoping report found that no environmental fatal flaws exist for the Proposed Project. The findings of this FSR indicated that the Proposed Project and its associated infrastructure would pose minimal and short- term negative environmental impacts if adequate and appropriate mitigation measures are implemented; and positive long-term environmental impacts when the project has been completed. Most importantly, the removal of these TSFs would assist with the alleviation of a major pollution source to the Blesbokspruit and Marievale Bird Sanctuary Nature Reserve (Ambani and Annegarn, 2015; McKay et al., 2018).

According to the Way Forward and the Plan of Study, contained in the FSR, impacts associated with the

Proposed Project needed to be considered further during this EIA Phase. It is important to take note of the current conditions of the Proposed Project area and the sensitive environment around it. The TSFs are a source of pollution and cause other direct and indirect nuisances to the surrounding environment. The Proposed Project is also in line with the Gauteng Mine Residue Area Strategy (2012), Ekurhuleni Metropolitan Spatial Development Framework (2011) and the Ekurhuleni Environmental Management Framework’s (2014) objectives to remove the TSFs scattered on Gauteng landscape, especially in ecologically sensitive areas.

Deviation from the Scoping Report

Appendix 3 of the NEMA EIA Regulations (GNR 982), 2014 (as amended) provide for documentation and information that must be contained within an EIA/EMP. Appendix 3(3)(u) states that:

An indication of any deviation from the approved scoping report, including the plan of study, including –

(i) Any deviation from the methodology used in determining the significance of potential environmental impacts and risks; and

(ii) A motivation for the deviation.

While there have been no deviations to the “methodology used in determining the significance of potential environmental impacts and risks”, there have been minor alterations to the project scope and technical details, which is expected as a project evolves and becomes more refined. Given that the Final Scoping Report (FSR) was undertaken as a high-level desktop assessment, the EIA was able to ground-truth the assumptions made in the scoping report, with additional information and recommendations from independent specialists.

Table 2-7 below provides a short summary of the details which have changed from the Scoping Phases of the project, to the EIA phase of the project.

Table 2-7: A summary of the deviations from Scoping Phase to EIA Phase.

FSR STATEMENT CHANGES IN THE EIA REPORT REFERENCE IN THE REPORT Pipelines: There are three pipeline routes considered in the EIA: Section 2.3.2

“The first alternative pipeline route would be approximately 25 km long and Pipeline Route 1: There will be a 600mm pipeline from Trans-Caledon made up of two parts. The first part would be a 7 km extension from the Tunnel Authority (TCTA) AMD treatment project towards the project site to the Daggafontein Plant; while the second part would be a 17 Daggafontein plant. This pipeline will then continue on Ergo’s existing km extension from the Daggafontein Plant to the Ergo Plant. This alternative Surface Right Permits to the Ergo Plant and hence to the Brakpan/Withok is being considered due to existing surface right permits that run along this TSF where the brine will be deposited. proposed route. The Daggafontein Plant is not part of the Proposed Project and is not owned by Ergo.” Pipeline Route 2: There will be two 600 mm slurry pipelines and a single 600 mm return water pipeline that will run from the project site (7L7, 7L6 and 7L5) north towards the Daggafontein plant. These pipes will then continue on Ergo’s existing Surface Right Permits to the Ergo Plant, where after residue will be disposed of on the Brakpan/Withok TSF via existing and authorised pipelines.

Pipeline Route 3: This route consists of a similar pipeline configuration as Route 2 but will run south from the project site (7L5, 7L6 and 7L7) before it deviates in north - westerly direction to the Ergo Plant. This route is approximately 19 km long. Residue will be disposed of on the Brakpan/Withok TSF via existing and authorised pipelines. Access roads: Proposed access to Site 1 (Dumps 7L5 and 7L6) is proposed by means of Section 2.3.3 an existing small gravel access road from the Zincor Plant Access Road, “As far as possible, existing access roads will be utilised, and where this is not this road will need to be widened to 10m with a 2% camber. This road possible, these will be constructed as a two-by-two roadway, operating in will have to be realigned when the construction of the K135 is started, to both directions. Where access roads are to be constructed, these will be 4 m comply with the minimum access spacing of 600m required by Gautrans wide gravel road…”

for class 2 roads.

Proposed access to Site 2 (Dump 7L7) are is proposed by means of a proposed access road from the Marievale Sanctuary Road, as indicated on Drawing 19059/KP/01. Traffic from the main road and established mining activities will have the right of way and a ‘STOP’ condition will be implemented for the proposed access road. Water Sources: In terms of water make-up and process water use, Ergo will make use of Section 2.3.4 its Centralised Water Distribution System to recycle process water in a “Originally, water required for the reclamation activities was to be sourced closed circuit. Where water makeup is required, this would be from TCTA, from the existing Ergo central water storage facility located in Germiston and the Strubenvale Water Treatment Plant (WTP) and from the conveyed through existing and proposed process water pipelines to the Daggafontein TSF. The Central Water Distribution System was project site for reuse in the closed-circuit system.” commissioned during the last quarter of 2017 to store and distribute water emanating from the Rondebult waste water treatment works, “Technical challenges with the distance of transporting this water from treated AMD water from Trans-Caledon Tunnel Authority (TCTA) and Germiston to the Marievale site have resulted in there being a need to recycled water from the Brakpan/ Withok Tailings Deposition Facility. The investigate alternative/supplementary water sources. These may include centrally located water facility allows Ergo to distribute water more sourcing water from the existing Brakpan/Withok TSF, Daggafontein TSF or efficiently throughout the operations. Further improvements have been Marievale One and Two Shafts, wastewater treatment works, as well as the initiated and implemented to increase pumping capacity from the Trans-Caledon Tunnel Authority (TCTA) AMD treatment project.” Brakpan/ Withok Tailings Deposition Facility so that more recycled water can be delivered to the Central Water Distribution System and better utilised from there. An example of improvements is the installation of an inline booster pump station to improve pumping efficiencies and volume from the Brakpan/Withok TSF and the Central Water Distribution System. The Central Water Distribution System continues to perform as planned with significant reductions in potable water consumed. Dirty water containment: Dirty storm water will be contained in existing paddocks. The term Section 2.3.5 paddocking refers to the containment of precipitation and operational fluids within the confined space of the residue deposit, thereby creating a scenario where maximum infiltration of fluids into the polluted area are

“The slurry then flows under gravity along trenches at the base of the TSF to being allowed. Paddocks are typically 15 to 20 m long and 5 m wide. a collection sump which is positioned at the lowest elevation of the bench Water entering the paddocks will be controlled by the flapper valves of being mined.” the collection sump that will hold and release water where necessary Rehabilitation: The rehabilitation should invariably be evaluated in view of the future Section 2.3.7.6 land use. It is the primary aim of rehabilitation to: Once the dumps have been reclaimed, rehabilitated, cleared of radiation, the land will be shaped and revegetated to match the surrounding environment. ❖ Reduce the potential environmental risks s to acceptable levels. ❖ Protect the future value of the land by re-establishing a sustainable land use as close to, or similar, to its pre-mining condition.

Kongiwe’s suggested end land use is recommended to be the extension of the Marievale Bird Sanctuary and the Blesbokspruit wetland, however, this would be at the discretion of the end landowner. To achieve this preferred end land use, the land must be levelled, and remnants of contaminated slime removed. Infiltration and dust generation will be minimised by planting of the soil with appropriate plant/grass species. Lastly, paddocks will remain as a short-term method of containing the surface migration of contaminants into the Blesbokspruit and will be removed once rehabilitation has proven to be successful. Since the TSFs lie within close proximity to the wetland system, it is expected that the flat lying areas directly adjacent to the Blesbokspruit may fill with water once again, thereby extending the Marievale Bird Sanctuary and contributing to ecological success and sustainability.

CHAPTER 3: CONSIDERATION OF ALTERNATIVES

In accordance with the requirements of Appendix 3 of the 2014 EIA Regulations (as amended), an EIA report must contain a consideration of the alternatives, which can include activity alternatives, site alternatives, location alternatives and the “do-nothing” alternative. Alternatives are required to be assessed in terms of social, biophysical, economic and technical factors.

For applications submitted to the DMRE for environmental authorisation in terms of the NEMA and NEM:WA, in respect of listed activities that have been triggered, the project is expected to assess alternative properties, the type of activity, the design and layout of the activity, technologies, operational aspects and the “do- nothing” alternative.

When assessing alternatives, they should be “practical”, “feasible”, “relevant”, “reasonable” and “viable”. In this instance, this chapter provides a detailed explanation, including the advantages and disadvantages of the alternatives considered in this EIA .

3.1 The property on which or location where it is proposed to undertake the activity

The Proposed Project is the reclamation of already existing TSFs (7L5, 7L6 and 7L7). Therefore, there are no alternative sites.

Currently the TSFs are passive mineral disposal areas with no other land use or development associated with them. The goal of reclamation will be to return the sites to a condition that most resembles the pre-mining condition. When the TSFs have been reclaimed, rehabilitated and cleared of radiation, the land will be levelled and revegetated to match the surrounding environment.

3.2 The type of activity to be undertaken

The only optional activity for Ergo is to reclaim and reprocess the existing Marievale TSFs. Gold reclamation and processing is the recovery and treatment of gold surface tailings generated from historical underground mining operations. Vast quantities of material are processed monthly through Ergo owned plants to recover gold from old mine TSFs at a recovery rate that varies depending on the material being treated.

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 TSF-related issues, has led to the ‘Preferred Activity’.

Table 3-1: The advantages and disadvantages of the Marievale Project operations

OPTION ADVANTAGE DISADVANTAGE

Reclaiming and ❖ Low-technical-risk nature of tailings ❖ Potential profits rely on substantial reprocessing of the retreatment projects sets them apart volumes of material.

OPTION ADVANTAGE DISADVANTAGE

Marievale TSFs from traditional underground ❖ Potential negative environmental (Preferred) operations effects during construction and ❖ Not labour intensive. operational phase of the project. ❖ Minimal safety issues. ❖ Not labour intensive. ❖ Easy access to surface tailings, as well as lower labour and operating costs. ❖ Boost to local economy. ❖ Removal of pollution source after rehabilitation and cessation of project.

3.3 The Design and Layout of the Activity

The current layout plan alternatives for the Proposed Project are considered as the preferred layout plan. The layout plan is dictated by the existing location of the TSFs, their associated infrastructure and the routes of the proposed pipelines. The routes of these pipeline are limited to existing Surface Right Permits (SRPs)/servitude route or wayleave that are in favour of Ergo, where not existing, a new servitude, usufruct or wayleave will be sought.

The existing paddocks/stormwater dams will need to be desilted and reinstated. The paddocks are provided to capture storm water overflow from the TSFs in the event of a rain event, and for pump station overflows. If water accumulates within the storm water paddock below the pump stations it will be pumped back into the reticulation circuit.

Figure 3-1: Preferred layout for the Marievale Project Page | 48 Ergo Mining (Pty) Ltd: The Marievale Tailings Project Final Environmental Impact Assessment Report © 2020 Kongiwe Environmental (Pty) Ltd

3.4 The Technology to be Used in the Activity

The reclamation of the Marievale TSFs is the “Preferred Activity” and there are no alternatives. The dumps will be reclaimed using Hydraulic Reclamation. Other technology options which will be considered by Ergo for the reclamation of the Marievale TSFs are: Recycling initiatives, water conservation and electricity alternatives.

Ergo believes that it will implement the best available technology in the best possible combination, in a way which is cost effective for this specific project. Best practices (as utilised in the industry) have been selected and, where applicable, SANS standards and legislative requirements will be followed in design, construction and management of infrastructure and activities on site.

Table 3-2: The advantages and disadvantages of hydraulic reclamation

OPTION ADVANTAGE DISADVANTAGE

Hydraulic Reclamation ❖ Cost effective ❖ Dust emissions which are to be ❖ Easier to transport slurry for processing. mitigated ❖ Compatible with existing infrastructure. ❖ Not very labour intensive, thus new ❖ Lowered risks when compared to other employment opportunities are limited methods of reclamation ❖ May cause environmental impacts if not done responsibly.

Recycling, potable water use and electricity reliance

The reclamation of the Marievale TSFs will, in its operational phase, implement recycling policies and measures for optimal utilisation of resources and minimisation of waste generation. Potable water will be purchased from Rand Water, with a contingency for portable JoJo tanks or connection to existing water pipeline infrastructure.

In terms of water make-up and process water use, Ergo will make use of its Centralised Water Distribution System to recycle process water in a closed circuit. Where water makeup is required, this could be from TCTA, the Strubenvale Water Treatment Plant (WTP) and from the Daggafontein TSF. The Central Water Distribution System was commissioned during the last quarter of 2017 to store and distribute water emanating from the Rondebult waste water treatment works, treated AMD water from Trans-Caledon Tunnel Authority (TCTA) and recycled water from the Brakpan/ Withok Tailings Deposition Facility. The centrally located water facility allows Ergo to distribute water more efficiently throughout the operations. Further improvements have been initiated and implemented to increase pumping capacity from the Brakpan/ Withok Tailings Deposition Facility so that more recycled water can be delivered to the Central Water Distribution System and better utilised from there. An example of improvements is the installation of an inline booster pump station to improve pumping efficiencies and volume from the Brakpan/Withok TSF and the Central Water Distribution System. The Central Water Distribution System continues to perform as planned with significant reductions in potable water consumed.

Ergo is investigating the possibility of producing its own power through alternative sources of energy, including solar and gas fired power plants. It is a long-term project and it is still in the early stages of research. If successful, this project will mitigate one of Ergo’s major risks – sustainable and affordable power supply.

3.5 The Operational Aspects of the activity

Pipeline route options and Rehabilitation

Please see Section 2.3.2 and Please see Section 2.3.7.6 respectively.

Infrastructure placement

Two locations for temporary site infrastructure have been considered:

3.6 The “No-Go” option

The Option of the project not proceeding would mean that the environmental and social status would remain the same as current. This implies that both negative and positive impacts would not take place. As such, the short-term negative impacts on the environment would not transpire; equally so, the long term positive impacts such as environmental pollution source removal, economic development, skills development, and the availability of land for re-development would not occur. The only alternative land use is to leave the dumps as they stand. There is no other potential use of the space as the project area is a cluster of polluting historic mine dumps that impact upon the surrounding biophysical and social environment.

The “No-Go” Option also assumes the continuation of the current land use, implying the absence of any reclamation activities and associated infrastructures. The means that the attraction of the gold reserves located within the dumps could potentially enhance illegal mining, and if left as is, population settlement on or around the dumps could occur.

The ‘No Project’ alternative is not preferred due to the anticipated benefits of the proposed reclamation project. The expected indirect benefits resulting from the reclamation of the Marievale TSFs include:

❖ Removal of a source of pollution and radiation in the area. ❖ The potential to unlock land for redevelopment, as read in the Metropolitan Spatial Development Vision. ❖ Continued supply of gold to the local and national markets, and therefore contribution to local, provincial and international economy. ❖ Removal of a pollution source to the Blesbokspruit Wetland System and the associated Marievale Bird Sanctuary Nature Reserve.

CHAPTER 4: POLICY AND LEGISLATIVE CONTEXT

This chapter provides an overview of the policy and legislative context relevant to the reclamation of the Marievale TSFs. 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 Proposed 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 were 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 overlooked, 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 4-1: Applicable National Legislation and Guidelines

APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT. REFERENCE WHERE APPLIED The Constitution of South Africa, 1996 (Act 108 of 1996) As per the Requirements of NEMA and the NEMA EIA Regulations, alternative activities that are less Section 24 of the Act states that everyone has the right to an environment that is not harmful to their health or well-being; to taxing on the environment and resources must be have the environment protected for the benefit of present and future generations, through reasonable legislative and other investigated where possible. The DSR was made measures that prevent pollution and ecological degradation; promote conservation; and secure ecological sustainable available for public review & the Final EIA Report development and use of natural resources while promoting justifiable economic and social development. will be made available to the public (as per the PPP section 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 other described to all stakeholders through the EA people that is required in the exercise or protection of a right. notification described in the PPP section of this report. Section 33 of the Act states that everyone has a right to just and procedurally fair administrative action. The One Environmental System Ergo proposes to reclaim the Marievale TSFs and submit the required documents within the In terms of the One Environmental System established by the NEMLAA, an EA in respect of a reclamation operation must be prescribed timeframes. issued within 300 days of the application being submitted. This system aims to streamline the licensing processes for environmental authorisations and water use. Mine Health and Safety Act (MHSA), Act 29 of 1996 (as amended): Although not strictly addressed in the Scoping Report or EMPr, protecting the environment Although the Mineral and Petroleum Resources Development Act, 2002, does not apply to this project, Ergo operates in contributes to a safe working environment. MHSA accordance to the MHSA and associated regulations. This includes creating a safe and healthy work environment and providing regulations will be worked into the operation’s the necessary protection and training to staff to ensure their health and safety is not compromised. Code of Practice (COP) and Standard Operating Procedures (SOPs). Hazardous substances will be adequately stored and labelled. All regulations pertaining to safe use, handling, processing, storage, transport and disposal of hazardous substances; protection of equipment, structures and water sources and the surface of land; 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.

APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT. REFERENCE WHERE APPLIED National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA) It is the objective of this application to align to NEMA. The overarching principle of the NEMA is sustainable development. It defines sustainability as meaning the integration of social, economic and environmental factors into planning, implementation and decision making to ensure the development The NEMA is the overarching Act governing serves present and future generations. Section 2 of NEMA provides for the NEMA principle which apply throughout the sustainable development and the NEMA principles Republic to the actions of all organs of state that may significantly affect the environment and in conjunction with other apply to all prospecting and mining operations appropriate and relevant considerations. The NEMA principles serve as the general framework within which environmental (which included reclamation activities) and any management and implementation plans must be formulated and serve as a guideline by reference to which any organ of state matter or activity relating to such operation. 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 NEMA principles apply to all prospecting Listed activities as per the EIA 2014 Regulations, as and mining operations and any matter or activity relating to such operation and serve as guidelines for the interpretation, amended, have been identified (refer to Chapter 2, administration and implementation of the environmental requirements of the MPRDA. subsection 2.5).

4 NEMA authorises the Minister of the DEFF to issue Regulations relating to the administration of the Act 3F3F , which has been done with the publication of the EIA 2014 Regulations, as amended. Section 24(2) allows the Minister to identify activities which may not commence without environmental authorisation from the competent authority. This identification has been done in accordance with listing notices referred to as Listing Notice 1, Listing Notice 2 and Listing Notice 3. The NEMA also allows the Minister to determine which authority will be the competent authority to receive 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

4 Sections 24(5) and Section 44

APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT. REFERENCE WHERE APPLIED provincial authority concerned.

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 DMRE (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 DMRE (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 DMRE 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 DMRE, 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 DMRE 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 DMRE (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 have been identified (refer to Chapter 2, As part of the waste management matters dealt with in the NEM: WA, waste activities have been identified in GN 921 of 29 subsection 2.5). 5 November 20134F4F : List of Waste Management Activities that have, or are likely to have, a Detrimental Effect on the 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

5 Published in Government Gazette 37083

APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT. REFERENCE WHERE APPLIED 6 the NEM: WA.5F5F

Category A activities require a BAR process while Category B Activities require a S&EIR process. It should be noted that although previously residue deposits and residue stockpiles were regulated in terms of the MPRDA Regulations and in particular Regulation 73, the National Environmental Laws Amendments Act 25 of 2014 (NEMLAA) deleted section 4(b) from the NEM:WA and residue stockpiles and residue deposits therefore fall within the ambit of the NEM:WA and its various regulations. Activity B 4(11) of GN 921, as amended by GN 633 of 24 July 2015 now refers to “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 Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002)”. Since the Marievale TSFs are comprised of historic mineral deposits, the MPRDA does not apply and Activity B4(11) will likewise not apply. However, it must be noted that Schedule 3, Category A (Hazardous Waste) of NEM:WA itself adopts a definition for residue stockpiles precisely similar to the definition proposed for the MPRDA 3rd Amendment which never came into force. Accordingly, the Marievale TSFs must be regarded as waste accordingly and recovery operations would require a waste management licence, but in terms of Section 20 of the NEM:WA, not Activity B 4(11).

In addition to the requirement for a WML for the mine discard dump (historic mineral deposits), the mine is likely to trigger the following waste activities, all of which require a Category B WML:

1) The storage of hazardous waste in lagoons excluding storage of effluent, wastewater or sewage; 2) 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.

The EA and WML are being dealt with as integrated application. National Water Act, 1998 (Act No. 36 of 1998) (NWA) An IWULA will be required for the reclamation of the Marievale TSFs and will be submitted to the

6 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

APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT. REFERENCE WHERE APPLIED In terms of the NWA, the national government, acting through the Minister of Water and Sanitation, is the public trustee of DHSWS. South Africa’s water resources, and must ensure that water is protected, used, developed, conserved, managed 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; (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

APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT. REFERENCE WHERE APPLIED (k) using water for recreational purposes.

It is not likely that sub-sections (a), (b), (d), (e), (f), (g), (h), (j) or (k) will apply to the Proposed Project.

Water uses associated with the reclamation activities include the actual reclamation of the Marievale TSFs within a wetland and the construction and operation of pipelines within 100 m of a river bank. These water uses will require an IWULA.

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, as well as conceptual design drawings of all water related infrastructure. National Environmental Management: Biodiversity Act, 2004 (Act No.10 of 2004) (NEM:BA) NEM:BA was used to inform the activities triggered by Listing Notice 3 (refer to Chapter 2, subsection The NEM:BA provides for the management and conservation of South Africa’s biodiversity within the framework of NEMA, as 2.5). well as the protection of species and ecosystems that warrant national protection and the sustainable use of 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.

The Proposed Project falls within the Gauteng Province, which has a provincial Biodiversity Assessment Protected Area Expansion Strategy. This strategy has been incorporated and considered throughout the compilation of this report. National Environmental Management: Protected Areas Act (NEM:PAA), Act 57 of 2003 as amended SANBI website and GIS tools were utilised to determine if the project area overlaps with CBAs. The National Environmental Management Protected Areas Act (No. 57 of 2003) (NEM:PAA) concerns the protection and Some sections of the project area were rated as conservation of ecologically viable areas representative of South Africa’s diversity and its natural landscapes and seascapes, Protected Area (PA) and Ecological Support Area and includes inter alia: (ESA); while some parts of the proposed pipeline routes traverse Ecological Support Areas, ❖ The establishment of a national register of all national, provincial and local protected areas; Important Areas and Protected Areas. Therefore, it ❖ The management of those areas in accordance with national standards; and is anticipated that some restrictions will apply to ❖ Inter-governmental co-operation and public consultation in matters concerning protected areas. the reclamation project in terms of protected

APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT. REFERENCE WHERE APPLIED Sections 48 to 53 of the NEM:PAA lists restricted activities that may not be conducted in a protected area. Section 48 states areas. that no person may conduct commercial prospecting or mining activities in a: The Regulations were utilised to determine the ❖ Special nature reserve or nature reserve; need for any additional listed scheduled activities ❖ Protected environment without the written permission of the Minister and the Cabinet member responsible for minerals under GNR 985. and energy affairs; and Protected area referred to in Section 9:

❖ (b) world heritage sites; and ❖ specially protected forest areas, forest nature reserves and forest wilderness areas declared in terms of the National Forests Act (No. 84 of 1998);

The Proposed Project is situated within 500 m of an important river (Blesbokspruit); within an important wetland and conservation area (Blesbokspruit Wetland System); and within a Protected Area (Marievale Bird Sanctuary Nature Reserve). However, the Proposed Project is neither a commercial prospecting nor mining activity but the reclamation of a pollution source from a protected site. Furthermore, the Proposed Project falls in an area identified in the 2018 Gauteng Environmental Management Framework’s Focus Areas for land-based protected areas expansion. National Heritage Resources Act, 1999 (Act No. 25 of 1999) (NHRA) A Heritage Impact Assessment has been undertaken as part of the EIA Phase and the The NHRA aims to promote good management of cultural heritage resources and encourages the nurturing and conservation assessment has been uploaded on the SAHRA web of cultural legacy so that it may be bestowed to future generations. site along with the EIA Report.

The Act requires all developers (including mines) to undertake cultural heritage studies for any development exceeding 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.

APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT. REFERENCE WHERE APPLIED The Marievale TSFs may represent ‘Historical Settlements and Townscapes’ as per the NHRA if they were established more than 60 years ago. The dumps and other associated mining infrastructure are integral components of the historical mining townscapes and settlements of the East Rand. Conservation of Agricultural Resources Act (No. 43 of 1983) The protection of land, soil, wetlands and vegetation and the control of weeds and invader The Conservation of Agricultural Resources Act (No. 43 of 1983) (CARA) includes the use and protection of land, soil, wetlands plants have been contained within this EIA Report. and vegetation and the control of weeds and invader plants. This is the only legislation that is directly aimed at conservation of wetlands in agriculture. The Act contains a comprehensive list of species that are declared weeds and 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 have been considered when assessing the project The National Road Traffic Regulations, 2000 places specific duties on the consignor and consignee of dangerous goods. A impacts and developing the associated mitigation consignor means the person who offers dangerous goods for transport (i.e. hazardous waste) and a consignee is the person measures in this EIA Phase. who accepts dangerous goods, which have been transported in a vehicle. Both consignor and consignee must comply with the requirements of several SANS standard specifications and codes of practice relevant to dangerous goods which have been incorporated into the regulations.

APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT. REFERENCE WHERE APPLIED The mine owner is responsible for:

❖ Offloading of the dangerous goods; ❖ Providing the dangerous goods offloading supervisor; and ❖ 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 Marievale TSFs are already in existence and fall within a Control Zone (Zone 3). The SPLUMA was promulgated in May 2015. SPLUMA is a framework act for all spatial planning and land use management legislation in South Africa. It seeks to promote consistency and uniformity in procedures and decision-making in this field. SPLUMA will also assist municipalities to address historical spatial imbalances and the integration of 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 requirements of the Act and Regulations have been considered when assessing the project The Regulations for Hazardous Chemical Substances apply to an employer or a self-employed person who carries out work at impacts and developing the associated mitigation a workplace which may expose any person to the intake of hazardous chemical substances at that workplace. Regulations 14 measures in this EIA Phase. and 15 provide for the labelling, packaging, transportation and storage and the disposal of hazardous chemical substances respectively. These regulations set out specific requirements which form part of an employer’s 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. National Development Plan, 2030 The requirements of this Plan have been considered when assessing the project impacts The National Development Plan (NDP) offers a long-term perspective. It defines a desired destination and identifies the role and developing the associated mitigation different sectors of society need to play in reaching that goal. measures in this EIA Phase.

As a long-term strategic plan, it serves four broad objectives:

APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT. REFERENCE WHERE APPLIED 1. Providing overarching goals for what we want to achieve by 2030. 2. Building consensus on the key obstacles to us achieving these goals and what needs to be done to overcome those obstacles. 3. Providing a shared long-term strategic framework within which more detailed planning can take place to advance the long-term goals set out in the NDP. 4. Creating a basis for making choices about how best to use limited resources.

The Plan aims to ensure that all South Africans attain a decent standard of living through the elimination of poverty and reduction of inequality. The core elements of a decent standard of living identified in the Plan are:

❖ Housing, water, electricity and sanitation; ❖ Safe and reliable public transport; ❖ Quality education and skills development; ❖ Safety and security; ❖ Quality health care; ❖ Social protection; ❖ Employment; ❖ Recreation and leisure; ❖ Clean environment; and ❖ Adequate nutrition

The Proposed Project falls in line with the goals of the NDP in creating a decent standard of living for all South Africans by removing a pollution source to the surrounding conservation and protected areas adjacent to the project site. As the Proposed Project may result in the decrease Action Plan of the Environmental Initiative of the New Partnership of Africa’s Development, 2003. of pollution affecting the Blesbokspruit Wetland System, the objectives of the NEPAD to This Action Plan was established with the aim of encouraging sustainable development, conservation and acceptable use of systematically address and sustain ecosystems, biodiversity in Africa. It has been recognised that a healthy and productive environment is a prerequisite for the success of biodiversity and wildlife has been considered New Partnership of Africa’s Development (NEPAD), together with the need to systematically address and sustain ecosystems, during the EIA Phase of the project.

APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT. REFERENCE WHERE APPLIED biodiversity and wildlife. Six areas have been identified:

❖ Combating land degradation, drought and desertification; ❖ Conserving Africa’s wetlands; ❖ Preventing and controlling invasive alien species; ❖ Conservation and sustainable use of coastal and marine resources; ❖ Combating climate change in Africa; and ❖ Cross-border conservation and management of natural resources.

The Proposed Project is expected to contribute to the conservation of Africa’s wetlands by removing a pollution source of the Blesbokspruit Wetland System. South Africa’s National Biodiversity Strategy and Action Plan The Proposed Project is cognisant of the obligation to protect and preserve the integrity of the The National Biodiversity Strategy and Action Plan (NBSAP) sets out a framework and a plan of action for the conservation and environment as well as its biodiversity. Principles sustainable use of South Africa’s biological diversity and the equitable sharing of benefits derived from this use. The NBSAP of this plan will be taken into consideration during was prepared by the former Department of Environmental Affairs and Tourism (DEAT), during the period May 2003 to May the EIA Phase. 2005. The goal of the NBSAP is to conserve and manage terrestrial and aquatic biodiversity to 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”, although the project is related to reclamation, the following would still apply:

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 Proposed Project would need to incorporate operational systems that minimise the impacts of threatening processes on biodiversity during the operational phase of the project, and by streamlining specialist recommendations during the implementation of all phases of this project. Promotion of Access to Information Act, 2000 The requirements of the Act have been considered when assessing and involving the public and ❖ The PAIA gives effect to the constitutional right of access to any information held by the state and any information that registered interested and affected parties.

APPLICABLE LEGISLATION AND GUIDELINES USED TO COMPILE THE REPORT. REFERENCE WHERE APPLIED is held by another person and that is required for the exercise or protection of any rights; and to provide for matters connected therewith. National Environmental Management Act; National Appeal Regulations, 2014 The requirements of the Act have been considered if an appeal may need to be or is lodged for the The purpose of these regulations is to regulate the procedure contemplated in section 43(4) of the National environmental project. management act relating to the submission, processing and consideration of a decision on an appeal. This Act is used to help guide and understand the appeal process and the procedures may follow.

Table 4-2: 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 objectives of the Strategy. The guidelines of the The aim of the project as a whole is to make more land available from the mine dumps in Gauteng to be used for other purposes, Strategy have been considered throughout the in line with government priorities. The objectives for the project are as follows: S&EIA process and reporting.

❖ To evaluate current pollution problems caused by mining activities and suggest how they should be addressed; ❖ 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 Bill are applicable to the Proposed Project. Where applicable, these have The Bill was established in 2014, and contains the following objectives: been considered throughout the S&EIA process and have been included within the reporting ❖ To provide for the sustainable utilization and protection of biodiversity within Gauteng; documents. ❖ to provide for the protection of wild and the management of alien animals; protected plants; aquatic biota and aquatic systems; ❖ To provide for the protection of invertebrates and the management of alien invertebrates;

Policies, Guidelines and By-Laws ❖ 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.

The Proposed Project is in close proximity to both the Blesbokspruit and Marievale Bird Sanctuary Nature Reserve; therefore, it is imperative for all phases of the S&EIA, as well those of the construction, operation and decommissioning of the Proposed Project ensure the protection of biodiversity within Gauteng. Gauteng Conservation Plan Version 3.3 Aspects of this Plan are applicable to the Proposed Project. Where applicable, these have The main purposes of C-Plan 3.3 are: been considered throughout the S&EIA process and have been included within the reporting ❖ To serve as the primary decision support tool for the biodiversity component of the Environmental Impact Assessment (EIA) documents. process; ❖ To inform protected area expansion and biodiversity stewardship programmes in the province; ❖ 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 Plan are applicable to the Proposed Project. Where applicable, these have The purpose of the EIP is to: been considered throughout the S&EIA process and have been included within the reporting ❖ Coordinate and harmonise environmental policies, plans and programmes and decisions to (i) minimise the duplication of documents. procedures and functions; and (ii) promote consistency in the exercise of functions that may affect the environment; ❖ 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

Policies, Guidelines and By-Laws 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 The Proposed Project will contribute towards employment creation within the Province and The main purpose of the GGDA Strategic Plan is: will also contribute positively towards economic growth within the region through both its ❖ Addressing the persistent racial imbalances regarding ownership and general configuration of Gauteng’s economy; development and operation. ❖ Addressing the spatially distorted economic development legacy of apartheid rule; ❖ Broadening the base of economic development beyond the Province’s dominant metropolitan municipal areas; ❖ 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.

Ekurhuleni Regional Spatial Development Framework, 2015 Aspects of this SDF are applicable to the Proposed Project. Where applicable, these have The Ekurhuleni Spatial Development Framework (SDF) provides a framework for making resource-effective decisions that can been considered throughout the S&EIA process help mitigate the following identified issues in the municipal zone: and have been included within the reporting documents. ❖ Increasing pressure on the natural environment and green infrastructure; ❖ Urban sprawl and fragmentation; ❖ Spatial inequalities and the job-housing mismatch; ❖ Exclusion and disconnection emanating from high potential underused areas; ❖ Lack of securitisation and gated developments, and disconnected street networks (high cul-de-sac ratios and low intersection densities); ❖ Inefficient residential densities and land use diversity.

The Proposed Project is anticipated to contribute in decreasing the pressure on the natural environment by removing a pollution source to conservation and protected areas. Ekurhuleni Environmental Management Framework (EMF), 2007 Aspects of this EMF are applicable to the Proposed Project. Where applicable, these have

Policies, Guidelines and By-Laws The aim of the EMF for the EMM is to provide a framework that identifies and illustrates the general environmental been considered throughout the S&EIA process characteristics of the municipality: and have been included within the reporting documents. The critical issues within the EMF are the identification of constraint zones and geographical areas. The development constraint zones within the EMF refer to the environmental suitability of land parcels for various types of land uses or activities. The types of development constraint zones identified in the EMF include:

❖ low to no constraint zone; ❖ agricultural constraint zone; ❖ geotechnical constraint zone; ❖ hydrological constraint zone; and ❖ ecological constraint zone.

The Proposed Project is within the vicinity of a protected and conservation area. These areas are identified as ecological constraint zones in the Ekurhuleni EMF. Guidelines discussed in the EMF, on these zones, will need to be considered throughout the S&EIR of the project.

Ekurhuleni Bioregional Plan (BRP), 2014 Aspects of this BRP are applicable to the Proposed Project. Where applicable, these have Subsequent to the approval of the Ekurhuleni BRP, the Guidelines for the compilation of the bioregional plans were set in terms been considered throughout the S&EIA process of the National Environmental Management: Biodiversity Act. EMM, together with the South African Biodiversity Institute and have been included within the reporting (SANBI) and the Gauteng Department of Agriculture and Rural Development (GDARD), developed the EMM Bioregional Plan. The documents. purpose of the bioregional plan is to inform land-use planning, environmental assessment and authorisations, and natural resource management, by a range of sectors whose policies and decisions impact on biodiversity. This is done by providing biodiversity priority areas, referred to as ‘critical biodiversity areas and ecological support areas’, with accompanying land use planning and decision-making guidelines.

Critical biodiversity areas within the bioregion are the portfolio of sites that are required to meet the region's biodiversity targets

Policies, Guidelines and By-Laws and need to be maintained in the appropriate condition for their category. The Ekurhuleni Metropolitan Municipality Bioregional Plan identified the following categories:

❖ Critical Biodiversity Area One; ❖ Critical Biodiversity Area Two; ❖ Ecological Support Area One; ❖ Ecological Support Area Two; ❖ Protected areas; ❖ Important areas ❖ Other natural areas

The Project is expected to affect Ecological Support Areas, Protected Areas and Important Areas. National Water and Sanitation Master Plan (NW&SMP) Aspects of this NW&SMP are applicable to the Proposed Project. Where applicable, these have The NW&SMP is based on five key objectives that define a ‘new normal’ for water and sanitation management in South Africa: been considered throughout the EIA process and have been included within the reporting ❖ Resilient and fit-for-use water supply; documents. ❖ Universal water and sanitation provision; ❖ Equitable sharing and allocation of water resources; ❖ Effective infrastructure management, operation and maintenance; and ❖ Reduction in future water demand.

The Proposed Project is likely to impact water resources. However, the long-term impacts are envisaged to be positive as the Proposed Project entails the removal of a water pollution source. The Centre for Environmental Rights - Mining and your Community: Know your Environmental Rights Even though the recovery of the Marievale TSFs is not mining governed by the MPRDA, this FEIA To exploit a mineral, mining companies must get permission to mine from the government. This is known as an Environmental incorporates the recommendations and Authorisation. To get permission, the mining company is required to assess the environment and learn about the community guidelines listed in the guide when undertaking and consult with everyone who will be affected by the proposed mining. The Guide published in 2014 by the CER discusses what Public Participation (PP). All PP is implemented

Policies, Guidelines and By-Laws rights communities and individuals who are affected by mining have, and what laws and processes must be followed by a mining according to the requirements listed in the company before it can start mining. NEMA EIA Regulations of 2017.

Refer to Chapter 7 for an overview of Public Participation to be undertaken. The National Water Resource Strategy (NWRS) Aspects of this resource strategy are applicable to the Proposed Project. Where applicable, The NWRS intends to ensure that: these have been considered throughout the S&EIA process and have been included within ❖ water supports development and the elimination of poverty and inequality; the reporting documents. ❖ water contributes to the economy and job creation, and ❖ water is protected, used, developed, conserved, managed and controlled sustainably and equitably.

The Proposed Project can contribute in ensuring that the Blesbokspruit is remediated and protected for future generations by eliminating a pollution point source. The Gauteng Province Environmental Management Framework, 2014 Aspects of this management framework are applicable to the Proposed Project. Where The Gauteng Department of Agriculture and Rural Development (GDARD) decided to produce an Environmental Management applicable, these have been considered Framework for the whole of Gauteng. The objective of the GPEMF is to guide sustainable land use management within the throughout the S&EIA process and have been Gauteng Province. The GPEMF, inter alia, serves the following purposes: included within the reporting documents.

❖ To provide a strategic and overall framework for environmental management in Gauteng; ❖ Align sustainable development initiatives with the environmental resources, developmental pressures, as well as the growth imperatives of Gauteng; ❖ Determine geographical areas where certain activities can be excluded from an EIA process; and ❖ Identify appropriate, inappropriate and conditionally compatible activities in various Environmental Management Zones in a manner that promotes proactive decision-making. The United Nations’ Sustainable Development Goals (SDGs) Aspects of these development goals are applicable to the Proposed Project. Where

Policies, Guidelines and By-Laws SDG 6 calls for access to water and sanitation for all. The objectives of SDG 6 include the following: applicable, these have been considered throughout the EIA process and have been 6.1 By 2030, achieve universal and equitable access to safe and affordable drinking water for all; included within the reporting documents.

6.2 By 2030, achieve access to adequate and equitable sanitation and hygiene for all and end open defecation, paying special attention to the needs of women and girls and those in vulnerable situations;

6.3 By 2030, improve water quality by reducing pollution, eliminating dumping and minimizing release of hazardous chemicals and materials, halving the proportion of untreated wastewater and substantially increasing recycling and safe reuse globally;

6.4 By 2030, substantially increase water-use efficiency across all sectors and ensure sustainable withdrawals and supply of freshwater to address water scarcity and substantially reduce the number of people suffering from water scarcity;

6.5 By 2030, implement integrated water resources management at all levels, including through transboundary cooperation as appropriate;

6.6 By 2020, protect and restore water-related ecosystems, including mountains, forests, wetlands, rivers, aquifers and lakes;

6.A By 2030, expand international cooperation and capacity-building support to developing countries in water- and sanitation- related activities and programmes, including water harvesting, desalination, water efficiency, wastewater treatment, recycling and reuse technologies;

6.B Support and strengthen the participation of local communities in improving water and sanitation management.

In relation to 6.3 and 6.6, we believe the Proposed Project would contribute to improving water quality and the ecological state of the Blesbokspruit Wetland System, respectively. The Public Participation Guidelines in terms of the National Environmental Management Act, 1998 Environmental Impact This guideline was used to ensure that all of the Assessment Regulations, 2017 required steps are followed to ensure that a complete and successful public participation

Policies, Guidelines and By-Laws This document aims to assist with the participation process of all interested and affected parties regarding any Proposed Project. process is conducted. This guideline provides information and guidance for proponents or applicants, interested and affected parties, competent authorities and environmental assessment practitioners on the public participation requirements of the act, as well as provides information on the characteristics of a vigorous and inclusive public participation process. Integrated Environmental Management Guideline on Need and Desirability, 2017 This guideline was used to ensure that the need and desirability of the project was correctly This document assists Environmental assessment practitioners on the best practice as well as how to meet the peremptory considered and that the need and desirability of requirements prescribed by the legislation as well as sets out both the strategic and statutory context for the consideration of the project was thoroughly considered. the need and desirability of a development involving any one of the NEMA listed activities. This document further sets out a list of questions which should be addressed when considering need and desirability of a proposed development. Upper Vaal Blue Deal Project Aspects of this project are applicable to the Proposed Project. Where applicable, these have The Blue Deal Project aims to enhance access to sufficient, clean and safe water for all by 2030 and beyond. It also advocates for been considered throughout the EIA process cooperation in solving local government level water-related problems. Some of the proposed interventions are to: and have been included within the reporting documents. ❖ Prevent further mining developments that threaten the sustainability of the wetland; ❖ Improve environmental education; ❖ Promote the green economy to foster local economic development; ❖ Introduce EM 50 data logger and sensor node (EC/Depth/temp) technology upstream and downstream of the wetland; ❖ Implement remote sensing to monitor trend of the wetland; ❖ Develop strategy to achieve the gazetted resource quality objectives (RQOs) of the catchment; ❖ Implement waste discharge charge system.

Although the Proposed Project is expected to impact the short, to medium, term quality and quantity of the Blesbokspruit; we envisage that the removal of the TSFs will improve the water qualities of the stream and extend the wetland footprint.

CHAPTER 5: THE NEED AND DESIRABILITY OF THIS PROJECT

The following sections below illustrate the need and desirability of the proposed project.

5.1 Environmental Pollution

TSFs 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 TSFs. However, the particulate matter associated with these areas can travel for kilometres and water pollution can be far reaching.

According to the Gauteng Department of Agriculture and Rural Development (GDARD, 2011), water pollution from abandoned mines is commonly associated with the problem of Acid Mine Drainage (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 TSFs, especially slimes dams, are closely associated with these underground mine voids, so the issue of water ingress into those voids, via fissures arising from the geotechnically unstable surface, is of great importance. Unfortunately, many older TSFs were placed in riverbeds or over dolomite 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 released AMD report. Possibly more important, however, is the broader issue of ‘diffuse sources’ of pollution represented by the TSFs and their possible interactions with precipitation, seepage, surface-water runoff and shallow groundwater. A long-term sustainable solution is needed for both the AMD and TSF problems. This project would contribute to resolving some these problems.

Soil contamination, including the mere presence of TSFs 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 unauthorized entry to a mine site, by living in settlements directly adjacent to mines or in some cases, living in settlements on the contaminated TSFs 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).

Winde et al. (2019) conducted a study on Human Exposure to Uranium in South African Gold Mining Areas Using Barber-Based Hair Sampling. The study investigated hair samples from customers at barber shops across Johannesburg and found that residents living in and around gold mining areas are exposed to elevated environmental levels of uranium which eventually finds its way into their bodies. Although the findings of this study were inconclusive, Winde et al. (2019) state that the Uranium (U) measurements in water, soil, and food that is in proximity to gold mining activities, in populated areas of Gauteng Province, suggest the possibility of exposure levels that may lead to adverse health consequences, including cancer.

The Proposed Project would play a significant role in eliminating some of these suspected pollution sources and reducing the extent of exposure to surrounding communities.

5.2 Safety and Security

According to GDARD (2012), most TSFs 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 TSFs. Dust control equipment such as sprayers and pumps are often stolen, which reverts back to environmental issues; while copper theft in the TSFs 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 TSFs include illegal mining and illegal settlements near the unsupervised properties. These issues pose safety risks for law enforcement, affected landowners and adjacent communities.

5.3 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 TSFs. 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.

The Proposed Project is situated in Zone 3 of the Gauteng Provincial Environmental Management Framework (GPEMF) (2018), which are sensitive areas outside of urban areas. It is also directly adjacent to the Blesbokspruit Wetland System and Marievale Bird Sanctuary Nature Reserve, Conservation and Protected Areas respectively. The project site is also situated in one of the focus areas for land-based protected areas expansion identified in the GPEMF (2018), it is anticipated that the land will be levelled and revegetated to match the surrounding environment after it has been rehabilitated.

5.4 The Gold Industry of South Africa

South Africa has undergone a long-term decline in gold output and South Africa’s share of world gold production has in recent times decreased to about 5%. This trend continued in 2018 and 2019. The overall decrease of gold production may be as a result of unreliable electricity-supply constraints, rising administered prices, labour issues, as well as waning productivity rates impeding its operational performance.

The reprocessing and reclamation of the Marievale TSFs will help retrieve gold from the slimes dams. The revival of gold processing and recovery will add valuable tonnages to a declining market.

5.5 Conclusion: Need and Desirability

The overall objective of this project is to recover residual gold from tailings within three existing TSFs (7L5, 7L6 and 7L7). The resultant residue 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 Marievale TSFs.

The land being cleared could be a secondary or consequential product. The clearing of land is an extremely important and positive benefit, as the removal of the TSFs would result in the removal of a water, land and dust pollution source to a highly sensitive surrounding environment, as well as costs associated with tailings dam maintenance. The land would be cleared to ground level and thereafter be available for a different land use. This could result in the reinstatement of the natural drainage lines of the Blesbokspruit and the subsequent expansion of the Blesbokspruit Wetland System, as well as an improvement in the biodiversity of the Marievale Bird Sanctuary Nature Reserve (McKay et al., 2018).

The Proposed Project would also directly and indirectly contribute to the country’s Growth Domestic Product (GDP), as well as provide continued employment to current employees of Ergo.

Overall, the Proposed Project is in line with the objectives of the Gauteng Mine Residue Area Strategy (2012), which are to reclaim and/or rehabilitate TSF footprints to the point where they become safe for adjacent communities and land can be made available for other purposes.

CHAPTER 6: APPROACH TO UNDERTAKING THE EIA PROCESS

An EIA process refers to a process undertaken in accordance with the requirements of the relevant EIA Regulations (i.e. the 2014 EIA Regulations, as amended (GN R982 of December 2014)), which involves the identification and assessment of direct, indirect, and cumulative environmental impacts associated with a proposed project or activity. The EIA process culminates in the preparation and submission of a Final EIA Report (including an EMPr) to the competent authority for decision-making. The EIA process is illustrated in Figure 6-1.

Figure 6-1: The Phases of the EIA process

The Marievale Project requires EA in accordance with the requirements of Section 24 of NEMA and the 2014 EIA Regulations (GN R982 of December 2014) (as amended). The applicant has appointed Kongiwe Environmental (Pty) Ltd, as the independent environmental consultants responsible for undertaking the EIA process required in support of the application for EA. An application for EA was prepared and submitted to DMRE, and the project was assigned a DMRE Reference of GP 30/5/1/1/2 (000007BP) BAR.

6.1 Relevant Legislative Permitting Requirements

7 National Environmental Management Act, 1998 (Act No. 107 of 1998) (NEMA)6F6F

Table 2-1 contains all the listed activities identified in terms of NEMA, the 2014 EIA Regulations (GNR 982), and Listing Notice 1 (GNR 983), Listing Notice 2 (GNR 984), and Listing Notice 3 (GNR 985) which may be triggered by the proposed development of the Proposed Project, and for which EA has been applied.

National Heritage Resources Act, 1999 (Act No. 25 of 1999) (NHRA)

The National Heritage Resources Act, 1999 (Act No. 25 of 1999) (NHRA) provides an integrated system which allows for the management of national heritage resources and to empower civil society to conserve heritage resources for future generations. Section 38 of the NHRA provides a list of activities which potentially require the undertaking of a Heritage Impact Assessment.

Section 38: Heritage Resources Management

7 The Minister of Environmental Affairs has, on the 7th April 2017, published the following amendments to the NEMA EIA Regulations of 2014: EIA Regulations of 2014 (GNR 326) and the 3 Listing Notices (GNR 324, 325 & 327).

1. Subject to the provisions of subsections (7), (8) and (9), any person who intends to undertake a development categorised as – a. the construction of a road, wall, power line, pipeline, canal or other similar form of linear development or barrier exceeding 300m in length; b. the construction of a bridge or similar structure exceeding 50m in length; c. any development or other activity which will change the character of a site – i. exceeding 5 000m² in extent; or ii. involving three or more existing erven or subdivisions thereof; or iii. involving three or more erven or divisions thereof which have been consolidated within the past five years; or iv. the costs of which will exceed a sum set in terms of regulations by SAHRA or a provincial heritage resource authority;

Must at the very earliest stages of initiating such a development, notify the responsible heritage resources authority and furnish it with details regarding the location, nature and extent of the proposed development.

In terms of Section 38(8), approval from the heritage authority is not required if an evaluation of the impact of such development on heritage resources is required in terms of any other legislation (such as NEMA), provided that the consenting authority ensures that the evaluation of impacts fulfils the requirements of the relevant heritage resources authority in terms of Section 38(3) and any comments and recommendations of the relevant resources authority with regard to such development have been taken into account prior to the granting of the consent. However, should heritage resources of significance be affected by the proposed development, a permit is required to be obtained prior to disturbing or destroying such resources as per the requirements of Section 48 of the NHRA, and the SAHRA Permit Regulations (GNR 668).

National Water Act, 1998 (Act No. 36 of 1998) (NWA)

In accordance with the provisions of the NWA all water uses must be licenced by the competent Authority (CA). The project falls within the 1:50 year floodline. Exemption from Government Notice No. 704 of the National Water Act, 1998 (Act 36 of 1998) (NWA) will be applied for. Ergo will apply for a water use licence (WUL) in terms of Sections 21 (c) and (i) of the same act.

Even though some parts of the proposed pipelines may be laid in Zones 1 and 5, they may require authorisation in terms of the NWA for Section 21 water uses. An Integrated Water Use Licence Application (IWULA) will 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 will be supported by a Technical Report and other necessary supplementary reports.

6.2 Overview of the Scoping and EIA process being undertaken

The Scoping Phase of the EIA process refers to the process of identifying potential issues associated with the proposed project and defining the extent of studies required during the EIA Phase. This is achieved through

an evaluation of the proposed project, involving the project proponent and a public consultation process with key stakeholders (including government authorities) and Interested and Affected Parties (I&APs).

Tasks completed during the EIA phase

The EIA Phase for the Marievale Project has been undertaken in accordance with the 2014 EIA Regulations (as amended) published in terms of Section 24(5) of NEMA. Key tasks undertaken during the EIA Phase to date include:

❖ Consultation with relevant decision-making and regulating authorities (at national, provincial and local levels). ❖ Undertaking a public participation process throughout the EIA process in accordance with the requirements of Regulations 39 to 44 of the 2014 EIA Regulations (as amended) to identify any additional issues and concerns associated with the proposed project. ❖ Preparation of a Comments and Response Report detailing key issues raised by I&APs as part of the EIA Process (in accordance with the requirements of Regulation 44 of the 2014 EIA Regulations (as amended). ❖ Undertaking independent specialist studies in accordance with the requirements of Regulation 23(5) and Appendix 6 of the 2014 EIA Regulations (as amended). ❖ Preparation of an EIA Report in accordance with the requirements of Regulation 23 and Appendix 3 of the 2014 EIA Regulations (as amended).

The following subsections outline the Public Participation activities within the EIA process that have been undertaken to date.

Public Participation 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 public participation process (PPP) has been developed to ensure compliance with the Environmental Authorisation and an Integrated Water Use Licence Application for the Proposed Project.

The PPP has four phases of consultation with I&APs during the environmental regulatory process. These are presented in Table 6-1 below:

Table 6-1: Activities undertaken and to be undertaken during the public participation process

PROJECT PHASE DESCRIPTION OF ACTIVITIES

Pre-scoping Phase ❖ Identification of stakeholders; ❖ Consultation with Authorities; ❖ Providing project information to stakeholders; and

❖ Obtaining comments, suggestions and concerns from stakeholders.

PROJECT PHASE DESCRIPTION OF ACTIVITIES

Scoping Phase ❖ Consultations 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; ❖ Providing stakeholders with further details of the proposed project and associated specialist studies; ❖ Consultations with stakeholders; ❖ Obtaining further comments, suggestions and concerns from stakeholders; and

❖ Informing specialists and the applicant about comments received from stakeholders.

EIA Phase ❖ Present findings from the specialist studies conducted and mitigation measures proposed by means of consultation with stakeholders; ❖ Provide opportunity for I&APs to comment on specialist findings, impacts assessments and recommendations; ❖ Make the relevant environmental reports available for public review and comment; ❖ Consultation with stakeholders; ❖ Verify that comments raised by I&APs have been accurately recorded; and

❖ Inform specialists and the applicant of stakeholders’ comments.

Decision Making Phase ❖ Once the competent authority has come to a decision regarding the authorisation of the project, all registered stakeholders will be notified of the decision made and the appeal process will be explained.

6.2.1.1 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).

6.2.1.2 Submission of the Application

An application for an Integrated Environmental Authorisation listed in terms of the National Environmental Management Act, (Act No. 107 of 1998) (NEMA) was submitted to the DMRE on 22 October 2019. An acknowledgement letter from the DMRE was received on 28 October 2019 and the following reference number (GP 30/5/1/1/2 (000007BP) BAR was assigned to the proposed project - Please see Appendix C7 for a copy of an acknowledgement letter.

6.2.1.3 Identification of Stakeholders

To ensure representation of stakeholders, the methods below were used 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 chain referral systems, this entailed the following activities:

o Telephonic consultations and meetings with landowners, National, Provincial and Local Government and other representatives; and o A site visit was undertaken to identify I&APs for which no contact details could be obtained; o Consultation meetings with the ward councillors; o Query to the Surveyor General and the Deeds office.

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

❖ Government: National, Provincial, and Local Authorities; ❖ Parastatals: Various semi-Government entities, Organs of State. ❖ Landowners: Directly and indirectly affected and adjacent; ❖ Land occupiers: Directly or indirectly affected and adjacent; ❖ Surrounding communities; ❖ Agriculture and Water: Farmers’ associations, entities responsible for water management and/or regulation; ❖ Environmental Forums; ❖ Non-Governmental Organisations (NGOs): Environmental organisations, community-based organisations; and ❖ Business and industry: Small to Medium and Micro-sized Enterprises, mines, industrial and large business organisations. ❖ Nature Reserves.

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

6.2.1.4 Land Claims

A formal enquiry, which contained a list of all the directly affected properties for the project, was submitted to the Land Claims Commission, Gauteng Department of Agriculture, Land Reform and Rural Development (DALRRD) on Thursday, 17 July 2019 (refer to Appendix C2). Feedback was received by means of letters dated Wednesday, 30 October 2019 (refer to Appendix C2) indicating that there are land claims on the following properties.

❖ Portion: 1 (RE), 93 (RE), 104, 113 (RE), 117 (RE), 122, 122, 123, 125, 126, 127 (RE), 128, 146, 151 (RE), 159, 180, 181, 182, 196, 197 and 199 of the farm Daggafontein 125 – Registration Division IR, Gauteng; ❖ Portion 0 (RE), 10, 35, 52 (RE), 82, 85, and 99 of the farm Grootfontein 165 – Registration Division IR, Gauteng; ❖ Portion 10, 85, 97 and 96 of the farm Vlakfontein 130 – Registration Division IR, Gauteng; ❖ Portion 1 (RE), 150, and 1558 of the farm Witpoortje 117 – Registration Division IR, Gauteng.

6.2.1.5 Public Participation Materials

Considering the legislative requirements and good practice, the following documents below have been developed and distributed to stakeholders. The various PPP information 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) provided important information regarding the following:

❖ A project description of the proposed reclamation of the Marievale Project; ❖ The Environmental Impact Assessment and the Public Participation Process to be undertaken in support of the reclamation process and relevant contact details of the public participation practitioners; ❖ 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 ❖ Invitation to attend an open day.

The BIDS were emailed to all stakeholders on the database, and hand delivered to the affected and surrounding landowners. The BID is available on Kongiwe’s website (under public documents).

Newspaper advertisements: Newspaper advert (Appendix 4) was placed in the Springs Advertiser, a local newspaper on Thursday, 24 October 2019 within project area. The newspaper advertisement provided the following details:

❖ Brief project description; ❖ Legal framework, the competent authorities and details of the appointed EAP; ❖ The venues where the DSR could be accessed; ❖ The details of the public meeting; ❖ Registration as Stakeholders; ❖ The contact details of the stakeholder engagement office.

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 similar to 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 map and the site notice report).

Notification Letter with a Comment and Registration Form: A notification letter was sent to stakeholders on Wednesday, 16 October 2019 to inform them about the proposed project, applicable legislation and competent authorities. The letter also shared details of the open day, a Registration Form was also provided for stakeholders to use for formal registration as stakeholders and/or to submit comments. (See Appendix C3). A reminder email was sent on Monday, 4 November to all stakeholders to inform them of the availability of the Draft Scoping Report public review period and the open day (Appendix C6).

Telephonic discussions: Stakeholders were also consulted by means of telephonic discussions. These discussions facilitated the process of inviting stakeholders to the open day.

6.2.1.6 Draft Scoping Phase Consultation

Pre-Scoping Consultation: Pre-scoping consultation with key stakeholders was aimed at providing stakeholders with an overview of the proposed project and to obtain initial comments which informed specialist studies and project planning. This was done by means of a Power Point Presentation and a locality map showing the properties. Pre-consultation meetings were held with the Competent and Commenting authorities. Meetings were also held with the directly affected landowners on a one-on-one basis. Minutes of these meetings were compiled and distributed to stakeholders. Refer to (Appendix C8) for a list of meetings and consultations that were undertaken.

All comments raised by stakeholders during these meetings were also captured into the Comment and Response Report (CRR). Responses to comments were provided in line with the overall project scope and available information (Appendix C9).

Open Day Workshop / Public Consultation: An Open Day was held on Saturday, 09 November 2019, from 10H00 until 15H00 at the Grootvaly Blesbokspruit Wetland Reserve in Welgadacht Road in Springs. The purpose of the open day was to discuss the proposed project, contents of the Draft Scoping Report, to provide stakeholders with an opportunity to raise their concerns/comments and also to interact with the project team members. Minutes from the open day have been compiled and distributed to all stakeholders on the database. (Appendix C8).

Mobilisation of stakeholders was done for Authorities, NGOs, landowners / land occupiers and community members to promote attendance, by means of telephonic consultation and distribution of emails and Short Message Services (SMS).

Figure 6-2: Pictures from the Open Day held on Saturday, 9 November 2019

All comments raised by stakeholders have been captured into the CRR (Appendix C9). Stakeholder comments were closely considered and addressed, where applicable, by the project team to ensure that the scope for specialist studies to be undertaken was well defined. Responses have been provided to the comments raised by stakeholders and included in the CRR throughout the PPP.

Comment sheets and electronic copies of the Draft Scoping Report were made available at the open day

Availability of the Draft Scoping Report for public review and comment: The Draft Scoping Report (DSR) was made available to stakeholders for a 30-day comment period from Wednesday, 23 October 2019 to Thursday, 21 November 2019 (please refer to Table 6-2 for a list of places where the report could be accessed). Notification of the availability of the documentation for review was distributed on Wednesday, 16 October 2019. A reminder email was sent on Monday, 4 November 2019 to all stakeholders on the database.

Table 6-2: Public places where the Draft Scoping Report can be accessed

LOCATION PHYSICAL ADDRESS CONTACT PERSON Hard copies Dunnottar Public Library 47 Rhodes Avenue, Dunnottar Mr Shelton Mnisi (Librarian)

(011) 999 9118 Kwa-Thema Public Library 7019 Nkosi Street, Kwa-Themba, Ms Portia Mosetlhe (Librarian) Springs (011) 999 8494 Electronic copies Kongiwe Environmental website www.kongiwe.co.za/ public Sibongile Bambisa / documents Vanessa Viljoen For a CD copy please contact the stakeholder engagement team (Sibongile Bambisa/ Vanessa Viljoen), Tel: (012) 003 6627, Email: [email protected]

The DSR was distributed to the Competent Authority, the Department of Mineral Resources and Energy (DMRE) and key Commenting Authorities.

Key Commenting Authorities that have received copies of the DSR are as follows:

❖ Department of Human Settlements, Water and Sanitation (DHSWS). ❖ National Nuclear Regulator (NNR). ❖ Gauteng Department of Agriculture and Rural Development (GDARD). ❖ National Department of Health (DoH). ❖ Johannesburg Health District. ❖ South African Heritage Resources Agency (SAHRA). ❖ Department of Public Works and Infrastructure (DPW). ❖ Department of Environment, Forestry and Fisheries (DEFF). ❖ Department of Environmental Affairs (DEA); and ❖ City of Ekurhuleni Metropolitan Municipality

The table below provides details of the activities that formed part of the Draft Scoping Phase.

Table 6-3: Summary of PP activities during the Draft Scoping Phase

REFERENCE IN DRAFT ACTIVITY DETAILS SCOPING REPORT Pre-scoping Phase Stakeholders, were identified by means of WinDeed Appendix C1 Identification of stakeholders searches, stakeholder networking and research for the compilation of a stakeholder database. Stakeholder database A formal enquiry, which contained a list of all the directly affected properties for the project, was submitted to the Land Claims Commission, Gauteng Department of Agriculture, Land Reform and Rural Development Appendix C2 Identification of land claims (DALRRD) on Thursday, 17 July 2019 (refer to Appendix C2). Feedback was received by means of letters dated Land claims letters Wednesday, 30 October 2019 (refer to Appendix C2) indicating that there are land claims on some of the properties within the proposed project area. The BID was developed and emailed to the full stakeholder Development of the Appendix C3 database on Wednesday, 16 October 2019. The BID was Background Information also distributed at stakeholder meetings, public libraries Document BIDs and was available on Kongiwe’s website. Appendix C4 Placing of media An advertisement was placed in the Springs Advertiser, a advertisements Regional newspaper on Thursday, 24 October 2019. Advertisements

REFERENCE IN DRAFT ACTIVITY DETAILS SCOPING REPORT Pre-scoping Phase Site notices were placed at a publicly accessible places within proximity of the project area from Tuesday, 29 October 2019. A copy of a Site Notice was also placed at the:

Appendix C5 ❖ Dunnottar Public Library, 47 Rhodes Avenue, Placing of site notices Dunnottar Site notice report and ❖ Kwa-Thema Public Library, 7019 Nkosi Street, placement map Kwa-Themba, Springs

A site notice placement report and map were developed, indicating the exact locations where site notices were placed, with photos and GPS coordinates. The announcement letter was emailed to the full stakeholder database on Wednesday, 16 October 2019 to: Appendix C6 ❖ Announce availability of the Scoping Report. ❖ Share details of the open day. Announcement Letter ❖ Indicate where the Scoping Report will be available Announcement of the project for public review and comment; and Appendix C3 and Draft Scoping Report ❖ Provide details of the public comment period. BID The Draft Scoping Report was made available on Kongiwe’s website http://www.kongiwe.co.za/publications-view/public- documents/ Appendix C8 One-on-one meetings and focus group meetings were held with Authorities and Directly Affected landowners. A List of meetings & Meeting list of meetings and minutes of these meetings was Minutes compiled and distributed. Stakeholder meetings Appendix C9 A high-level overview of the Proposed Project was discussed, and stakeholder comments have been captured Comment and Response and responded to in the CRR. Report An open day was held with stakeholders on Saturday, 09 Appendix C9 November 2019, from 10H00 until 15H00 at the Grootvaly Blesbokspruit Wetland Reserve in Welgadacht Comment and Response Open Day Road in Springs. Minutes from the open day were Report compiled and distributed to everyone who attended the meeting. Comments raised from the meeting were

included in the Comment and Response Report.

6.3 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 were notified of the availability of the Final Scoping Report for review on Thursday, 28 November 2019 (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.

Table 6-4: Summary of PPP activities undertaken during the Final Scoping Phase

ACTIVITY DETAILS

The stakeholder database was updated with new I&APs who formally Update of stakeholder information registered, attended stakeholder meetings or submitted comments. The Final Scoping Report for the proposed Marievale project has been made Placement of Final Scoping Reports available on the Kongiwe Environmental website http://www.kongiwe.co.za/publications-view/public-documents/ Announcement letter of availability of the Final Scoping Report for comment Announcement of the Final Scoping was emailed to the full stakeholder database on Thursday, 28 November Report 2019.

6.4 Consultation with stakeholders during the Impact Assessment Phase

Consultation with stakeholders during the EIA Phase provided stakeholders with an opportunity to provide comments on findings from the specialist studies, recommendations and mitigation measures proposed. These studies and recommendations were included as part of the Environmental Impact Assessment Report and the Environmental Management Programme EIA/EMPr. Stakeholders were provided with opportunities to raise their concerns/ comments and engage with the project team.

Availability of the Draft EIA and EMP for public comment

The DEIR/EMPr was made available for a 30-day public review period from Thursday, 19 March 2020 to Tuesday, 21 April 2020. Notification of the availability of the documentation for public review and comment was distributed on Tuesday, 10 March 2020 to all stakeholders on the database to notify them of the availability of the DEIR/EMPr and the Open Day. The reports were made available at the locations indicated in Table 6-5 below:

Table 6-5: Public places where the Draft EIA/EMPr reports could be accessed

LOCATION PHYSICAL ADDRESS CONTACT PERSON Hard copies Dunnottar Public Library 47 Rhodes Avenue, Dunnottar Mr Shelton Mnisi (Librarian)

(011) 999 9118

Kwa-Thema Public Library 7019 Nkosi Street, Kwa-Themba, Ms Portia Mosetlhe (Librarian) Springs (011) 999 8494 Marievale Bird Sanctuary Provincial R42 Delmas road, Marievale Nature Mr Rhulani Maluleke, Manager Nature Reserve Reserve, Nigel (071) 258 6518 Electronic copies www.kongiwe.co.za/ public Sibongile Bambisa/ Vanessa Viljoen, Kongiwe Environmental website documents Tel: (012) 003 6627

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

The DEIR/EMPr reports were distributed to the Competent Authority (Department of Mineral Resources and Energy (DMRE) and key Commenting Authorities. Refer to (Appendix C7) for proof of delivery.

The Public Open Day

An Open Day was scheduled for Saturday, 4 April 2020 for all stakeholders who are affected by or interested in the project, details of the Open Day are indicated below (Table 6-6). The intention of this open day was to provide feedback to stakeholders on specialist studies undertaken and to obtain further comments. The Open day afforded stakeholders the opportunity to engage with the project team members/specialists on technical information for example surface and ground water, air quality, wetlands and traffic.

Table 6-6: Details of the Open Day

Date Venue Time Marievale Bird Sanctuary Provincial Nature Reserve, Saturday, 4 April 2020 10:00 to 14:00 R42 Delmas road, Marievale Nature Reserve, Nigel

The Public Open Day Cancellation – COVID-19

Considering the announced ban on public gatherings to curb the spread of COVID-19 and in line with the Presidential address of 15 March 2020, stakeholders were informed that the proposed open day for the Marievale project has been cancelled indefinitely. Stakeholders have been encouraged to review the reports and submit written comments to Kongiwe’s stakeholder engagement team, please refer to the abovementioned methods on how you can comment on the Draft EIR/EMPr.

A notification letter (Appendix C6) informing stakeholders about the cancellation of the open day was sent on Monday, 17 March 2020, by means of email to the full stakeholder database.

In view of the declaration of a National State of Disaster by the President on 15 March 2020, to combat the spread of the Covid-19 virus, stakeholders were informed that the proposed open day (scheduled for 04 April 2020) was cancelled indefinitely. Stakeholders were encouraged to review the reports and submit written

comments to Kongiwe’s stakeholder engagement team. All comments raised are captured into the Comments and Responses Report and will be responded to.

6.5 Public Participation Materials: EIA phase

Notification Letter: a letter (Appendix C6) which provides details about the availability of the DEIR/EMPr Reports for public comment and an invitation to the Open Day were sent by email to the full stakeholder database. A Short Message Service (SMS) was sent to stakeholders who did not have email access.

Newspaper advertisements: A newspaper advert (Appendix C4) was placed in Springs Advertiser, a Regional newspaper on Thursday, 19 March 2020. The advertisement provided details about the public review period for the DEIR/EMPr and how the public could access the draft reports for their review and comment. The advert also provided information about the Open Day details.

Telephonic Discussions: Stakeholders were invited to the Open Day by means of telephonic discussions and SMS’ were be sent to key stakeholders to remind them of the Open Day (which was subsequently cancelled).

Maps: Various: Various maps were developed as part of the DEIR/EMPr for display during the Open Day (subsequently cancelled).

Posters: Posters were developed for use at the Open Day. The following aspects would have been covered in the poster presentation below:

❖ Project Overview; ❖ EIA process and legislative timeframes; ❖ Specialist findings, impacts and proposed mitigation measures; and ❖ PPP undertaken to date and next steps.

Table 6-7: Summary of PPP activities -Draft Environmental Impact Assessment Phase

Impact Assessment Phase Activity Details Reference in DEIR/EMPr A Notification letter announcing the availability of the DEIR/EMPr for public review and comment was emailed Announcement of the to the full stakeholder database on Friday, 13 March Appendix C6 availability of the Draft 2020. EIA/EMP Reports Announcement Letter (Public comment period for DEIR/EMPr (30 days): Thursday, 19 March 2020 to Tuesday, 21 April 2020. The DEIR/EMPr was made available to stakeholders at Placement of Draft EIA/EMP the following public places: Reports for public review - and comment ❖ Dunnottar Public Library

❖ Kwa-Thema Public Library; ❖ Marievale Bird Sanctuary Provincial Nature Reserve

An electronic copy of the DEIR/EMPr was made available on Kongiwe’s website http://www.kongiwe.co.za/publications-view/public- documents/

Copies of the DEIR/EMPr were sent to the DMRE and various Commenting Authorities for review and comment. In light of the announced ban on public gatherings to curb the spread of COVID-19 and in line with the Presidential address of 15 March 2020, stakeholders were informed that the proposed open day for the Marievale project had been cancelled indefinitely. Stakeholders were encouraged to review the reports and submit written comments to Kongiwe’s stakeholder Appendix C6 Open Day cancelled engagement team. Notification letter

A notification letter (Appendix C6) informing stakeholders about the cancellation of the open day was sent on Monday, 17 March 2020, by means of email to the full stakeholder database. Appendix C4

Placement of media An advertisement was placed in Springs Advertiser, a Advertisement advertisement for the EIA Regional newspaper on Thursday, 19 March 2020.

Extension of the public review and comment period

In accordance with Regulation GN R439 of 31 March 2020, the Minister of Forestry, Fisheries and the Environment, acting in terms of the Regulations issued in terms of section 27(2) of the Disaster Management Act, 2002, extended the timeframes prescribed in terms of the Environmental Impact Assessment Regulations 2014, the National Environmental Management: Waste Act, 2008 and National Environmental Management: Air Quality Act, 2004, by the number of days of the duration of the lockdown period of the national state of disaster declared for the COVID-19 pandemic, including any extensions to such duration, with effect from 27 March 2020 until the termination of the lockdown period.

Considering the above, the Draft EIA/EMPr reports for the proposed Marievale project were made available for an additional 21 days for public review and comment until Thursday, 14 May 2020.

A notification letter announcing the extension of the public review and comment period was emailed to all stakeholders on the database on Wednesday, 1 April 2020 (See appendix C6).

Extension of the public review and comment period 2nd announcement COVID-19

In light of the above, the Draft EIA/EMPr reports for the proposed Marievale project were available for public review and comment until Thursday, 28 May 2020.

A notification letter announcing the 2nd round COVID extension of the public review and comment period was emailed to all stakeholders on the database on Wednesday, 16 April 2020 (See Appendix C6).

6.6 Availability of the Final Environmental Impact Assessment Report / Final Environmental Management Programme (DEIR/EMPr) for public review and comment

The Final EIR/EMPr reports were distributed to the Competent Authority (DMRE) and key Commenting Authorities, please refer to (Appendix C7) for proof of delivery.

Key Commenting Authorities that have received copies of the reports are as follows:

❖ Department of Human Settlements, Water and Sanitation (DHSWS); ❖ National Nuclear Regulator (NNR); ❖ Gauteng Department of Agriculture and Rural Development (GDARD); ❖ National Department of Health (DoH); ❖ Johannesburg Health District; ❖ South African Heritage Resources Agency (SAHRA); ❖ Department of Public Works and Infrastructure (DPW); ❖ Department of Environment, Forestry and Fisheries (DEFF). ❖ Department of Environmental Affairs (DEA); and ❖ City of Ekurhuleni Metropolitan Municipality

Table 6-8: Summary of the PPP activities-Final EIA phase

Activity Details A notification letter announcing the availability of the FEIR/EMPr has been emailed to the full database on 26 June 2020.

Announcement of the FEIR/EMPr

An electronic copy of the Final EIR/EMPr is available on Kongiwe’s website http://www.kongiwe.co.za/publications-view/public- documents/ The FEIR/EMPr was submitted to the DMRE and the DHSWS and key Submission to the Authorities Commenting Authorities.

Availability of the technical report-IWULA process

A technical report in support of the IWULA process will be made available for public review and comment for a period of 60 days. Information regarding the availability of the IWULA report and how stakeholders can provide their comments will be communicated to all stakeholders

Consultation during the decision-making phase

Once the competent authority has taken a decision regarding the authorisation of the project, all registered stakeholders will be notified of the decision made and the appeal process to be followed

Table 6-9: Summary of the PPP activities-Final EIA phase

ACTIVITY DETAILS A notification letter announcing the availability of the FEIR/EMPr will be emailed to the full database. Announcement of the FEIR/EMPr

The FEIR/EMPr will be made available on Kongiwe’s website. The FEIR/EMPr will be submitted to the DMRE and the DHSWS and key Submission to the Authorities Commenting Authorities.

6.7 Consultation during the decision-making phase

Once the competent authority has taken a decision regarding the authorisation of the project, all registered stakeholders will be notified of the decision made and the appeal process to be followed.

CHAPTER 7: THE BASELINE ENVIRONMENT AND SPECIALIST FINDINGS

This Chapter provides a description of the environment that may be affected by the Marievale Project. The information is provided to assist the reader in understanding the receiving environment within which the project is proposed, and features of the biophysical, social, and economic environment that could be directly or indirectly affected by, or alternatively could impact on, the proposed development. This information has been sourced from existing available information and the on-site specialist investigations conducted as part of the EIA and aims to provide the context within which this EIA is being conducted. The full impact assessments undertaken by the independent specialists, including detailed descriptions of the affected environment, are attached as Appendices D of this EIA Report.

7.1 Climate

Refer to Specialist Study: Appendix D2 – Surface Water

Refer to Specialist Study: Appendix D4 – Air Quality

Rainfall

Rainfall data for the area was obtained from the Springs (RWB) rainfall station (station no. 0476736 W). The station is located 10 km north-west of the Marievale TSFs. Patched rainfall data was obtained for the period of 1971 to 2003. The mean monthly rainfall is indicated in Figure 7-1. The area has a Mean Annual Precipitation (MAP) of 716 mm. Rainfall is highest over the months of October to March, and lowest over the months of April to September.

Figure 7-1: Average monthly rainfall totals for the project area.

Storm Rainfall Depths

The storm rainfall depths for the centre position of the project area was 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 position, to calculate the storm rainfall depths. The extracted storm rainfall depths for the project is indicated in Table 7-1

Table 7-1: 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 9 12 15 18 22 25 29 10 min 13 18 21 25 31 36 41 15 min 16 22 26 31 38 44 51 30 min 20 28 34 40 49 57 65 45 min 24 33 39 47 57 66 76 1 hr 26 36 44 52 63 73 84 1.5 hr 30 42 51 60 73 85 97 2 hr 34 46 56 66 81 94 108 4 hr 40 56 67 80 98 113 130 6 hr 45 62 75 89 109 126 145 8 hr 49 67 81 96 118 136 156 10 hr 52 71 86 102 125 144 166 12 hr 54 75 90 107 131 152 174 16 hr 59 81 98 116 142 164 188 20 hr 62 86 104 123 150 174 199 24 hr 65 90 109 129 158 182 209 1 day 57 78 94 112 137 158 181 2 day 70 96 116 138 169 195 223 3 day 79 109 131 155 191 220 252 4 day 86 118 143 169 208 240 275 5 day 92 127 153 181 222 257 294 6 day 97 134 162 191 235 271 311 7 day 102 140 169 201 246 284 326

Evaporation

Symons Pan (S-Pan) evaporation data for the area was obtained from the WR2012 study for quaternary catchment C21E. S-Pan evaporation measurements are not a true reflection of evaporation from natural open water bodies, as the water temperatures in the S-Pan are higher, resulting in higher evaporation rates. To convert S-Pan measurements to open water evaporation, monthly open water evaporation conversion factors were used, which were obtained from the WR2012 study. The adopted monthly evaporation for the Project is

indicated in Table 7-2 shows that evaporation is highest over the months of September to March, and lowest over the cooler months of April to August.

Table 7-2: Symons Pan and open water evaporation for the project

Symons Pan Evaporation Open Water Evaporation Open Water Evaporation Month (mm) Factor (mm) January 185 0.84 155 February 153 0.88 135 March 143 0.88 126 April 108 0.88 95 May 88 0.87 77 June 71 0.85 60 July 77 0.83 64 August 111 0.81 90 September 150 0.81 122 October 177 0.81 143 November 177 0.82 145 December 191 0.83 159 Total 1 631 N/A 1 370

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 7-2 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 7-2: Minimum, average and maximum monthly temperature for the project (Source: HydroSpatial,2018)

Wind Direction

The predominant winds at the Proposed Project site (as given by the WRF data for the period from 2016 to 2018) are from an easterly direction for approximately 11 % of the time. However, the highest number of winds with speeds greater than 6.5 m/s are expected from a west-north-westerly direction, followed by winds from a north-westerly, north-north-westerly and westerly direction respectively. The average hourly wind speed predicted by the WRF model is approximately 2.44 m/s. Calm conditions (wind speeds below 0.5 m/s) are predicted for approximately 2.4 % of the time.

Figure 7-3: Wind rose of the average winds produced by the WRF model for the Marievale reclamation site, for the years 2015-2017

The seasonal variations in wind direction for the Marievale Project site are illustrated in Figure 7-4 The highest number of winds with speeds above 6.5 m/s are experienced in spring with winds originating mainly in the quadrant from westerly to north-north-westerly. In summer and autumn, the predominant wind direction is from the east. The maximum number of calm conditions are experienced in autumn.

Figure 7-4: Seasonal wind roses produced by the WRF model for the Marievale Project site for the years 2016-2018

There is a clear diurnal variation in both wind speed and wind direction at the Proposed Project site. During the warmer hours of the day, calm conditions are expected for approximately 4.4 % of the time, and average wind speeds are approximately 3 m/s. Wind speeds above 6.5 m/s are expected for approximately 6 % of the time. The most frequent winds with speeds above 6.5 m/s are expected from a west-north-westerly direction. During the night, calm conditions are expected for approximately 0.4 % of the time, and average wind speeds are approximately 2 m/s. The winds tend to blow more from an east-north-easterly to an east-south-easterly direction (Figure 7-5).

Figure 7-5: Diurnal wind roses predicted by the WRF model for the Marievale Project site for the years 2016- 2018

7.2 Geology and Soils

Refer to Specialist Study: Appendix D3 - Groundwater

Geology of the Project Area

Gold-bearing reefs within the Witwatersrand sediments have been mined over a significant portion of the East Rand and these operations have given rise to the mine dumps that are currently being reclaimed by Ergo.

The Witwatersrand strata is shallow in the area. Structurally, the geological basin in this area is marked by prominent folding and several major faults transect the area, notably the Vogels, Jeffreys and Grootvlei tear faults (DWAF, 2012). These strike east-west. The gold-bearing conglomerates outcrop in Nigel. The Witwatersrand rocks are entirely overlain by younger strata, including the Transvaal and Karoo Supergroups.

The Marievale TSFs and surrounding land are underlain by sandstone, shale and coal seams of the Vryheid Formation of the Ecca Group, Karoo Supergroup (Figure 7-6). The area is characterised by the intrusion of interconnected diabase sills, most significantly the Green Sill. This sill is present at a depth of approximately 60 m below surface and is considered laterally extensive in the area (AGES, 2006). It dips sub-parallel to the base of the Black Reef Formation. The intrusion of the sills is thought to result in the development of fractures and weathered rock, creating contact-zone localised aquifers. The sills are however considered impermeable.

Figure 7-6: Marievale Geology

Transvaal Supergroup formations, predominantly dolomite and quartzite, are found below the Vryheid Formations. The Chuniespoort sediments alternate between chert-rich and chert-poor dolomite. Based on the information presented by Barnard (2000) the chert-poor Oaktree Formation is adjacent to the Black Reef quartzite, followed by the chert-rich Monte-Christo Formation; then the Lyttleton, Eccles and lastly the Frisco Formations. The geological structure of the dolomitic rocks is expected to be karstic due to the erosion and dissolution of the carbonate rocks along joints and fractures (DWAF, 2012). This process has resulted in substantial water-storage potential and therefore the dolomite aquifer is considered a significant water resource, exploited extensively for domestic and agricultural usage. The Transvaal Supergroup is extensively developed, but largely covered by Karoo strata. The Transvaal formations are only exposed along river courses, especially the Blesbokspruit, as indicated on Figure 7-6 above.

Soils of the Project Area

According to DHSWS (2005), soils are the most important characteristic of wetlands to identify and delineate wetland areas accurately. The only hydromorphic soil form identified is that of the Katspruit soil form, a Wasbank soil form, a Dresden soil form and a Kroonstad soil form (Figure 7-7 to Figure 7-11)

The Wasbank soil form consists of an Orthic topsoil on top of an Albic horizon, which in turn is underlain by a Hard Plinthic horizon. The soil family group identified for the Wasbank soil form on-site has been classified as the “2100” soil family due to the light grey colour of the albic horizon when wet and the grey colours of the topsoil (see Figure 7-7 for an example of a Wasbank soil form).

Figure 7-7: Example of a Wasbank soil form, (SASA, 1999)

The Katspruit soil form consists of an Orthic topsoil on top of a Gleyic horizon. The 2210 family group is applicable to this soil form given the grey colours, the firm texture and structure of the soil form and the absence of lime (see Figure 7-8 for an example of a Katspruit soil form).

Figure 7-8: Example of a Katspruit soil form, (SASA, 1999).

The Kroonstad soil form consists of an Orthic topsoil on top of an Albi horizon, which in turn is underlain by a Gleyic horizon. The soil family group identified for the Kroonstad soil form is “1110” due to the gleyed colour of the topsoil, the Albic horizon’s grey colours when in a wet condition as well as the non-calcareous nature of the soil (see Figure 7-9 for an example of a Kroonstad soil form).

Figure 7-9: Example of a Kroonstad soil form (SASA, 1999)

The Dresden soil form consists of an Orthic topsoil on top of a Hard Plinthic horizon. The soil family group identified for the Dresden soil form on-site has been classified as the “3000” soil family given the fact the dark colours of the topsoil (see Figure 7-10 for an example of a Dresden soil form).

Figure 7-10: Example of a Dresden soil form, (SASA, 1999)

Figure 7-11: Hydromorphic soil forms. A: Mottling within an Orthic topsoil. B: Dresden soil form. C: Unspecified material without signs of wetness. D: Oxidation/reduction processes within hydromorphic soil. E: Gleyic horizon

Figure 7-12: Soils classified for the project area

7.3 Biodiversity

Refer to Specialist Study: Appendix D1 – Biodiversity Impact Assessment and Wetland Assessment

Environmental features relevant to the project area are listed in Table 7-3.

Table 7-3: Summary of Desktop spatial features examined

DESKTOP INFORMATION CONSIDERED RELEVANT/NOT RELEVANT

2011 Gauteng Conservation Plan 3.3 (C- Multiple sections of the proposed development intersect with CBA: Plan 3.3) Important and ESA areas. It also marginally overlaps with a protected area. The project area does not overlap with any ridges; the closest ridge is Rocky Ridges approximately 5km from the project area. Ecosystem Threat Status The project area falls within ecosystems which are listed as CR, EN, and LT. The ecosystems of the project area are rated as Not protected, Poorly Ecosystem Protection Level Protected and Moderately protected The 500 regulated area of the project area overlaps with several CR wetlands NBA Rivers and Wetlands as well as several LC wetlands. A CR river intersects the 500 m regulated area. Ramsar The project area overlaps with portions of the Blesbokspruit Ramsar site. The project area overlaps with both the Blesbokspruit conservation area and Protected Areas the Marievale Nature Reserve According to these guidelines, the project area falls within areas which are Mining and Biodiversity Guidelines considered to be ‘high risk for mining’, ‘highest risk for mining’ and ‘moderate risk for mining’ Important Bird and Biodiversity Areas The project area overlaps with portions of the Blesbokspruit IBA JMOSS The Blesbokspruit system is protected by JMOSS.

At the time of undertaking the Biodiversity Field Surveys, the project area, including a 200 m (wide) survey corridor was ground truthed on foot, which included spot checks in pre-selected areas to validate or refute desktop data. Photographs were recorded during the site visits and some are provided under the results section in this report.

The Habitat Assessment

Habitats identified during the field visit were delineated and are presented in Figure 7-13 to Figure 7-17. A 200 m survey corridor was used. Four primary habitats that were identified included: degraded grassland, secondary grassland, transformed habitat and wetlands.

The degraded grassland habitats have been fragmented from one another and disturbed from either historic mining practices and urban development, but also due to current ongoing impacts received from subsistence agriculture, commercial agriculture, informal settlement and general human presence. Due to the extent of the previous and current disturbance, the area is in a degraded state. This area does, however, form small

green islands within the largely transformed areas which acts as refugia for urban dwelling fauna. This habitat has a low-moderate sensitivity.

The secondary grassland habitat is considered to be areas in a natural ecological state, albeit currently and historically somewhat disturbed by the surrounding land use. This area serves as vital habitat for all fauna within the area. Within a local context, habitats like this function as an island for fauna and flora to survive within the ever-expanding human environment. This habitat has a high sensitivity.

The transformed areas are the areas which have little to no natural areas left due to being transformed. This habitat has been transformed by informal and formal housing, roads, old mining practise and other urban and industrial infrastructure such as powerlines. This habitat contributed to the high amount of alien flora recorded.

Figure 7-13: Habitats identified within the Marievale Project area

Figure 7-14: Habitats identified within the Marievale Project area.

Figure 7-15: Habitats identified within the Marievale Project ‘initial development area’.

Figure 7-16: The habitats observed within the project area; A) Transformed B) Degraded Grassland

Figure 7-17: Examples of some of the habitats observed within the project area; A) Secondary Grassland B) Wetlands

Gauteng Biodiversity Conservation Plan

The Gauteng Conservation Plan (Version 3.3; GDARD, 2014b) classified areas on the basis of their contribution to reach the conservation targets within the province. These areas are classified as Critical Biodiversity Areas (CBAs) and Ecological Support Areas (ESAs) to ensure sustainability in the long term. The CBAs are classified as either ‘Irreplaceable’ (must be conserved), or ‘Important’.

CBAs are terrestrial and aquatic areas that need to be maintained in a natural or near-natural state to ensure the continued existence and functioning of species and ecosystems and the delivery of ecosystem services. Thus, if these areas are not maintained in a natural or near natural state then biodiversity targets cannot be met.

According to the Gauteng Terrestrial CBA Plan (C-Plan), multiple sections of the proposed development intersect with CBA: Important and ESA areas, it also marginally overlaps with a protected area (Figure 7-18).

Figure 7-18: Gauteng C-Plan.

Designated Ramsar site

The Blesbokspruit Ramsar site is the only one found in Gauteng. It extends over 2 000 ha along the Blesbokspruit from the Grootvaly wetland reserve to the Marievale Bird Sanctuary. This wetland system is home to 230 species, of which 65 waterbird species can be exclusively found in the Marievale portion. Species of conservation concern in this area include African Grass Owl, Lesser- and Greater Flamingos, and White- bellied Korhaan. The Spotted-necked Otter has also been found in this habitat. The project area overlaps with portions of the Blesbokspruit Ramsar site (Figure 7-19).

Figure 7-19: The project area in relation to the Blesbokspruit Ramsar site.

National Biodiversity Assessment

The National Biodiversity Assessment (NBA) was completed as collaboration between the SANBI, the DEFF and other stakeholders, including scientists and biodiversity management experts throughout the country over a three-year period (Skonwo, 2018).

The two headline indicators assessed in the NBA are ecosystem threat status and ecosystem protection level (Skonwo, 2018).

7.3.1.1 Threatened Ecosystems

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 (CR), Endangered (EN), Vulnerable (VU) or Least Threatened (LT), based on the proportion of each ecosystem type that remains in good ecological condition (Skowno et al., 2019).

The project area falls within ecosystems which are listed as CR, EN, and LT. These ecosystems were given their threat status based on the classification of the IUCN Red List Ecosystem status (Skowno et al., 2019) (Figure 7-20).

Figure 7-20: The project area showing the ecosystem threat status of the associated terrestrial ecosystems (NBA, 2018)

7.3.1.2 Ecosystem Protection Level

Ecosystem protection level -indicates whether ecosystems are adequately protected or under-protected. Ecosystems were 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 (Skowno et al., 2019).

The project area falls within areas categorised as Not protected, Poorly Protected and Moderately protected areas.

National Freshwater Ecosystem Priority Area (NFEPA) Status

This spatial dataset is part of the South African Inventory of Inland Aquatic Ecosystems (SAIIAE) which was released with the National Biodiversity Assessment (NBA) 2018. In the NBA 2018 the National Freshwater

Ecosystem Priority Area (NFEPA) rivers GIS layer was used to represent the diversity of rivers nationally. This GIS layer summarizes the river ecosystem types, river condition, Ecosystem Threat Status (ETS) and Ecosystem Protection Level (EPL) as well as the free flowing (62 identified by the NFEPA project) and flagship river information and can be seen in relation to the project area in Figure 7-21.

The 500-metre regulated area intersects a CR river. The CR river is Poorly Protected.

Figure 7-21: The project area in relation to the NBA Rivers (BGIS, 2018).

Figure 7-22 Marievale project area in relation to NFEPA wetlands

Wetlands

This spatial dataset is part of the South African Inventory of Inland Aquatic Ecosystems (SAIIAE) which was released with the National Biodiversity Assessment (NBA) 2018. National Wetland Map 5 includes inland wetlands and estuaries, associated with river line data and many other data sets within the South African Inventory of Inland Aquatic Ecosystems (SAIIAE) 2018 and can be seen in relation to the project area in Figure 7-23.

Ecosystem threat status (ETS) of river ecosystem types is based on the extent to which each river ecosystem type had been altered from its natural condition. Ecosystem types are categorised as critically endangered (CR), endangered (EN), vulnerable (VU) or least concern (LC), with CR, EN and VU ecosystem types collectively referred to as ‘threatened’ (Van Deventer, et al., 2019; Skowno et al., 2019).

The project area and the associated 500-metre regulated area intersects and contains CR wetlands as well as wetlands that are LC. The CR wetlands are Not Protected where the LC wetlands are Poorly protected.

Figure 7-23: The project area in relation to the NBA wetlands (BGIS, 2018)

Flora

The project area falls within the Soweto Highveld Grassland, the Andesite Mountain Bushveld and the Tsakane Clay Grassland vegetation types (Mucina & Rutherford, 2018 vegetation delineation).

7.3.1.3 Tsakane Clay Grassland

The Tsakane Clay Grassland (GM9) vegetation type occurs in patches extending from Soweto and Springs, southwards to Nigel and Vereeniging. It also occurs north of the Vaal Dam and between the towns of Balfour and Standerton (Mucina & Rutherford 2006).

According to Mucina and Rutherford (2006), the Tsakane Clay Grassland vegetation type is classified as Endangered. The national target for conservation protection for this vegetation type is 24%, with only 1.5% conserved in statutory reserves (Suikerbosrand, Olifantsvlei, Klipriviersberg, Marievale) and a small portion also in private nature reserves (Avalon, Ian P. Coetser, Andros). More than 60% has been transformed by cultivation, urbanisation, mining, dam-building and roads. Large portions of Alberton, Springs, Tsakane and part of Soweto (all south and east of Johannesburg) were built in the area of this vegetation unit. Urbanization is increasing and further expansion of especially the southern suburbs of Johannesburg and the towns of the East Rand (especially the Brakpan District) will bring further pressure on the remaining vegetation.

7.3.1.4 Andesite Mountain Bushveld

The Andesite Mountain Bushveld vegetation type occurs in several separate patches across Gauteng, North- west, Mpumalanga and the Free State Provinces (Mucina & Rutherford, 2006). Several separate occurrences of which the main are: the Bronberg Ridge in eastern Pretoria extending to Welbekend; from Hartebeesthoek in the west along the valley between the two parallel ranges of hills to Atteridgeville; hills in southern Johannesburg; several hills encompassing Nigel, Willemsdal, Coalbrook and Suikerbosrand (in part); and the outer ring of ridges of the Vredefort Dome and some hills to the northwest around Potchefstroom. This vegetation type occurs at an altitude of about 1 350–1 800m. This vegetation type is characterized by dense, medium-tall thorny bushveld with a well-developed grass layer on hill slopes and some valleys with undulating landscape.

According to Mucina and Rutherford (2006), this vegetation type is classified as Least threatened. The national target for conservation protection is 24%. About 7% is statutorily conserved mainly in the Suikerbosrand Nature Reserve and Magaliesberg Nature Area. An additional 1–2% conserved in other reserves mainly in the Hartbeesthoek Radio Astronomy Observatory. Some 15% has already been transformed, mainly by cultivation and some urban and built-up areas.

7.3.1.5 Soweto Highveld Grasses

The Soweto Highveld Grassland (GM8) vegetation type is found in Mpumalanga, Gauteng and to a little extent also in neighbouring Free State and North-West Provinces. This vegetation type typically comprises of an undulating landscape on the Highveld plateau supporting short to medium-high, dense, tufted grassland dominated almost entirely by Themeda triandra and accompanied by a variety of other grasses such as

Elionurus muticus, Eragrostis racemosa, Heteropogon contortus and Tristachya leucothrix. Scattered small wetlands, narrow stream alluvia, pans and occasional ridges or rocky outcrops interrupt the continuous grassland cover (Mucina & Rutherford, 2006).

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. Some Soweto Grassland areas have been flooded by dams including Grootdraai, Leeukuil, Trichardtsfontein, Vaal and Willem Brummer.

7.3.1.6 Plant Species of Special Concern

Based on the Plants of Southern Africa (BODATSA-POSA, 2016) database, 572 plant species were previously recorded in the area (Figure 7-26). Of these, four species are listed as being SCC and is described in Table 7-4. They are all also protected on a provincial basis in Gauteng.

Figure 7-24: Map showing the grid drawn to compile an expected species list (BODATSA-POSA, 2016).

Table 7-4: Plant Species of Conservation Concern (SCC) expected to occur in the project area (BODATSA- POSA, 2016)

FAMILY TAXON IUCN Crassulaceae Adromischus umbraticola subsp. umbraticola Bont Plakkie Aizoaceae Delosperma leendertziae Leendertz yellow vygie Aizoaceae Khadia beswickii Khadiwortel Aizoaceae Lithops lesliei subsp. lesliei Transvaal Stone Plant

7.3.1.7 Hydrophytes: Wetland Habitats

Vegetation plays a considerable role in identifying, classifying and accurately delineating wetlands, (DWAF, 2005). During the site visit, three dominant hydrophytic species were identified, including Juncus spp., Schoenoplectus spp., Kylinga spp., Paspalum spp., Verbena spp., Phragmites australis and Imperata cylindrica (Figure 7-25).

Figure 7-25: Hydrophytic plants identified within the delineated wetlands. A: Phragmites australis. B: Schoenoplectus spp. C: Kylinga erecta. D: Juncus kraussii. E: Paspalum dilatatum. F: Verbena spp. G: Juncus rigidus. H: Agrostis lachnantha.

7.3.1.8 The Vegetation Assessment

The vegetation assessment was conducted throughout the extent of the project area. A total of 94 tree, shrub and herbaceous plant species were recorded (please see Table 12 of the Biodiversity Impact Report).

One provincially protected plant was recorded, namely Hypoxis hemerocallidea and mainly occurred within the wetland areas. According to GDARD this plant species is protected in the Gauteng Province due to rapid declines in localised population numbers associated with heavy harvesting for the medicinal plant trade. One endemic species Hermannia transvaalensis was observed, this species is found only in the Free State, Gauteng, KwaZulu-Natal and Mpumalanga provinces of South Africa.

Figure 7-26: Plant species recorded during the survey: A) Walafrida densiflora, B) Pelargonium luridum, C) Monopsis decipiens, D) Hypoxis rigidula, E) Hypoxis iridifolia and F) Hibiscus aethiopicus.

7.3.1.9 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 National Environmental Management: Biodiversity Act (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 National Environmental Management: Biodiversity Act (Act 10 of 2004) (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 National Water Act, 1998 (Act No. 36 of 1998), 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.

Seventeen Category 1b invasive species were recorded within the project area and must therefore be removed by implementing an alien invasive plant management programme in compliance of section 75 of the Act as stated above.

Figure 7-27: Some invasive plant species recorded in the project area: A) Hibiscus trionum, B) Verbena bonariensis, C) Eucalyptus sp., and D) Campuloclinium macrocephalum.

Fauna

7.3.1.10 Avifauna

Based on the South African Bird Atlas Project, Version 2 (SABAP2) database, 325 bird species are known to occur in the vicinity of the project area (pentads 2610_2820; 2610_2825; 2610_2830; 265_2820; 2615_2825; 2615_2830; 2620_2820; 2620_2825; 2620_2830). The full list of regionally occurring bird species is provided in Appendix B of the Biodiversity Impact Assessment (Appendix D1 of this EIA).

7.3.1.10.1 Important Bird Areas:

Important Bird & 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; 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.

The project area overlaps with portions of the Blesbokspruit IBA. The Blesbokspruit IBA system supports a diversity of waterbird species, including Goliath Heron (Ardea goliath), Purple Heron (A. purpurea), African Spoonbill (Platalea alba), Glossy Ibis (Plegadis falcinellus), Pied Avocet (Recurvirostra avosetta), Red-knobbed Coot (Fulica cristata) and White-winged Tern (Chlidonias leucopterus). African Marsh Harrier (Circus ranivorus), which has been displaced from much of the surrounding veld as a result of intense industrialisation, urbanisation and habitat modification, is a breeding resident. African Grass Owl (Tyto capensis) is now rarely recorded along the Blesbokspruit, its local population decline being attributed to a reduction in its preferred rank grassland habitat adjacent to the wetland.

7.3.1.10.2 Avifaunal Assessment:

Bird species observed in the last year (2019) in Marievale identified 224 bird species, of which 121 bred in the reserve. This list of bird species is provided in Appendix C of the Biodiversity Impact Assessment (Appendix D1 of this EIA). Of the regionally occurring bird species, twenty-seven (27) species are listed as SCC (Table 7-5). The SCC includes the following: The bird species protected under provincial legislation is indicated by *

❖ Four species that are listed as EN on a regional basis; ❖ Seven species that are listed as VU on a regional basis; and ❖ Twelve species that are listed as NT on a regional basis

The likelihood of occurrence is based on literature describing their habitat preferences and the level of adaptability to disturbed areas (Birdlife SA, 2019; IUCN, 2019; Sinclair et al., 2010; Hockey et al., 2005; Del Hoyo et al., 1996). This was then adjusted after the field assessment was completed, based on the availability of suitable habitat for the respective species. Owing to the proximity of the project area to large wetlands and the Marievale bird sanctuary, the majority of the birds have a high or moderate likelihood of occurrence.

Table 7-5: List of bird species of regional or global conservation importance that are expected to occur in pentads 2610_2820; 2610_2825; 2610_2830; 265_2820; 2615_2825; 2615_2830; 2620_2820; 2620_2825; 2620_2830.

CONSERVATION STATUS DESKTOP LIKELIHOOD SPECIES COMMON NAME Regional (SANBI, 2016) IUCN (2017) OF OCCURRENCE Alcedo semitorquata* Kingfisher, Half-collared NT LC High Anthropoides paradiseus* Crane, Blue NT VU Low Aquila verreauxii Eagle, Verreaux's VU LC Low Calidris ferruginea Sandpiper, Curlew LC NT High Ciconia abdimii Stork, Abdim's NT LC Moderate Ciconia nigra Stork, Black VU LC Moderate Circus macrourus Harrier, Pallid NT NT Moderate Circus ranivorus* Marsh-harrier, African EN LC High Coracias garrulus Roller, European NT LC Moderate Egretta vinaceigula Egret, Slaty LC VU Moderate Eupodotis caerulescens* Korhaan, Blue LC NT High Falco biarmicus* Falcon, Lanner VU LC High Falco vespertinus Falcon, Red-footed NT NT High Glareola nordmanni Pratincole, Black-winged NT NT High Limosa lapponica Godwit, Bar-tailed LC NT Moderate Limosa limosa Godwit, Black-tailed NT NT Moderate Mycteria ibis Stork, Yellow-billed EN LC High Nettapus auritus Goose, African Pygmy VU LC High Oxyura maccoa Duck, Maccoa NT NT High Phalacrocorax capensis Cormorant, Cape EN EN Moderate Phoenicopterus minor* Flamingo, Lesser NT NT High Phoenicopterus ruber* Flamingo, Greater NT LC High Polemaetus bellicosus Eagle, Martial EN VU High Rostratula benghalensis* Painted-snipe, Greater NT LC High Sagittarius serpentarius* Secretarybird VU VU High Sterna caspia Tern, Caspian VU LC High Tyto capensis* Grass-owl, African VU LC High

Phalacrocorax capensis (Cape Cormorant) is endemic to the southwestern coast of Africa, but during the non- breeding season, they spread inland and up the east coast of South Africa. The IUCN, as well as Birdlife South Africa, lists these birds as Endangered, and the main cause of the decline is as a result of the decline of the epipelagic fish stock, oil spills and avian cholera. The species is more confined to the coast of SA, they can likely occur in the project area, but the chance is moderate.

Polemaetus bellicosus (Martial Eagle) is listed as EN on a regional scale and VU on a global scale. This species has an extensive range across much of sub-Saharan Africa, but populations are declining due to deliberate and incidental poisoning, habitat loss, reduction in available prey, pollution and collisions with power lines (IUCN, 2017). It inhabits open woodland, wooded savanna, bushy grassland, thorn-bush and, in southern Africa, more open country and even sub-desert (IUCN, 2017). Large numbers of suitable prey species (mammals, birds and reptiles) occur in the project area; therefore, the likelihood of occurrence is rated as high.

Sagittarius serpentarius (Secretarybird) occurs in sub-Saharan Africa and inhabits grasslands, open plains, and lightly wooded savanna. It is also found in agricultural areas and sub-desert (IUCN, 2017). Grasslands and agricultural habitat occur in the project area that are suitable for this species, as such the likelihood of occurrence was rated as high.

During the survey, 95 bird species were recorded. Two of the species recorded were SCCs. The provincially protected species is indicated with an asterisk (*). The diversity of birds was high with a large number of the species being made up of water birds.

Table 7-6: A list of the avifauna species recorded in the project area

SPECIES COMMON NAME CONSERVATION STATUS REGIONAL (SANBI, 2016) IUCN (2017) Phoenicopterus ruber Flamingo, Greater * NT LC Mycteria ibis Stork, Yellow-billed EN LC Phalacrocorax carbo Cormorant, White-breasted LC LC

Figure 7-28: Avifaunal species recorded during the survey: A) Pied kingfisher (B) Southern Red Bishop (C) Cape Longclaw, D) Grater flamingo, E), Red-billed teal , F) White throated sparrows, G) White-faced ducks, H) Yellow-billed ducks, I) Reed Cormorant and J) Red-knobbed Coot.

7.3.1.11 Mammals

The IUCN Red List Spatial Data (IUCN, 2017) lists 88 mammal species likely to occur within the project area (Appendix D of the Biodiversity Impact Assessment (Appendix D1 of this EIA)).

Of these species, 9 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. These species are not expected to occur in the project area and are removed from the expected SCC list. They are however still included (highlighted in red) in Appendix D of the Biodiversity Impact Assessment (Appendix D1 of this EIA).

Of the remaining 79 small to medium sized mammal species, fifteen (14) (17.7%) are listed as being of conservation concern on a regional or global -scale (Table 7-7).

❖ Two that are listed as EN on a regional scale; ❖ Five that are listed as VU on a regional scale; ❖ Eight that are listed as NT on a regional scale (Table 7-7); and ❖ On a global scale, 1 species is listed as EN, 2 are listed as VU and 4 as NT.

A full description of each specie is given in the Biodiversity Impact Assessment (Appendix D1) of this EIA.

Table 7-7: List of mammal species of conservation concern that may occur in the greater project area as well as their global and regional conservation statuses (IUCN, 2017; SANBI, 2016)

CONSERVATION STATUS DESKTOP Regional SPECIES COMMON NAME LIKELIHOOD OF IUCN (2017) OCCURRENCE (SANBI, 2016) Aonyx capensis Cape Clawless Otter NT NT High Atelerix frontalis South Africa Hedgehog* NT LC High Crocidura maquassiensis Makwassie musk shrew VU LC Moderate Dasymys incomtus African Marsh rat NT LC High Eidolon helvum African Straw-colored Fruit Bat LC NT Low Felis nigripes Black-footed Cat VU VU Low Hydrictis maculicollis Spotted-necked Otter VU NT High Leptailurus serval Serval NT LC High Mystromys albicaudatus White-tailed Rat VU EN High Ourebia ourebi Oribi EN LC Low Panthera pardus Leopard VU VU Low Parahyaena brunnea Brown Hyaena NT NT Low Pelea capreolus Grey Rhebok NT LC Moderate Poecilogale albinucha African Striped Weasel NT LC High Redunca fulvorufula Mountain Reedbuck EN LC Unlikely Rhinolophus blasii Blasius's horseshoe bat * NT LC Moderate

Hydrictis maculicollis (Spotted-necked Otter) inhabits freshwater habitats where water is un-silted, unpolluted, and rich in small to medium sized fishes (IUCN, 2017). This species has a high likelihood of occurrence as they are known species of the Marievale bird sanctuary wetlands.

Mystromys albicaudatus (White-tailed Rat) is listed as VU on a regional basis and EN on a global scale. It is relatively widespread across South Africa and Lesotho; the species is known to occur in shrubland and grassland areas. A major requirement of the species is black loam soils with good vegetation cover. This species has a high likelihood of occurrence based on the suitable habitat found in the project area.

Three mammal species were observed in the project area. These were the Water Mongoose (Atilax paludinosus), House Rat (Rattus rattus) and the Common Duiker (Sylvicapra grimmia).

7.3.1.12 Herpetofauna (Reptiles & Amphibians)

Based on the IUCN Red List Spatial Data (IUCN, 2017) and the ReptileMap database provided by the Animal Demography Unit (ADU, 2017) 52 reptile species are expected to occur in the project area (Appendix E of the Biodiversity Impact Assessment (Appendix D1 of this EIA)). Two SCC should be present according to the above- mentioned sources within the project area. The provincially protected species is indicated by an asterisk (*).

Based on the IUCN Red List Spatial Data (IUCN, 2017) and the AmphibianMap database provided by the Animal Demography Unit (ADU, 2019) 19 amphibian species are expected to occur in the project area (Appendix E of the Biodiversity Impact Assessment (Appendix D1 of this EIA)). One (1) amphibian SCC could be present in the project area according to the above-mentioned sources.

Table 7-8: List of amphibian species of conservation concern that may occur in the project area as well as their global and regional conservation statuses (IUCN, 2017; SANBI, 2016).

LIKELIHOOD CONSERVATION STATUS SPECIES COMMON NAME OF Regional (SANBI, 2016) IUCN (2017) OCCURRENCE Reptiles Crocodylus niloticus Nile Crocodile VU VU Unlikely Homoroselaps dorsalis* Striped Harlequin Snake NT LC High Amphibians High / Pyxicephalus adspersus Giant Bullfrog NT LC Observed

Homoroselaps dorsalis (Striped Harlequin Snake) 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 low due to the lack of termitaria in the area.

The Giant Bull Frog (Pyxicephalus adspersus) is a species of conservation concern that may potentially occur in the project area. The Giant Bull Frog is listed as NT 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). This species is known to occur in this area based on literature and were observed in the project area during the field survey.

Figure 7-29: Some of the amphibians recorded in the project area: A) Common sand frog (Tomopterna cryptotis) and B) Giant Bullfrog (Pyxicephalus adspersus) froglet

No reptile species were recorded in the project area, however, four amphibians species were recorded. Numerous Giant bullfrog tadpoles were recorded in the project area, high numbers were found in the vicinity of the Marievale military base, special care will need to be taken in this area when constructing the pipeline.

CONSERVATION STATUS SPECIES COMMON NAME Regional (SANBI, 2016) IUCN (2017) Pyxicephalus adspersus Giant Bullfrog NT LC Sclerophrys gutturalis Guttural Toad LC LC Tomopterna cryptotis Common Sand Frog LC LC Xenopus laevis Common Platanna LC LC

It must be noted that where species ‘Likelihood of occurrence’ has been indicated as “low” or “Unlikely” – it is probable that these species will never occur in the project area due to the transformed and altered habitat associated with the proposed project. Results were obtained from regional databases on a desktop level and may not be a true reflection of what is occurring on site.

7.4 Wetlands

Refer to Specialist Study: Appendix D1 – Biodiversity Impact Assessment and Wetland Assessment

Wetland Classification

The wetland areas were delineated in accordance with the DWAF (2005) guidelines (see Figure 7-30). Sixteen (16) different Hydrogeomorphic (HGM) units were identified, which include hillslope seeps, depressions,

channelled valley bottom wetlands and unchanneled valley bottom wetlands. In addition to the 16 HGM units, one artificial wetland system was identified, which has been deemed to have formed as a result of seepage from the waste impoundments. It, therefore, is the specialist’s opinion that this wetland will be lost once the relevant impoundment has been reclaimed/decommissioned.

Figure 7-30: Delineation of wetlands and within the 500 m regulated area

The wetland classification as per SANBI guidelines (Ollis et al. 2013) is presented in Table 7-9. Four wetland types were identified within the project assessment boundary, namely depressions, hillslope seeps, channelled valley bottoms and unchanneled valley bottoms.

Table 7-9 Wetland classification as per SANBI guideline (Ollis et al. 2013)

WETLAND LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 SYSTEM SYSTEM DWS NFEPA WET LANDSCAPE 4A (HGM) 4B 4C ECOREGION/S VEG UNIT GROUP* HGM 1, 2, Inland Without Mesic 3, 4, 6, 7 & Highveld Hillslope Hillslope Seep Channelled N/A Highveld 14 Outflow

WETLAND LEVEL 1 LEVEL 2 LEVEL 3 LEVEL 4 SYSTEM SYSTEM DWS NFEPA WET LANDSCAPE 4A (HGM) 4B 4C ECOREGION/S VEG UNIT GROUP* Grassland Group 2 Inland Highveld Mesic Without HGM 13 & Highveld Hillslope Hillslope Seep Channelled N/A 5 Grassland Outflow Group 3 Inland Highveld Mesic Without HGM 8, 9, Highveld Valley Depression Endorheic Channelled & 11 Grassland Outflow Group 2 Inland Highveld Mesic Without Highveld HGM 10 Valley Depression Dammed Channelled Grassland Outflow Group 2 Inland Highveld Mesic Highveld Channelled HGM 12 Valley N/A N/A Grassland Valley Bottom Group 3 Inland Highveld Mesic HGM 15 Highveld Unchanneled Valley N/A N/A and 16 Grassland Valley Bottom Group 2

Functional Description of the HGM Units

Hillslope seeps are well documented by (Kotze et al., 2009) to be associated with sub-surface ground water flows. These systems tend to contribute to flood attenuation given their diffuse nature. This attenuation only occurs while the soil within the wetland is not yet fully saturated. The accumulation of organic material and sediment contributes to prolonged levels of saturation due to this deposition slowing down the sub-surface movement of water. Water typically accumulates in the upper slope (above the seep). The accumulation of organic matter additionally is essential in the denitrification process involved with nitrate assimilation. Seeps generally also improve the quality of water by removing excess nutrient and inorganic pollutants originating from agriculture, industrial or mine activities. The diffuse nature of flows ensures the assimilation of nitrates, toxicants and phosphates with erosion control being one of the Eco Services provided very little by the wetland given the nature of a typical seep’s position on slopes.

Channelled valley bottom wetlands tend to contribute less to sediment trapping and flood attenuation than other systems. Channelled valley bottom wetlands are well known to improve the assimilation of toxicants, nitrates and sulphates, especially in cases where sub-surface flows contribute to the system’s water source (Kotze et al., 2009).

The generally impermeable nature of depressions and their inward draining features are the main reasons why the streamflow regulation ability of these systems is mediocre. Regardless of the nature of depressions in regard to trapping all sediments entering the system, sediment trapping is another Eco Service that is not deemed as one of the essential services provided by depressions, even though some systems might contribute to a lesser extent. The reason for this phenomenon is due to winds picking up sediments within pans during dry seasons which ultimately leads to the removal of these sediments and the deposition thereof elsewhere. The assimilation of nitrates, toxicants and sulphates are some of the higher rated Eco Services for depressions. This latter statement can be explained the precipitation as well as continues precipitation and dissolving of minerals and other contaminants during dry and wet seasons respectively, (Kotze et al., 2009).

Unchanneled valley-bottoms are characterised by sediment deposition, a gentle gradient with streamflow generally being spread diffusely across the wetland, ultimately ensuring prolonged saturation levels and high levels of organic matter. The assimilation of toxicants, nitrates and phosphates are usually high for unchanneled valley-bottom wetlands, especially in cases where the valley is fed by sub-surface interflow from slopes. The shallow depths of surface water within this system adds to the degradation of toxic contaminants by means of sunlight penetration.

It is, however, important to note that the descriptions of the above-mentioned functions are merely typical expectations. All wetland systems are unique and therefore, the ecosystem services rated high for these systems on site might differ slightly to those expectations.

Wetland Ecological Functional Assessment

The ecosystem services provided by the wetlands identified on site was assessed and rated using the WET- EcoServices method (Kotze et al. 2008).

The majority of HGM units are characterised by an “Intermediate” (C) average ecosystem service score (12 of the 16) with four HGM units being classified as having a “Moderately Low” (D) average ecosystem service score. The most significant of all 16 HGM units in regard to ecosystem services, is that of HGM 15, which has been classified as having a “High” average ecosystem service score.

This score is attributed to the Ramsar status of the wetland and the presence of various red data species. This wetland also is characterised by high concentrations of organic material within the soil and a dense vegetation growth, which aids in the assimilation of toxicants and the attenuation of flows (Table 7-10).

Table 7-10: The ecosystem services being provided by the identified HGM unit 1 – 16.

HGM UNIT 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Average Ecosystem C C C C C C C C D D C C C C B D Service Score

The Wetland Health Assessment

The hydrology aspect of the delineated HGM units differ from “Moderately Modified” to “Seriously Modified” depending on the severity of anthropogenic aspects affecting the hydrology of the wetlands (see Table 7-11)

Typical aspects considered for the justification of scores include the presence of crop fields, artificial and hardened surfaces that decrease infiltration and promote overland flow and the extent of alien invasives.

The geomorphology of the delineated wetlands differs from “Largely Natural” to “Seriously Modified” due to various anthropogenic modifications. These modifications include roads and bridges intersecting and affecting flows, significant deposition (waste impoundments), dams upstream of wetlands and evidence of erosion, sedimentation as well as the formation of gullies.

The vegetation component differs from “Largely Modified” to “Critically Modified” due to the removal of indigenous vegetation to make way for infrastructure, crop fields, mining etc. The vegetation component, as well as the geomorphological and hydrological components, have all contributed to the “Largely Modified” and “Seriously Modified” overall PES scores calculated for the 16 HGM units.

Figure 7-31: Some of the impacts observed. A) Building rubble, B & F) Litter, C) Cattle, D & E) Existing mining infrastructure and pipelines, G) Roads, E) Agriculture and F) Erosion.

Table 7-11: Summary of the scores for the Wetland PES

HGM UNIT HYDROLOGY GEOMORPHOLOGY VEGETATION OVERALL PES Score Rating Score Rating Score Rating Score Rating Moderately modified Critically Modified Largely Modified HGM 1 Seriously Modified (E) 6.0 2.6 8.2 5.7 (C) (F) (D) Seriously Modified Largely Modified HGM 2 Largely Modified (D) 4.0 Largely Natural (B) 1.8 7.8 4.5 (E) (D) Moderately modified Seriously Modified Largely Modified HGM 3 Largely Modified (D) 5.5 2.2 7.9 5.2 (C) (E) (D) Moderately Modified Seriously Modified Largely Modified HGM 4 3.7 Largely Natural (B) 1.8 7.9 4.4 (C) (E) (D) Seriously Modified Largely Modified HGM 5 Largely Modified (D) 5.8 Largely Modified (D) 4.6 7.2 5.9 (E) (D) Seriously Modified Seriously HGM 6 Largely Modified (D) 5.4 Largely Modified (D) 5.8 7.9 6.2 (E) Modified (E) Critically Modified Seriously HGM 7 Seriously Modified (E) 6.2 Largely Modified (D) 5.5 8.0 6.5 (F) Modified (E) Moderately Modified Critically Modified Largely Modified HGM 8 3.5 Largely Natural (B) 1.2 8.1 4.2 (C) (F) (D) Critically Modified Largely Modified HGM 9 Largely Modified (D) 5.2 Largely Modified (D) 4.6 8.2 5.9 (F) (D) Critically Modified Seriously HGM 10 Largely Modified (D) 5.8 Seriously Modified (E) 6.2 8.1 6.6 (F) Modified (E) Moderately Modified Seriously Modified Largely Modified HGM 11 3.8 Largely Modified (D) 4.3 7.9 5.1 (C) (E) (D) Critically Modified Seriously HGM 12 Seriously Modified (E) 6.4 Largely Modified (D) 5.3 8.2 6.6 (F) Modified (E) Critically Modified Seriously HGM 13 Seriously Modified (E) 6.6 Largely Modified (D) 5.9 8.3 6.9 (F) Modified (E)

HGM UNIT HYDROLOGY GEOMORPHOLOGY VEGETATION OVERALL PES Score Rating Score Rating Score Rating Score Rating Moderately Modified Largely Modified HGM 14 Largely Modified (D) 4.0 3.0 Largely Modified (D) 5.5 4.1 (C) (D) Moderately Modified Seriously Modified Largely Modified HGM 15 Seriously Modified (E) 6.5 3.1 6.6 5.5 (C) (E) (D) Seriously Modified Seriously HGM 16 Seriously Modified (E) 7.1 Seriously Modified (E) 7.3 7.2 7.2 (E) Modified (E)

The Ecological Importance and Sensitivity Assessment

The results of the assessment are shown in Table 7-12. The direct human benefits differ from “High” (B) to “Low” (D). The only HGM unit scored “High” is HGM 15, which has been scored high due to the fact that this wetland system (Blesbokspruit system) provides various recreational (especially birding) and educational opportunities. As for the hydrological functional importance, the HGM units delineated within the 500 m regulated area has been scored “High” (B) to “Low” (D). Five wetlands have been scored “High” scores given their abilities to assimilate contaminants (which is vital in areas surrounded by housing developments and tailing facilities) and attenuate floods. As for the Ecological Importance and Sensitivity (EIS), various factors contribute to the scores calculated for the identified wetlands. These scores include the protective status of wetlands, the presence of red data species, the potential habitat for red data species, the sensitivity of wetlands to dry periods etc.

As in the case with direct human benefits and hydrological/functional importance, the Blesbokspruit wetland system directly to the east of the proposed wetlands have been scored an exceptionally high score, due to the provision of habitat to red data species, the sensitivity of unchanneled valley bottoms to dry periods in general and the Ramsar and Important Birding Area (IBA) status of this wetland.

Table 7-12: The Ecological Importance and Sensitivity results.

HGM UNIT 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16

Ecological Importance & C C C C C C C B C D C C C C A D Sensitivity Hydrological/Functional C B B B C C C C D D C B C C B D Importance Direct Human Benefits C C C C C D D C D D C C C D B D

Buffer Requirements

According to Graham & de Winnaar (2009), the buffer size recommended for mining related waste impoundments is 110 m. This conservative buffer zone has been chosen for the reclamation of the relevant waste impoundments with the “Preliminary Guideline for the Determination of Buffer Zones for Rivers, Wetlands and Estuaries” (Macfarlane et al., 2014) being used to determine the appropriate buffer zone for the proposed pipelines (which has been calculated at 15 m). It is worth noting that the recommended buffer zones were assigned to the proposed pipelines and relevant tailings facilities rather than the wetlands, due to the difference in buffer sizes (110 m for tailings facilities and 15 m for pipelines). Wetlands located within these buffer zones will be affected directly by the proposed activities.

Figure 7-32: Buffer zones assigned to proposed components (tailings facilities and pipelines)

7.5 Biodiversity and Wetlands Sensitivity Assessment

As per the terms of reference for the project, GIS sensitivity maps are required to identify sensitive features in terms of the relevant specialist discipline/s within the project area. The sensitivity identified during the field survey for each terrestrial habitat and wetland is mapped in Figure 7-33 to Figure 7-35 respectively. These sensitivity maps were made by combining the terrestrial sensitivities with the wetland sensitivities. The locations of the SCCs record in the project are shown in Figure 7-36.

In terms of terrestrial habitats, areas that were classified as having a low sensitivity are those areas which were deemed by the specialists to have been most impacted upon and/or were transform from their original condition due to factors such as previous and current human activity and/or presence of alien invasive species. A low-moderate sensitivity was given to the degraded grassland habitats. These habitats function as an ecosystem, habitat and/or important corridors for various species within the transformed areas in the project area and the immediate local area. The high sensitivity areas are the secondary grassland and wetland areas that are still viable and vital habitat for fauna and flora as well as the wetland function in the water resource scheme.

The 200 metre buffer has been assigned to wetlands of importance for the various SCC present and has been given a moderate-high sensitivity.

Figure 7-33: Habitat sensitivity within Marievale project area.

Figure 7-34: Habitat sensitivity within the project area.

Figure 7-35: Habitat sensitivity within the adjusted project area footprint

Figure 7-36: Location of the SCCs in the project area

Regional Catchments and Drainage

The impacts identified during the wetland and terrestrial surveys that are currently having a negative ecological impact in the project area were identified, are listed below and can be seen in Figure 7-37. Impacts in the project area include:

❖ Presence of alien and invasive plant species which have altered natural vegetation communities; ❖ Human encroachment leading to the degradation of the environment; ❖ Dumping of builder’s rubble and general waste; ❖ Urban infrastructure, resulting in the removal of natural vegetation; ❖ Unregulated burning leading to loss of habitat and increased air pollution; ❖ Fencing that is responsible for separating the various habitats; ❖ Habitat fragmentation and degradation; specifically of the CBA, ESA, CR and EN ecosystems as well as a portion of a protected and Ramsar area; ❖ Agriculture and livestock; ❖ Existing mining infrastructure and pipelines; ❖ Erosion; and ❖ Telephone lines and power lines within the vicinity of the project area that could lead to bird strikes and electrocutions.

Figure 7-37: Some of the impacts observed: A) Building rubble, B & F) Litter, C) Cattle, D & E) Existing mining infrastructure and pipelines, G) Roads, E) Agriculture and F) Erosion

7.6 Surface Water

Refer to Appendix D2 of the EIA for the Surface Water Impact Assessment

Regional Catchments and Drainage

The DHSWS has divided South Africa into primary, secondary, tertiary and quaternary catchments. Primary catchments are the largest defined catchments for South Africa, of which there are 22, and are assigned a letter ranging from A – X (excluding O). Secondary catchments are subdivisions of the primary catchments and are the second largest catchments in South Africa, and are assigned the primary catchment letter within which they are located and a number e.g. A5 (secondary catchment 5 located within primary catchment A). Similarly, tertiary catchments are subdivisions of secondary catchments, and are represented for example by A53 (tertiary catchment 3 located within secondary catchment A5). Lastly, quaternary catchments are the smallest defined catchments and are assigned the tertiary catchment number, along with a quaternary catchment letter e.g. A53D (quaternary catchment D located within tertiary catchment A53).

Further to the above, the DHSWS has divided South Africa into 9 Water Management Areas (WMAs), that is, the Limpopo, Olifants, Inkomati-Usuthu, Pongola-Mtamvuna, Vaal, Orange, Mzimvubu-Tsitsikamma, Breede- Gouritz and Berg-Olifants WMAs.

The project is in the Vaal WMA, within quaternary catchment C21E in the Suikerbosrant River Catchment. The project is drained in an easterly direction towards the Blesbokspruit. A non-perennial stream drains the Vogelspruisbult Dam, flowing between the Marievale TSFs and into the Blesbokspruit. The Blesbokspruit flows in a southerly direction, and consists of a wide floodplain area, reaching a width of approximately 1 km wide, directly south of the Marievale TSFs. The Blesbokspruit flows into the Suikerbosrant River, 35 km south-west of the project. The Suikerbosrant flows into the Vaal Barrage near the town of Vereeniging.

Surface Water Quality

Ergo has been monitoring the surface water quality of the Blesbokspruit upstream and downstream of the Marievale TSFs since November 2017. The monitoring locations are summarised in Table 7-13 and are indicated on Figure 7-38.

Table 7-13: Summary of Ergo’s surface water quality monitoring locations on the Blesbokspruit.

MONITORING POINT NO. OF OCCASIONS LOCATION FROM LATITUDE* LONGITUDE* MONITORED PROJECT AREA DT2 7 Upstream of TSFs -26.266733° 28.50327° DT5 7 Downstream of TSFs -26.357317° 28.5137°

The surface water quality results are indicated in Table 7-14. Only results where the limit has been reached, or where there are exceedances have been shown. Refer to Table 3-4 of the Surface Water impact report for a detailed breakdown of all results.

The water quality results are compared to the Blesbokspruit catchment guideline limits and the South African National Standard (SANS) 241:2015 Drinking Water Quality limits. The Blesbokspruit catchment guideline limits are specified as follows –

❖ 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.

The water quality results are summarised below:

❖ pH was within limits at all sampling locations along the Blesbokspruit, with an average pH of approximately 7.7. ❖ Electrical Conductivity (EC), which provides an indication of the dissolved salts within water, exceeded unacceptable limits on a regular basis. What is interesting to note, is that EC levels were within limits over the period of March 2011 to September 2016, however, since then, EC levels have been regularly elevated within the Blesbokspruit. This coincides with the commissioning of the upstream TCTA WTP in August 2016, which according to a DHSWS directive, is allowed to discharge water quality with an EC of 450 mS/m, with a 7 month average of 261 mS/m;

❖ Sulphate follows a similar trend to EC, with levels rising sharply since September 2016 in the Blesbokspruit. As in the above, this can be attributed to discharges from the TCTA WTP, as sulphate levels of 3 000 mg/l, with a 7 month average of 1 377 mg/l, can be discharged into the Blesbokspruit. ❖ In terms of heavy metals, elevated levels of antimony, cadmium, chromium, lead, manganese, nickel and selenium have been recorded in the Blesbokpruit. The Blesbokspruit generally had heavy metal concentrations within limits barring on a few occasions; ❖ Uranium has been within limits within the Blesbokspruit except during September 2004 at JV04/052; ❖ Fluoride levels within the Blesbokspruit have substantially increased since September 2018. It is unknown to what the cause of the sharp increase can be attributed; ❖ Phosphate is regularly elevated above unacceptable limits within the Blesbospruit. However, since September 2016, sharp increases in phosphate appear to have reduced, which may be as a result of dilution provided by the TCTA WTP; and ❖ Wetland sediment samples from the Blesbokspruit indicated that metal concentrations were within the specified general guideline limits.

It can be concluded that the Blesbokspruit has an alkaline pH of approximately 7.7, with regular elevated levels of EC, sulphate and phosphate. More recently, a substantial increase in fluoride has occurred. Elevated heavy metals also occur in the Blesbokspruit, but on a less frequent basis. It is expected that the top 3 m of the Marievale TSFs will have low element concentrations, as leaching from rainfall would have most probably flushed out the minerals (Groundwater Abstract, 2020). However, deeper into the TSF, the pH is expected to be much lower and element concentrations higher, but due to stable conditions that include low permeability and low oxygen levels, metal and salt leaching does not happen readily (Irene Lea, 2016). This could potentially change when the reclamation process introduces oxygen and high volumes of water.

The water quality of the Blesbokspruit is impacted on by agricultural and urban runoff, discharges from the TCTA WTP, WWTWs and industrial sites, as well as seepage and runoff from mining areas.

Surface Water Runoff

According to the WR2012 study, the simulated Mean Annual Runoff (MAR) at the outlet of quaternary catchment C21E, between October 2004 and September 2010, was 132.4 million cubic metres (mcm). The naturalised MAR, which is the simulated runoff after all man-made land use activities are removed from the catchment is 74.04 mcm. This indicates that the Blesbokspruit received on average 58.36 mcm per annum more than it should have under natural (virgin) catchment conditions. The Blesbokspruit upstream the Marivale TSFs is known to be receiving large volumes of water from the TCTA Water Treatment Plant (WTP) (approximately 94 million litres per day), Sewage Treatment Plants (STPs), mining areas and industrial sites.

Figure 7-38: Ergo surface water quality monitoring locations

Table 7-14: Surface water quality results for the Marievale Project where limits are tolerable or exceeded.

SANS 241:2015 BLESBOKSPRUIT CATCHMENT DRINKING NOV 2017 JAN 2018 SEP 2018 OCT 2018 JAN 2019 MAY 2019 JUL 2019 GUIDELINE LIMITS QUALITY LIMITS PARAM UNI UN ETER TS ACCE TOLER ACCE IDEAL PTAB RISK LIMIT DT2 DT5 DT2 DT5 DT2 DT5 DT2 DT5 DT2 DT5 DT2 DT5 DT2 DT5 ABLE PTAB LE LE pH - pH 6.5 - < 6.5; Operati ≥ 5 to Value @ unit 7.5 8 7.4 7.6 7.7 7.9 7.4 7.7 7.8 7.8 7.4 7.6 7.4 8.2 8.5 >8.5 onal ≤ 9.7 25 ºC s Electrica l mS/ 45- 70 - Aesthe Conduct <45 > 120 ≤ 170 152 161 132 124 157 155 173 166 92.9 164 123 116 135 133 m 70 120 tic ivity @ 25°C Total Dissolve mg/ Aesthe ≤ 1 112 123 117 127 131 112 ------1188 1248 974 1356 584 902 812 940 d Solids ℓ tic 200 8 0 8 6 0 0 @ 180°C Sulphat mg/ 150 - 300 - Acute < 150 > 500 ≤ 500 598 600 505 382 575 565 635 632 103 487 462 274 640 497 e as SO4 ℓ 300 500 health Sodium mg/ 70 - 100 - Aesthe < 70 > 150 ≤ 200 116 128 95 94 119 118 134 113 94 150 90 91 117 100 as Na ℓ 100 150 tic Magnesi mg/ 8.00 - um as < 8 30-70 > 70 ------44 51 41 36 42 45 41 43 19 46 33 30 39 34 ℓ 30.00 Mg

SANS 241:2015 BLESBOKSPRUIT CATCHMENT DRINKING NOV 2017 JAN 2018 SEP 2018 OCT 2018 JAN 2019 MAY 2019 JUL 2019 GUIDELINE LIMITS QUALITY LIMITS PARAM UNI UN ETER TS ACCE TOLER ACCE IDEAL PTAB RISK LIMIT DT2 DT5 DT2 DT5 DT2 DT5 DT2 DT5 DT2 DT5 DT2 DT5 DT2 DT5 ABLE PTAB LE LE Antimo ny as Sb mg/ Chronic <0. <0. 0.0 0.0 <0. <0.00 <0.0 0.0 <0. 0.0 <0.0 ------≤ 0.02 0.184 0.124 0.001 (Dissolv ℓ health 020 020 01 01 001 1 01 01 001 02 01 ed) Cadmiu m as Cd mg/ Chronic ≤ <0.00 <0.00 <0. <0. <0. <0. <0.00 <0. <0.00 <0.0 <0. <0. 0.0 <0.0 ------(Dissolv ℓ health 0.003 3 3 003 003 003 003 3 003 3 03 003 003 07 03 ed) Total Chromiu mg/ Chronic <0. <0. <0. <0. <0.02 <0. <0.02 <0.0 <0. <0. 0.1 <0.0 m as Cr ------≤ 0.05 0.04 0.032 ℓ health 025 025 025 025 5 025 5 25 025 025 13 25 (Dissolv ed) Lead as Pb mg/ Chronic <0.01 <0. <0. <0. <0. <0.01 <0. <0.01 <0.0 <0. <0. 0.0 <0.0 ------≤ 0.01 0.012 (Dissolv ℓ health 0 010 010 010 010 0 010 0 10 010 010 88 10 ed) Mangan ese as mg/ 0.2 - 0.5 - Chronic <0.02 <0.02 <0. 0.0 0.0 0.1 <0.02 <0. 0.1 0.2 2.2 0.0 <0.0 Mn < 0.2 > 1.00 ≤ 0.4 1.43 ℓ 0.5 1.0 health 5 5 025 37 53 53 5 025 76 99 7 95 25 (Dissolv ed)

Peak Flows

The catchment parameters and calculated peak flows for the Blesbokspruit are summarised in Table 7-15. The SCS method peak flow was adopted for the floodline modelling.

Table 7-15: Catchment parameters and calculated 1:100 year peak flows

CATCHMENT CATCHMENT 1 CATCHMENT 2 CATCHMENT 3 CATCHMENT 4 Catchment Area (km²) 814.8 23.9 524.9 49.1 Longest Watercourse (km) 41.03 6.06 30.51 12.32 Average Longest Watercourse 0.0012 0.0035 0.0013 0.0046 Slope (m/m) Tc (hrs) 16.17 2.34 11.84 3.64 SDF Basin 7 N/A 7 N/A Rainfall Intensity (mm/hr) 7.381 40.071 10.193 25.762 Runoff Coefficient (C) 0.60 0.40 0.60 0.51 Peak Flow Method SDF Rational SDF Rational 1:100 Year Peak Flow (m3/s) 1002 107 892 178

Floodline Determination

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 greater.

7.6.1.1 Floodlines and 100 m Stream Buffer

The 1:100 year floodline is indicated on Figure 7-39. The floodline determination indicated the following:

❖ The proposed pipeline falls within the floodline where it crosses the wetland between the dumps, as well as at the Klein Blesbokpruit river crossing near the TCTA plant; and ❖ The toe of the eastern sides of Dumps 7L6 and 7L7 are at risk of flooding under a 1:100 year flood.

The following is recommended:

❖ Exemption from GN R704 is obtained for proposed infrastructure that falls within the floodlines or a 100 m horizontal distance from a watercourse (whichever is greatest). It should be noted that the dumps are historical and were created prior to GN R704; ❖ The proposed pipelines are elevated above the 1:100 year floodline with support structures capable of handling a 1:100 year flood; and ❖ A suitably designed flood protection berm is placed along the eastern toe of Dumps 7L6 and 7L7, at a height above the floodline.

Figure 7-39: 1:100 year floodline

Conceptual Stormwater Management Plan

The purpose of the conceptual SWMP is to ensure that clean and dirty water are adequately separated, by diverting clean water away from dirty areas, and ensuring that dirty water from the operation is captured, contained and managed appropriately in accordance with GN R704 Regulations and DHSWS best practice guidelines.

The following design philosophy was adopted to guide the development of the SWMP, and is based on GN R704 and the DWS Best Practice Guideline (BPG) G1: Storm Water Management:

❖ Confine or divert any unpolluted water to a clean water system, away from a dirty area; ❖ Runoff from dirty areas must be captured, contained and managed appropriately; ❖ Clean and dirty water systems must be designed and constructed to prevent cross contamination; ❖ Dirty water must, as far as possible, be recycled and reused or treated and discharged; ❖ Clean and dirty water systems must convey/contain runoff from the 50-year storm event, and should not lie within the 100-year floodline or within a horizontal distance of 100 m from any watercourse, whichever is the greater of the two; and ❖ Appropriate maintenance and management of stormwater related infrastructure should always be ensured.

The following are assumptions and limitations for the conceptual SWMP:

❖ The SWMP is based on the project description provided. Should the project description or infrastructure layout change, then the SWMP will need to be revised; and ❖ The SWMP is conceptual. A detailed SWMP should be designed based on the concept design prior to construction.

7.6.1.2 Clean and Dirty areas

Dirty areas include the following areas:

❖ TSF footprint area; ❖ Reclamation pump station; and ❖ Coarse material stockpile.

Clean areas include all areas surrounding the above-mentioned dirty areas.

7.6.1.3 Proposed stormwater measures

The proposed SWMP for Dumps 7L5 and 7L6 is indicated on Figure 7-42, whilst Figure 7-43 indicates the proposed SWMP for Dump 7L7.

The SWMPs have been designed as closed systems (i.e. no discharge of dirty water runoff to the surrounding environment). Stormwater measures proposed to separate clean and dirty water areas are discussed below.

7.6.1.4 Clean Cut-Off Trenches

Upslope runoff will be diverted away from the dumps via cut-off trenches. An existing trench was noted to be running along the northern side of Dumps 7L5 and 7L6 (Figure 7-40). The trench was noted to be silted and overgrown and will need to be repaired and upgraded. No trenches or channels to divert upslope runoff away from Dump 7L7 were noted, and it is therefore proposed that a trench is dug around the dump, as indicated on Figure 7-43. The soil removed during the construction of the trench, should be placed on the dump side of the channel, to create a berm that will provide a separation barrier between clean and dirty areas. To prevent erosion and siltation, the trenches and the berms must be vegetated with indigenous grass. It is proposed that the trenches are constructed to be trapezoidal in shape, with side slopes of 1V:2H (Figure 7-41). This will allow for easy access when maintenance is required, such as when the trenches become silted or overgrown.

Figure 7-40: Existing trench running along the northern side of Dumps 7L5 and 7L6

Figure 7-41: Proposed channel and berm design

Figure 7-42: Proposed conceptual stormwater management plan for Dumps 7L5 and 7L6

Figure 7-43: Proposed conceptual stormwater management plan for Dump 7L7

7.6.1.5 Top Paddocks

It is proposed that the top of the dumps be sectioned off into a series of paddocks. The purpose of the paddocks is to ensure that runoff from storm events is contained on top of the dump, as well as to prevent flooding and potential spills at the slurry collection sump. The paddock walls should be constructed at a height of 1.5 m, which is higher than the 1:50 year storm event including an average year of rainfall, with side slopes not steeper than 1V:3H. The only area that will contribute runoff to the slurry collection sump, is the paddock where hydraulic reclamation takes place (this area is referred to as the working area in this report, which has been assumed to be 5 % of the dump area at any time).

7.6.1.6 Toe Paddocks

The purpose of the toe paddocks is to capture, contain and evaporate runoff from the side slopes of the dumps. The existing toe paddocks at the dumps were noted to be silted and these will accordingly require desilting. Figure 7-44 indicates silted paddocks at Dump 7L5.

Figure 7-44: Silted toe paddocks at Dump 7L5

7.6.1.7 Berms

Berms are proposed around the reclamation pump stations. The purpose of the berms is to ensure that potential spills from the pump stations are contained. An existing berm at Dumps 7L5 and 7L6 can be made use of, which will need to be repaired and upgraded. At Dump 7L7, soil taken from the clean cut-off trench can be used to construct a berm. The berms must be vegetated to prevent erosion.

Recommendations

It is recommended that the proposed SWMPs are implemented in line with GN R704 Regulations. It is further recommended that an exemption from GN R704 is obtained for the proposed stormwater management measures that fall within the 100 m watercourse buffer. It should be kept in mind that these are historical dumps that were created prior to the establishment of GN R704.

The Water Balance

A monthly water balance was setup in Microsoft Excel spreadsheet format, to estimate the volumes of water in the reclamation circuit. The water balance has been setup to simulate the average yearly, average dry and average wet season volumes. This section details the water balance which has been prepared in accordance with the Best Practice Guideline G2: Water and Salt Balances.

The parameters and assumptions/sources used in the water balance calculations are provided in the table below.

Table 7-16: Parameters and assumptions/sources used in the water balance calculations

PARAMETER VALUE UNITS ASSUMPTION/SOURCE Dirty area of dump measured from proposed Dump 7L5 total area 284 000 m² SWMP Dirty area of dump measured from proposed Dump 7L6 total area 528 000 m² SWMP Dirty area of dump measured from proposed Dump 7L7 total area 548 000 m² SWMP Dump 7L5 working area 14 200 m² Assumed to be 5 % of dirty area Dump 7L6 working area 26 400 m² Assumed to be 5 % of dirty area

Dump 7L7 working area 27 400 m² Assumed to be 5 % of dirty area Dump 7L5 sump area 5 000 m² Assumed Dump 7L6 sump area 5 000 m² Assumed

Dump 7L7 sump area 5 000 m² Assumed

Assumed 50% of monthly rainfall runs off Working area rainfall-runoff coefficient 0.5 - from the dirty areas to slurry sump

Assummed 80% of water used for Reclamation water runoff coefficient 0.8 - reclamation runs off as slurry. 20 % losses

Dump 7L5 monthly water volume required Calculated based on 1m³ of water required to 273 829 m³/month for hydraulic reclamation remove 1 ton of tailings

Dump 7L6 monthly water volume required Calculated based on 1m³ of water required to 308 414 m³/month for hydraulic reclamation remove 1 ton of tailings

PARAMETER VALUE UNITS ASSUMPTION/SOURCE

Dump 7L7 monthly water volume required Calculated based on 1m³ of water required to 319 461 m³/month for hydraulic reclamation remove 1 ton of tailings Based on the 10-year operational phase and Dump 7L5 operational phase 24 months tonnage of dump Based on the 10-year operational phase and Dump 7L6 operational phase 42 months tonnage of dump Based on the 10-year operational phase and Dump 7L7 operational phase 54 months tonnage of dump Number of employees 10 - Assumed

Potable water provision per employee 0.1 m3/day Assumed 100L/day per employee

7.6.1.8 Water Balance Results

The water balances for dumps 7L5, 7L6 and 7L7, for the average yearly, average wet and dry season scenarios are indicated in Figure 7-45, Figure 7-46 and Figure 7-47, respectively.

Figure 7-45: Dump 7L5 monthly water balance (m³/month)

Figure 7-46: Dump 7L6 monthly water balance (m³/month)

Figure 7-47: Dump 7L7 monthly water balance (m³/month)

7.7 Groundwater

Refer to Appendix D3 of the EIA for the Surface Water Impact Assessment

Available Surface and Groundwater Monitoring Data

Boreholes at dumps 7L5, 7L6 and 7L7 are not included in Ergo’s water quality monitoring programme (Ergo Quarterly Water Quality Monitoring Reports, 2017 to 2019). Six boreholes at the Daggafontein TSF (2.5 km north) are included in the monitoring programme (Table 7-17) (Figure 7-48), but only five boreholes are sampled on a regular basis. The Daggafontein TSF water monitoring programme includes five surface water monitoring sites – 3 contaminated water storage sites, one upstream Blesbokspruit sampling point and a sampling point on the Blesbokspruit, just below dump 7L7.

The water qualities for the Ergo sites are measured against the Blesbokspruit Catchment Water Quality Objectives and the sampling is done to comply with conditions in Water Use Licenses 08/C22C/CGI/425 and 08/C22B/CGI/3575.

Table 7-17. Daggafontein TSF monitoring sites - Ergo

MONITORING NO LOCATION LATITUDE LONGITUDE DT1 Dagga collector 26°18.596'S 28°31.423'E DT2 Blesbokspruit, Ermelo Rd 26°16.004'S 28°30.196'E DT3 Dagga return 26°17.094'S 28°31.399'E DT4 Dagga launder 26°17.117'S 28°31.730'E DT5 Blesbokspruit, Marievale 26°21.439'S 28°30.822'E DT7 Dagga GBH9 26°17.126'S 28°31.775'E DT8 Dagga GBH10 26°17.485'S 28°32.483'E DT9 – not sampled recently Dagga GBH11 26°18.153'S 28°32.846'E DT10 Dagga GBH5 26°18.627'S 28°31.370'E DT11 Dagga GBH4 26°18.410'S 28°31.181'E DT12 Dagga GBH2 26°17.514'S 28°31.128'E

There are four historical groundwater monitoring boreholes 7 to 10 km north of the Marievale TSFs, According to the National Groundwater Archive database (Figure 7-48 and Table 7-18).

Table 7-18: NGA boreholes - DHSWS

MONITORING DRAINAGE MONITORING MONITORING POINT NAME LAT LONG NAME POINT ID REGION ACTIVE

- GROOTVALY (DUP NAME 28.5055 162159 26.2286 GROOTVALY C21D NO 21153) 56 11

MONITORING DRAINAGE MONITORING MONITORING POINT NAME LAT LONG NAME POINT ID REGION ACTIVE

- GROOTVALY (DUP NAME 162160 26.2438 28.505 GROOTVALY C21E NO 21154) 89 - GROOTVALY (DUP NAME 28.4855 162161 26.2605 GROOTVALY C21E NO 21155) 56 56

GROOTVALLEY (DUP NAME 28.4888 164211 -26.25 GROOTVALLEY C21E NO 22680) 89

Figure 7-48: Historical borehole locality map

A study by the Council for Geosciences (2005) – “Contamination of wetlands by Witwatersrand gold mines – processes and the economic potential of gold in wetlands” – included the sampling of three surface water and two wetland sediment sampling sites, along the Blesbokspruit, from Largo Colliery to the R42 – Nigel-Delmas Road in the south. Surface water site JV04/052 and wetland sediment sampling site GN05/009 are approximately 1 km from dump 7L7. The other sites are between 4,5 and 8 km away.

Table 7-19: Council for Geosciences sampling sites

MONITORING NO LOCATION LATITUDE LONGITUDE

JV04/044 Surface water - Bridge at Nigel-Delmas Rd 26. 389930°S 28. 497650°E JV04/052 Surface water - Marievale bridge 26. 358310°S 28. 508000°E GN04/205 Surface water - Bridge near Largo 26.254970°S 28.498500°E GN05/009 Wetland site close to 7L7 26°20'52.9”S 28°30'49.9”E GN05/010 Wetland site close to Largo Colliery 26°15'18.3”S 28°30'00.7”E

The data from these surface water, groundwater and wetland sampling sites were included in the Marievale TSF impact assessment. Data was also sourced during the 2019 hydrocensus and historical EIAs conducted in the area, that included the proposed Vlakfontein/ Brikor, Canyon Coal/ Anglo Coal and the Bloemendal Projects.

The Marievale 2019 Hydrocensus

A hydrocensus was conducted across the Marievale area during December 2019. The survey concentrated on identifying existing boreholes to enhance the knowledge of the groundwater systems and current groundwater use.

During the 2019 hydrocensus 22 boreholes were identified (Figure 7-49). Ten of the 22 boreholes include 2 to 3 piezometer tubes, for measuring groundwater quality and water level depths at various depth intervals. Most of the sites have two piezo tubes installed, measuring a deep and shallow zone. Borehole Mari13 has three piezometer tubes. The construction and depth information of these sites were not available. All boreholes identified are open and not in use. It has been assumed that the boreholes may be old groundwater exploration/ monitor boreholes.

No boreholes were identified in-between Site 1 (dumps 7L5/ 7L6) and Site 2 (dump 7L7), or downgradient (south) of dump 7L7. The extent of the study area, budget and time constraints, and land access limited the hydrocensus in terms of surveying every property in the area. The study did aim at covering the whole area to ensure a data set representative of the study area.

7.7.1.1 Groundwater Levels

According to a study by GPT in 2018 (Bloemendal Coal Mine Hydrogeological Study) the groundwater levels to the east of the Blesbokspruit were between 1.53 and 3.77 m bgl, with a correlation of 99.6% between surface elevation and groundwater level.

During the 2019 hydrocensus groundwater level measurements were possible from 25 of the 29 identified boreholes; the remaining four boreholes were blocked / collapsed.

Water levels were measured by using a dip meter to measure the distance from the mouth of the borehole (borehole collar elevation) to the groundwater table depth in the borehole. The height of the borehole collar was subtracted from the measured water level to define a water level below surface (measured in mbgl).

The groundwater level below surface varied between a maximum depth of 29.65 mbgl (borehole Mari10) and close to the Vlakfontein Quarry, to 1.3 m bgl at Mari1 Figure 7-49). The correlation between topography and groundwater elevation is approximately 69%, as shown in Figure 7-50. If the three borehole points marked by orange dots are disregarded, the correlation changes to 93%. This means that the depth to groundwater correlates well with the surface elevations (topography), indicating that on a local scale groundwater flow follows topography. The three dots represent boreholes Mari15_deep, Mari16_deep and Mari10. Construction details are not available for these sites, but it has been assumed that the three sites penetrated the deeper dolomitic aquifer. Hence the deeper rest levels.

Figure 7-49: Hydrocensus boreholes

Ten boreholes are equipped with two or three piezometer tubes to assist with groundwater level and quality measurements at various depths below surface (Table 7-20).

The water table in an area generally mimics the topography and drains on a regional scale towards the rivers and streams. On a local scale groundwater movement might be in the opposite direction but adopt the regional trend/flow direction as the groundwater moves further away from the topographical feature. Generally, a groundwater mound occurs beneath a TSF because of seepage from the TSF, that recharges the underlying aquifer. This results in radial flow from the TSF footprint but assumes regional flow direction again as the distance increases from the TSF.

For the Marievale TSF area, the groundwater flow direction will be in an easterly to south-easterly direction towards the Blesbokspruit, but on a regional scale the flow will be south.

Figure 7-50: Correlation between surface and groundwater elevations in hydrocensus BHs

Table 7-20. 2019 Hydrocensus data

LATITUDE LONGITUDE ELEVATION WATER LEVEL SITE ID ALT NO. STATUS WGS84 (M AMSL) (M BGL) Mari1 26°19'38,0"S 28°30'32,8" E 1572 1,33 Open borehole near Mari2 Mari2 26°19'37,9"S 28°30'33,1" E 1572 1,48 Open borehole near Mari1 Mari3 26°19'47,6"S 28°29'43,6" E 1563 8,28 Open borehole near Mari4 Mari4 26°19'47,2"S 28°29'43,7" E 1562 8,07 Open borehole near Mari3 Mari5 26°19'18,0"S 28°29'25,3" E 1577 blocked Piezo tube. Blocked Mari6 26°19'31,8"S 28°29'33,2" E 1571 1,99 Large diameter casing, open borehole Mari7 26°19'32,3"S 28°29'32,3" E 1573 2,15 Large diameter casing, open borehole Mari8s 26°19'49,4"S 28°29'28,5" E 1572 8,57 2 piezos in 1 borehole. Open borehole Mari8d 26°19'49,4"S 28°29'28,5" E 1572 8,39 Mari9 26°19'49,6"S 28°29'28,4" E 1568 9,31 Open borehole near Mari8 Mari10 26°20'21,7"S 28°29'24,8" E 1569 29,65 Next to golf course and coal mine Mari11 26°18'17,9"S 28°32'29,7" E 1591 blocked Blocked at 4.5m Mari12 26°17'08,2"S 28°31'06,5" E 1576 6,32 2 piezos with same waterlevel, inside cement ring Mari13s ZBH25 - shallow 26°19'28,4"S 28°30'40,0" E 1564 1,42 Mari13m ZBH25 - medium 26°19'28,4"S 28°30'40,0" E 1564 1,43 3 piezos in 1 borehole Mari13d ZBH25 - deep 26°19'28,4"S 28°30'40,0" E 1564 2,62 Mari14 ZBH27 26°19'16,7"S 28°29'30,8" E 1585 2,49 Borehole with cap Mari15s ZBH31 - shallow 26°19'30,3"S 28°29'14,0" E 1573 blocked 2 piezos in 1 borehole. Shallow piezo is blocked at 11m Mari15d ZBH31 - deep 26°19'30,3"S 28°29'14,0" E 1573 18 Mari16s ZBH33 - shallow 26°19'37,5"S 28°29'18,4" E 1572 blocked 2 piezos in 1 borehole. Shallow piezo is blocked at 9m Mari16d ZBH33 - deep 26°19'37,5"S 28°29'18,4" E 1572 21 Mari17s ZBH34 - shallow 26°19'33,3"S 28°29'32,4" E 1570 4,38 2 piezos in 1 borehole. Open borehole Mari17d ZBH34 - deep 26°19'33,3"S 28°29'32,4" E 1570 5,08

LATITUDE LONGITUDE ELEVATION WATER LEVEL SITE ID ALT NO. STATUS WGS84 (M AMSL) (M BGL) Mari18s ZBH35 - shallow 26°19'39,9"S 28°29'32,6" E 1569 6,65 2 piezos in 1 borehole Mari18d ZBH35 - deep 26°19'39,9"S 28°29'32,6" E 1569 9,23 Mari19 DT9 26°18'09,5"S 28°32'51,2" E 1620 5,88 Open borehole Mari20 DT10 26°18'37,8"S 28°31'22,3" E 1569 2,47 Inside very high cement rings. 2 tubes. Open top Mari21 DT11 26°18'24,6"S 28°31'10,7" E 1586 4,59 Inside cement rings. 2 tubes, 1 blocked. Open top Mari22 DT12 26°17'31,2"S 28°31'07,2" E 1576 3,01 Inside cement rings. 2 tubes, 1 blocked at 3m. Open top

7.7.1.2 Groundwater Quality

Five (5) water samples were collected from the project area during the 2019 hydrocensus:

❖ Mari1 – at the north-eastern corner of dump 7L6; ❖ Mari4 – at the north-western corner of dump 7L5; ❖ Mari10 – near the Vlakfontein Quarry; and ❖ ZBH35 (Mari18) shallow and deep. Two samples taken to assess the difference between the shallow and deeper zones being monitored. This borehole is in a large open area, to the west of the study area.

The groundwater specialist recommended that dedicated monitoring boreholes be installed in-between 7L5/ 7L6 (Site 1) and at 7L7 (Site 2) and also downstream of 7L7 for monitoring purposes, before the reclamation activities start (if approved) (starting at least 1 year in advance and sampling every quarter thereafter). The database will help the client identify groundwater quality and level trends and will serve as reference to identify and quantify potential impacts on the groundwater environment.

Based on the water quality results (Table 7-21), the following conclusions were drawn (SANS 241:2015):

• Chronic Health effects: o Manganese –Only borehole Mari1 measured a manganese concentration that could result in chronic health effects (0.683 mg/L) (Table 7-21). o Nickel – An elevated nickel concentration was measured at borehole Mari10.

The mobility of trace elements is dependent on several parameters, including pH. All the trace elements examined are most mobile when the pH <4.5, and least mobile when the pH > 6. The pH for all sampled sites was near neutral.

• Acute Health effects: o Sulphate – Sulphate concentrations were elevated in boreholes Mari1 and Mari4, both sites are located close to the footprint of a TSF (Table 7-21). • Aesthetic effects: o Manganese – Boreholes Mari4 and Mari18D measured manganese concentrations that could pose an aesthetic concern (0.30 and 0.19 mg/L respectively). o Sodium – Borehole Mari4 exceeds the aesthetic limits for drinking water. o Turbidity –Turbidity was high in boreholes Mari1, Mari10 and Mari18S. o Magnesium –High magnesium concentrations were measured boreholes Mari1 and Mari4. o Total hardness –Borehole Mari10 has moderately hard water. High concentrations of calcium were measured at 4 of the 5 sites.

The chemicals of concern for the Marievale project area, associated with the recent sampled results are manganese, sulphate and nickel. Parameters exceeding aesthetic limits include calcium, magnesium and sodium. Most of these are only elevated in boreholes Mari1 and Mari4. Based on the SANS241 drinking water

guidelines and on the sampled water results, the sampled water from Mari1, Mari4 and Mari10 is not fit for human consumption (unless treated).

The element concentrations seem to reduce in the groundwater, further away from the TSFs (Table 7-21). This relates to dilution and a change in pH conditions – more alkaline further away from the TSF and the buffering effect of the geological formations and associated minerals.

The groundwater specialist concluded that there are many pollution sources (industrial discharge, mining activities and poor waste and sanitation management) that can contribute to groundwater contamination. It was stated that it will be difficult to define the contaminants and concentration at all point sources in the area.

Only exceedances were indicated in Table 7-21 below. Please refer to the Groundwater impact study for the full details of parameters.

Table 7-21: Marievale water quality – December 2019

MARI MARI MARI ZBH ZBH PARAMETER UNIT SANS241 STANDARD LIMITS DHSWS DRINKING STANDARDS 1 4 10 35D 35S No health. Scaling intensifies from Calcium mg Ca/ℓ 291 596 16,9 65,9 96,1 32mg/L Diarrhoea and scaling issues from Magnesium mg Mg/ℓ 161 302 7,28 36,8 44,6 70mg/L - Manganese mg Mn/ℓ Aesthetic ≤0.1 Chronic health ≤0.4 0,683 0,307 0,007 0,191 0,001 Chronic health Nickel mg Ni/ℓ 0,028 -0,002 0,131 0,03 0,031 ≤0.07 Electrical Conductivity at mS/m Aesthetic ≤170 239 487 22.2 56,4 73,8 25°C Sodium mg Na/ℓ Aesthetic ≤200 63,1 238 13,3 6,39 6,93

Sulphate mg SO4/ℓ Aesthetic ≤250 Acute health ≤500 973 2412 6,89 79,5 124 Total Dissolved Solids mg/ℓ Aesthetic ≤1200 1839 3998 113 354 450 mg 60–120 mg/l, moderately Total Hardness 120–180 mg/l, hard more than 180 mg/l, very hard 1389 2732 72 316 424 CaCO3/ℓ hard Turbidity NTU Aesthetic ≤5 2540 4,69 6,12 3,32 81,6

Geochemistry

During tailings deposition and after decommissioning, seepage from the tailings facility walls is largely removed by the drain systems. A study has shown that the top 3 metres of an old TSF / dump indicate low element concentrations, as leaching from rainfall most probably flushed out the minerals. Deeper into the TSF the pH is much lower and element concentrations higher, but due to stable conditions that include low permeability and low oxygen levels, metal and salt leaching does not happen readily (Irene Lea, 2016). This could potentially change when the reclamation process introduces high volumes of water and oxygen.

The prerequisite for AMD is the generation of acid at a faster rate than it can be neutralised by any alkaline materials in the system, with pyrite being the most common mineral in AMD formation. The oxidation of pyrite occurs in the following steps:

2+ 2- + (1) 2FeS2 + 7O2 + 2H2O = 2Fe + 4SO4 + 4H

2+ + (2) 4Fe + 10H2O + O2 = 4Fe (OH)3 + 8H

2+ + 3+ (3) 2Fe + O2 + 2H = 2Fe + H2O

3+ 2+ 2- + (4) FeS2 + 14Fe + 8H2O = 15Fe + 2SO4 + 16H

The intensity of acid generation is determined by chemical parameters such as pH, temperature and oxygen concentration in the different stages and the surface area of the exposed metal sulphides (Nengovhela, October 2006).

The reclaimed slurry and any water must be removed from the exposed surfaces (immediately) to avoid seepage of contaminated water into the shallow weathered shale / sandstone and deeper karst aquifers.

Comment on the Risk Associated with Uranium

The risk associated with elevated Uranium concentrations for the Marievale Reclamation Project was evaluated. Uranium can be an indicator of risk since it is associated with Witwatersrand mining activities and has been identified as the contaminant of most concern in the Wonderfonteinspruit Catchment, situated on the West Rand. Uranium is considered chemotoxic, radiotoxic and carcinogenic. Uranium is furthermore mobile under oxidizing conditions and in an acidic environment.

A guideline value of 0,02mg/L for the chemical toxicity of uranium in drinking water was proposed by Wade and Winde (2005). The South African National Nuclear Regulator provides a guideline level of 80 mg/kg for whole rock analyses. The SANS241:2014 Drinking Water Standard for Uranium is 0,03 mg/L. The latter will be used in this assessment.

The Council for Geoscience completed an assessment of the wetlands associated with the Witwatersrand mining basin in 2005 (Coetzee et al, 2005). As part of this study, a geochemical analysis of water and sediment samples was completed, including in the Blesbokspruit wetland in the vicinity of the Marievale Bird Sanctuary, namely sample GN5/009A. Trace element and batch leach test results for this sample is presented in Figure 7-51. The results of both tests indicate comparatively low concentrations of Uranium present in the soil sample taken. This suggests that elevated Uranium is not as prevalent in the East Rand Mining Basin compared to in the West Rand.

Please note that no samples were taken of the tailings material to be reclaimed as part of this project. It is therefore not possible to confirm whether similar trends would manifest in tailings material.

Figure 7-51: Trace metal and batch leach tests for Marievale soil sample (Coetzee et al, 2005)

Aquifer Characterisation

Aquifer characterisation is done based on the information presented thus far, and guidelines and maps provided by the DHSWS. 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.

Except for the Malmani dolomite, all the 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.

The dolomite is classified as a major aquifer system, which are viewed as a high yielding aquifer, with generally good quality water (Parsons, 1998).

7.7.1.3 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 Department of Human Settlements, Water and Sanitation (DHSWS) in July 2013 the dolomite is classified as a vulnerable aquifer system. The Karoo formations are less vulnerable.

7.7.1.4 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 Karoo formations have a low susceptibility to contamination. The dolomite is highly susceptible to contamination.

Groundwater Modelling

The conceptual hydrogeological model provides an understanding and description of the aquifers present, specifically the structural and physical characteristics that control the flow, storage and quality of groundwater. The description of the conceptual model is accompanied by a cross section compiled from the existing dataset.

The cross section in Figure 7-52 indicates that TSF 7L5, 7L6 and 7L7 are situated on Vryheid Formation shale and Dwyka tillite and in some instances, on alluvium. The Blesbokspruit and its associated alluvium are situated directly on Malmani dolomite. The Green Sill has intruded into the dolomite and occurs at a depth of approximately 60 m below surface. The Black Reef is located at the base of the dolomite. The depth and geometry of the dolomite were inferred from the position of the sub-outcrop and the Environmental Control Level (ECL) set in 2011 (the base of the dolomite). The dolomite, Green Sill and Black Reef sub-outcrops against the Karoo shale and tillite, in the vicinity of the project area. South of this sub-outcrop, Witwatersrand strata are present below the Karoo sediments. It is understood that the DHSWS is currently dewatering the East Rand Basin to a depth of 1 470 mamsl, as indicated by on Figure 7-52 (DWAF 2013 ECL).

Based on available literature, specifically AGES (2006), aquifer parameters could be assigned to the different rock formations that play a role in the project. These parameters are presented in Table 7-22. Four aquifer layers are described in the table, based on the conceptualization of the aquifers presented in Figure 7-52.

Figure 7-52: Cross section through the aquifers present

Table 7-22. Aquifer parameters used during the assessment (after AGES, 2006)

HORIZONTAL VERTICAL COMMENT ON RECHARGE RATE (% AQUIFER LAYER PERMEABILITY PERMEABILITY AQUIFER OF MAP) (M/D) (M/D) CONDITIONS Alluvium: enhanced Alluvium: 0,26 Alluvium: 5E-5 Alluvium: 15% aquifer Shallow perched aquifer Karoo shale: 5E-4 Karoo shale: 5E-5 Karoo 2% Karoo shale: low- yielding aquifer Dolomite: enhanced Dolomite: 4 Dolomite: 1E-4 Dolomite: 7% aquifer Shallow weathered aquifer Wits sediments: 2E-9 Wits sediments: 5E-5 Wits sediments: 3% Wits sediments: poor aquifer Green Sill Green Sill: 5E-7 Green Sill: 5E-7 Aquitard Dolomite: enhanced Fresh dolomite: 4E-4 Fresh dolomite: 4E-4 aquifer Fractured rock

aquifer Wits sediments: 2E-9 Wits sediments: 2E-9 Wits sediments: poor aquifer

7.7.1.5 Source Term 7.7.1.5.1 Seepage Quality

The source term used in the impact prediction simulations presented in this report is a function of leachate quality and the volume of leachate available for infiltration to the aquifers. The leachate quality component of the source term was developed from the current Ergo monitoring programme for the Daggafontein TSF, situated northeast of the Marievale project area (approx. 2.4 km) (Figure 7-49).

The groundwater study concluded that the groundwater associated with the Daggafontein TSF has high risk quotients for Electrical Conductivity (EC), sulphate (SO4), ammonia (NH4), magnesium (Mg), iron (Fe) and Uranium (U). These high-risk quotients were calculated mainly for borehole DT9, which was only sampled until January 2018. The high quotients calculated for ammonia are most probably related to the discharge of treated sewage upstream in the Blesbokspruit and not associated with tailings deposition. Only one uranium risk quotient exceeded the threshold value slightly.

The highest risk quotients were however calculated for sulphate and iron concentrations, especially the latter, as shown in the table. For this reason, these two elements will be considered as indicator elements during the impact prediction presented in this report.

Table 7-23: Daggafontein TSF seepage, surface water and groundwater qualities

SAMPLE NOV- JAN- SEP- OCT- JAN- MAY- JUL- DESCRIPTION POSITION 17 18 18 18 19 19 19 Sulphate DT1, DT3, DT4 Tailings seepage quality 5947 4797 3471 4904 6113 3882 4260 DT5 Blesbokspruit 600 382 565 632 487 274 497 DT9, DT10 Impacted groundwater 948 445 208 246 17 17 172 Downstream DT12 11 595 747 683 661 278 466 groundwater DT7, DT8, DT11 Ambient groundwater 23 29 25 16 11 12 11 Iron DT1, DT3, DT4 Tailings seepage quality 59 32 5 25 44 25 30 DT5 Blesbokspruit 0,246 0,076 0,183 0,105 0,066 0,067 0,028 DT9, DT10 Impacted groundwater 2,827 3,980 0,025 0,025 0,032 0,025 0,025 Downstream DT12 0,126 0,025 0,041 0,025 0,025 0,025 0,025 groundwater DT7, DT8, DT11 Ambient groundwater 0,037 0,025 0,025 0,048 0,091 0,040 0,036

Based on the information presented in Table 7-23, the source term for TSF 7L5, 7L6 and 7L7 will be assigned as follows:

❖ Sulphate: 4 800 mg/L; and ❖ Iron: 30 mg/L.

Figure 7-53: Tailings seepage quality for the Daggafontein TSF

7.7.1.5.2 Seepage Volume

The volume of leachate available for infiltration was calculated from water balance information made available by the surface water specialist working on the Marievale project (pers. comm. Mr Andy Pirie). The calculations used are presented in Table 7-24. Average water balance conditions were used to complete the calculation. A value of 691 mm/a was used as the Mean Annual Precipitation (MAP) for the quaternary catchment in which the project is situated (waterresourceswr2012.co.za).

The seepage volume is dependent on the volume of water that is not used, captured, returned back into the project water circuit or is evaporated. The leachate volume is therefore equivalent to the difference between inflows and outflows at each of the TSFs, based on the water balance calculations.

The calculations presented in Table 7-24 provide an estimated rate of seepage over the footprint area of each TSF. These vary between 22 and 41% of the MAP, based on average conditions. These rates are comparable to similar TSF projects based on the author’s experience. An average rate of 32% of MAP will be applied during the impact prediction. This will represent Ergo’s operational impact on groundwater during tailings reclamation.

Table 7-24. Water balance calculations (pers. comm. Mr Andy Pirie)

AVERAGE WATER BALANCE CONDITIONS PARAMETER 7L5 7L6 7L7 Direct rainfall (m3/month) 298 298 503 Rainfall runoff (m3/month) 424 788 818 Reclamation runoff (m3/month) 219 063 246 731 255 569 Potable water supply (m3/month) 31 31 31 Total inflow (m3/month) 219 816 247 848 256 921 Evaporation (m3/month) 571 571 571 Volume pumped to Plant (m3/month) 218 916 246 948 255 815 Total outflow (m3/month) 219 487 247 519 256 386 Balance correct to entire footprint (m3/month) 6580 6580 10700 TSF area (m2) 284 000 528 000 548 000 Possible seepage over the footprint area (m/d) 7,72E-04 4,15E-04 6,51E-04 % of MAP 41 22 34

7.7.1.6 Potential Pathways and Receptors

Based on the available dataset, the following aquifer pathways are identified for the project:

❖ Vertical flow through the unsaturated soil horizon from the tailings reclamation areas to the underlying weathered and fractured rock aquifers. ❖ Vertical and horizontal flow through the weathered aquifer at the tailings reclamation areas. It is noted that the contact between fresh and weathered rock is considered a preferential flow path to groundwater. ❖ Preferential flow along the alluvium associated with the Blesbokspruit. ❖ Preferential flow in the dolomitic aquifer associated with the Malmani dolomite. It is noted that the Blesbokspruit alluvium is in direct contact with the dolomitic aquifer adjacent to the project area. ❖ It is noted that the Green Sill will act as an aquitard in the vertical flow direction. The sill is present within the dolomitic aquifer underneath the project sites. In the unlikely event that contamination from the TSF reaches the fractured rock aquifer, the preferential flow paths include fractures, faults, joints and bedding planes in the rock formations. Groundwater will also flow through the rock matrix, but at much lower rates compared to the preferential pathways. The position, depth and extent of such zones of increased permeability is not currently known.

The following receptors were identified:

❖ The Blesbokspruit and its tributaries down gradient of the project areas. Groundwater is expected to contribute to river and baseflow, specifically during the wet season when groundwater levels are expected to rise above the base of the streams as a result of the recharge of rainwater. ❖ The wetlands associated with the Blesbokspruit and its alluvium. Shallow groundwater is expected to contribute to the maintenance of these wetlands, especially during the dry season, when river water levels may be lowered.

❖ The dolomitic aquifer present in the area. As this aquifer is considered a major aquifer in the context of the study, impacts associated with tailings reclamation may be significant. It is understood that this aquifer is regionally used for groundwater abstraction by farmers (DWAF, 2012). The potential pathways and receptors are summarised in Table 7-25.

Table 7-25. Pathways and receptors

PATHWAYS RECEPTORS

Runoff Blesbokspruit and its tributaries Wetlands associated with the Blesbokspruit and the Seepage Marievale Bird Sanctuary The dolomitic aquifer The dolomitic aquifer Alluvium associated with the Blesbokspruit

Blesbokspruit (Possibly the greatest unknown and potential long-term risk area) Fractures, faults, joints and bedding planes Regional aquifer

7.7.1.7 Contaminant Transport Simulations

The impact of the proposed Marievale Reclamation project on groundwater quality was simulated using

Sulphate (SO4) and Iron (Fe) as indicator elements. The conceptual source term used to commence contaminant transport simulations is presented in Section 7.7.6.1.

All existing TSFs, including those not associated with the Marievale Reclamation project, were included during simulations. These were all included under the same assumptions made for TSF 7L5, 7L6 and 7L7. These TSFs were included during simulations to assess the cumulative impact of historical TSF deposition in the area.

Impact Prediction

The existing monitoring dataset confirms that the historical deposition of the tailings on the 7L5, 7L6 and 7L7 and other TSFs in the region has impacted on groundwater quality. Groundwater monitoring data obtained during the 2019 hydrocensus confirms that groundwater close to the footprint of TSF 7L5 and 7L6 has sulphate concentrations exceeding 2 400 mg/L (Mari 4), for example.

DHSWS (DWAF 2012) reports that the tailings storage facilities have been identified as sources of ingress to the East Rand Mining Basin. DHSWS further states that the rate of ingress can be reduced through the removal and reworking of these TSFs. It is noted that a short-term negative impact is expected during the operational phase as a result of the method in which the tailings is removed, but that an overall improvement of surface water and underground water quality is expected in the long-term as a result of the removal of the TSFs.

TSF 7L5, 7L6 and 7L7 were positioned on outcrops of Karoo sediments. The Karoo aquifer is thought to exhibit low permeabilities and is therefore a low-yielding aquifer, which is emphasised by third party clay mining in the area. Portions of the footprints of these TSF are however located on alluvium, as indicated by the regional

geological map. There is no information available on the construction and management of these TSF. For the purpose of this assessment, it was assumed that the TSF footprint areas were not prepared and that tailings were deposited on virgin ground.

The outcome of the simulations are presented as sulphate and iron concentration contour maps that delineate the anticipated plumes. For both sulphate and iron, two maps are provided for each scenario tested. The first is to show the impact on the shallow weathered aquifer and the alluvium associated with the Blesbokspruit and the second the impact on the fractured rock aquifer above the Green Sill.

The extent of the contours is based on the In-Stream Water Quality Guidelines for the Blesbokspruit, as detailed in Table 7-26.

Table 7-26. Applicable In-stream Water Quality Guidelines for the Blesbokspruit Catchment

ACCEPTABLE IDEAL CATCHMENT TOLERABLE INTERIM ELEMENT MANAGEMENT UNACCEPTABLE BACKGROUND TARGET TARGET Sulphate <150 150 – 300 300 - 500 500 Iron <0.1 0.1 – 0.5 0.5 – 1.0 >1.0

Three scenarios are presented on each figure:

❖ The anticipated current status, which reflects the impact of historical tailings deposition prior to the commencement of the Ergo project, is indicated as a green dashed line. This line delineates the position of the 500 mg/L sulphate and 1 mg/L iron contour (the unacceptable limits). ❖ The impact at the end of the Ergo reclamation project is indicated as a yellow dashed line to delineate the extent of unacceptable concentrations of sulphate and iron.

The long-term impact is shown as the full set of concentration contours ranging from the Ideal Catchment Background values to the maximum concentrations obtained during simulations. Within these, the zone of unacceptable concentrations for sulphate and iron are indicated as a red dashed line

7.7.1.8 Scenarios tested

To complete the impact prediction, three scenarios were tested with the calibrated model. These include:

❖ Scenario 1: The operational and long-term impact if only partial tailings reclamation is implemented. This scenario tests the impact if the reclamation project is not completed or is selectively completed. ❖ Scenario 2: This scenario tests the impact if the tailings material is removed, but if the contaminated soils in the footprint are left in-situ. To complete this scenario, guidance was taken from the Council for Geoscience report on wetlands in the area (Coetzee et al, 2005). ❖ Scenario 3: This scenario tests the impact if tailings material is removed and if the contaminant load in the footprint soils is reduced through further rehabilitation. During simulations, it was assumed that

to achieve this, sulphate and iron concentrations in the soils would be reduced to below the Blesbokspruit unacceptable concentrations (Sulphate <500 mg/L and Iron <1 mg/L).

7.7.1.9 Scenario Outcomes

The results for the simulations show similar patterns for all three scenarios tested. These outcomes are attributed to the current understanding of the geometry and characteristics of the aquifers. For both sulphate and iron, the impact on the weathered aquifer and alluvium, as well as on the fractured rock aquifer above the Green Sill, is provided.

The general outcome of the simulations is summarised as follows:

❖ The contamination associated with historical tailings flows preferentially along the alluvium associated with the Blesbokspruit. As the wetlands are intricately linked to the extent of the alluvium, this preferential flow is therefore expected to impact on the quality of the groundwater component of baseflow to the wetlands. ❖ As there is no vertical barrier between the weathered aquifer/alluvium and the underlying dolomitic aquifer, contamination from surface is expected to reach the dolomitic aquifer. This is confirmed in the 2019 hydrocensus monitoring dataset. The extent of contamination in the dolomitic aquifer is however expected to follow similar patterns as those in the overlying weathered aquifer. The vertical movement of contamination can be estimated with more certainty if site-specific monitoring boreholes are drilled to quantify aquifer parameters and to improve the understanding of vertical flow between the two aquifers. ❖ The plumes move in a southerly direction away from the TSF, downstream in the Blesbokspruit alluvium. ❖ The historical impact of tailings deposition has impacted on groundwater quality in the aquifers. Based on the current conceptualisation, it is possible that contamination in the alluvium may have already migrated more than 1 000 m from the TSFs. ❖ In contrast, the movement of contamination in the Karoo weathered aquifer is slow due to its perceived low permeability. In this aquifer, historical contamination has most probably not migrated more than 200 m from the TSF. This is confirmed by water qualities obtained from hydrocensus boreholes to the west of TSF 7L5/7L6. ❖ The historical impact of tailings deposition is expected to continue to affect groundwater quality associated with the project areas in the long-term, even if Ergo removes the tailings as part of the proposed project. This is due to the fact that the contamination already present in the aquifers will continue to move downgradient, away from the site. With time, the concentrations will reduce if tailings reclamation proceeds, as a result of dilution from fresh rainwater in the catchment. This effect will be more pronounced in aquifers with higher permeability (and throughflow) like the alluvium and dolomitic aquifers, compared to the low-permeability aquifers (Karoo and Witwatersrand formations). ❖ Although other TSFs in the vicinity of the Marievale Reclamation Project were included during the simulations, a detailed assessment for these facilities fall outside the scope of this study. These TSFs were included under the same assumptions as those made for TSF 7L5, 7L6 and 7L7. It is noted that these TSFs are also expected to contribute to the impact on the Blesbokspruit, its wetlands and the

alluvium. It would most probably be difficult to distinguish between these impacts and to quantify the contribution of each site to the overall contamination load within the scope of this study. ❖ The main impact on the wetlands is expected to be associated with reclamation of TSFs 7L5 and 7L6. The impacted wetlands are situated south of these TSFs, over an area of approximately 680 000 m2. TSF 7L7 is expected to impact on a smaller section of the wetlands, mainly as it is not situated immediately upstream of wetlands and plume movement will take place preferentially in the alluvium. A wetland area of 4800 m2 could be affected in downgradient of this TSF. The simulations suggest that the interaction between the aquifer and the wetlands occur mainly in the upper weathered aquifer and the alluvium. ❖ The extent of the iron plume is larger in most instances compared to that of sulphate. This is due to the fact that lower concentration guidelines are imposed for the Blesbokspruit on iron compared to sulphate.

7.7.1.9.1 Scenario Three Outcomes: Impact prediction if reclamation includes footprint rehabilitation

The outcome of this scenario is presented in Figure 7-54 and Figure 7-55 for sulphate and in Figure 7-56 and Figure 7-57 for iron concentrations. To complete this simulation, it was assumed that footprint soils would be ameliorated to reduce contaminant concentrations to within tolerable interim targets. This implies that sulphate would be reduced to below 500 mg/L and iron to below 1 mg/L in leachate draining from the soils. The general outcome discussed above is applicable to the interpretation of the results. Quantification of the impacts are summarised in Table 7-27 for ease of comparison.

Table 7-27. Quantification of impacts if reclamation does not include footprint rehabilitation

SO4 IN FE IN

SO4 IN FRACTURED FE IN FRACTURED COMPONENT WEATHERED AQUIFER WEATHERED AQUIFER AQUIFER ABOVE GREEN AQUIFER ABOVE GREEN SILL SILL

Impact at the end of the Ergo Operational Phase

Maximum concentration over footprint >2 500 >1 500 >15 >10 area (mg/L) Distance that plume migrates downstream >1 000 >800 >2 000 >1 500 of site (m) Maximum concentration in wetlands >1 800 >1 400 >8 >5 within unacceptable zone (mg/L) Average concentration in wetlands within >900 >600 5 3 unacceptable zone (mg/L) Estimated volume of baseflow to wetlands <14 000 - < 14 000 - within unacceptable zone (m3/a) Estimated average salt load within <13 000 - <80 - unacceptable zone (kg/a)

SO4 IN FE IN

SO4 IN FRACTURED FE IN FRACTURED COMPONENT WEATHERED AQUIFER WEATHERED AQUIFER AQUIFER ABOVE GREEN AQUIFER ABOVE GREEN SILL SILL

Impact 100 years after decommissioning of the Marievale Project

Maximum concentration over footprint <500 <400 <2 <2 area (mg/L) Distance that plume migrates downstream <100 <500 >7 000 >7 000 of site (m) Maximum concentration in wetlands <500 <400 <2 <2 within unacceptable zone (mg/L) Average concentration in wetlands within <300 <300 <2 <2 unacceptable zone (mg/L) Estimated volume of baseflow to wetlands <14 000 - <14 000 - within unacceptable zone (m3/a) Estimated average salt load within <5 000 - <30 - unacceptable zone (kg/a)

Figure 7-54 Scenario 3: Sulphate concentrations in the weathered aquifer if reclamation includes footprint soil rehabilitation

Figure 7-55 Scenario 3: Sulphate concentrations in the fractured aquifer above the Green Sill if reclamation includes footprint soil rehabilitation

Figure 7-56. Scenario 3: Iron concentrations in the weathered aquifer if reclamation includes footprint soil rehabilitation

Figure 7-57. Scenario 3: Iron concentrations in the fractured aquifer above the Green Sill if reclamation includes footprint soil rehabilitation

Results indicate similar trends as those reported for the Ergo operational phase discussed for Scenario 2. The main benefit of footprint soil amelioration is that the long-term impact on the aquifers and wetlands is significantly reduced.

It is shown that footprint soil amelioration would result in a further 40% reduction in the concentrations of sulphate and iron in both aquifers, which in turn results in a reduction in the salt load on the wetlands in the long-term.

The concentration plumes presented in Figure 7-54 to Figure 7-57 further indicates that the area over which sulphate and iron concentrations would exceed unacceptable levels is greatly diminished in this scenario. In the case of sulphate, unacceptable concentrations would be confined to the immediate footprint areas of the TSF. Some remnants of historical groundwater contamination may remain but are expected to be flushed with time in the long-term.

Although the area over which iron concentrations would exceed unacceptable concentrations in the long-term for this scenario would reduce by approximately 25%, elevated iron concentrations are expected to prevail over large areas in the groundwater and in the wetlands associated with the Blesbokspruit. It is however anticipated that the concentrations in these areas would on average remain below 2 mg/L.

7.8 Air Quality

Refer to Appendix D4 for the Air Quality Impact Assessment (AIQA) report.

Health Effects of Particulate Air 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 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). 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). Furthermore, both the amount and the chemical and mineralogical composition of these small particles will influence the potential for health impacts (Schwegler, 2006).

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 a mine project 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 projects 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 1000µg/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 7-28).

Table 7-28: 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 matter ❖ Respiratory symptoms symptoms ❖ Adverse effects on the cardiovascular ❖ Reduction in lung function in children system ❖ Increase in chronic obstructive ❖ Increase in medication usage pulmonary disease ❖ Increase in hospital admissions ❖ Reduction in lung function in adults ❖ Increase in mortality ❖ Reduction in life expectancy ❖ Reduction in lung function development

7.8.1.1 Short-term Exposure

There is good evidence that even 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).

7.8.1.2 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, Europe and Canada,

3 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 an increase in the long- 3 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).

Ambient Air Quality

The Marievale Project TSFs fall within the declared Highveld Priority Area (HPA) for air quality. The Minister of Environmental Affairs declared the HPA on 23 November 2007 as the second National Priority Area (Government Notice No. 1123, 2007). The Highveld area in South Africa is associated with poor air quality. Elevated concentrations of criteria pollutants occur due to the concentration of industrial and non-industrial sources (Held, 1996; DEAT, 2006).

There are sensitive receptors such as schools and hospitals within a 10 km radius (Figure 7-58).

Figure 7-58: Sensitive receptors within a radius of approximately 10 km from the Marievale Project area.

Other large sources of particulate matter within a radius of 10 km from the project area include several TSFs, active mine dumps, quarries and brickworks, all of which contribute to the baseline levels of particulate matter in the air. There are also two industrial areas that may contribute to ambient concentrations of particulate matter (Figure 7-59). The closest air quality monitoring stations are situated in Springs and Tsakane.

There are two dustfall monitoring stations in the vicinity of the Marievale Project area – Dagga 1 and House 53 Howeson Road. However, they are not currently active (Figure 7-59).

Figure 7-59: Large sources of airborne particulate matter and monitoring stations in the vicinity of the Marievale Project area

The Ekurhuleni Metropolitan Municipality has recently resuscitated its monitoring network, however there are still some lags in data availability for certain periods (DEA, 2015). The closest monitoring stations to the project area, which measure ambient air concentrations of particulate matter, are the Springs and Tsakane monitoring stations. The Springs air quality monitoring station lies approximately 11 km to the north-west and the Tsakane monitoring station lies approximately 13 km to the west-south-west of the Marievale Project area respectively (Figure 7-59).

Figure 7-60 presents a graph (compiled on the South African Air Quality Information System (SAAQIS) website) of the measured PM10 ambient concentrations in Springs and Tsakane. It illustrates the high ambient concentrations of PM10 in the general area, with regular exceedances of the NAAQS measured in Tsakane. Because of the distance of these stations from the project area, they cannot be considered representative of the air quality of the project area. However, the modelling undertaken for the HPA AQMP (Government Notice No. 144, 2012) highlights the general project area as one of the hotspots (a node of frequent modelled exceedance of the standards) for PM as a result of emissions from brickworks in the area (Figure 7-59).

Figure 7-60: Daily average PM10 concentrations for the Diepkloof air quality monitoring station (SAAQIS, 2019).

Emission Scenarios Modelled

Dispersion simulations were undertaken to determine ambient concentrations of PM2.5 and PM10 resulting from the Marievale Project TSFs. Three scenarios were simulated – a status quo scenario showing the emissions from the TSFs before the start of the reclamation process; two possible worst-case scenarios – one with reclamation starting along the south of 7L7 and one with reclamation starting simultaneously along the south of 7L7 and 7L6; and a post reclamation scenario where all tailings material has been removed to expose bare ‘red earth’. The dispersion of particulate matter was modelled up to a distance of 6 km from a central point between the three TSFs.

It should be noted that isopleth plots reflecting the 24-hour averaging periods contain the 99th percentile or 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, and then averages those fifth-highest concentrations at each receptor across the three years of meteorological data for plotting. This is in line with the NAAQS which allows for four exceedances per year. Concentrations are presented in µg m-3.

Evaluation of the STATUS QUO Modelling Results

❖ The modelled highest daily average concentrations of PM10 indicate that exceedances of the national daily standard of 75µg/m3 can be expected on windy days up to approximately 1 350 m to the north-

west of 7L5, up to 800 m to the south and west of 7L7 and up to 650 m to the east of the TSFs. The affected areas include agricultural land, parts of the Marievale Bird Sanctuary, parts of the Marievale golf course and nearby residences.

❖ The modelled highest daily average concentrations of PM2.5 indicate that exceedances of the national daily standard of 40µg/m3 can be expected on windy days up to approximately 950 m to the northwest of 7L5, up to 550 m to the west of 7L7 and up to 200 m to the south of 7L7 and up to 250 m to the east of the TSFs. The affected areas include agricultural land, parts of the Marievale Bird Sanctuary, parts of the Marievale golf course and a few nearby residences.

❖ The modelling also indicates that annual average concentrations of both PM10 and PM2.5 may be expected to exceed the national standards of 40µg/m3 and 20µg/m3 respectively in areas up to 350 m from the TSFs.

Figure 7-61: Modelled prediction of highest 24-hour average PM10 concentrations resulting from the undisturbed 7L5, 7L6 and 7L7 TSFs.

Figure 7-62: Modelled prediction of the annual average PM10 concentrations resulting from the undisturbed 7L5, 7L6 and 7L7 TSFs.

Figure 7-63: Modelled prediction of the highest 24-hour average PM2.5 concentrations resulting from the undisturbed 7L5, 7L6 and 7L7 TSFs.

Figure 7-64: Modelled prediction of annual average PM2.5 concentrations resulting from the undisturbed 7L5, 7L6 and 7L7 TSFs.

Evaluation of the SOUTH CUT modelling results

The south cuts of the TSFs are the areas where the largest effects of the reclamation process may be expected. This is because all of the status quo emissions continue with the added increase in emissions resulting from the stripping of vegetation in a 40-metre wide band for reclamation.

7.8.1.3 Reclamation Starting at the 7L7 South Cut

❖ The modelling results indicate that the distance from 7L7 within which exceedances of the national standards may be expected is increased by up to approximately 150 m further than may be expected from the status quo emissions. ❖ The modelling also indicates that the area of exceedances around the other TSFs is unaffected.

7.8.1.4 Reclamation Starting at the 7L7 and 7L6 South Cuts Simultaneous

❖ The modelling results indicate that the distance from all of the TSFs within which exceedances of the national standards may be expected is increased by up to approximately 600 m further than may be expected from the status quo emissions.

❖ The difference is least to the east of 7L6 and greatest to the north of 7L5 and 7L6.

Figure 7-65: Modelled prediction of the highest 24-hour average PM10 concentrations resulting from starting reclamation at the 7L7 southernmost area.

Figure 7-66: Modelled prediction of the highest 24-hour average PM2.5 concentrations resulting from starting reclamation at the 7L7 southernmost area

Figure 7-67: Modelled prediction of the highest 24-hour average PM10 concentrations resulting from starting reclamation at both the 7L7 and 7L6 southernmost areas.

Figure 7-68: Modelled prediction of the highest 24-hour average PM2.5 concentrations resulting from starting reclamation at both the 7L7 and 7L6 southernmost areas.

Evaluation of the POST RECLAMATION modelling Results

Once reclamation is complete, and all tailings material has been removed, leaving bare ‘red earth’:

❖ No exceedances of the NAAQS are expected from emissions from the cleared areas.

❖ The surrounding areas should notice a marked decrease in ambient concentrations of PM10 and PM2.5 on windy days

Figure 7-69: Modelled prediction of the highest 24-hour average PM10 concentrations resulting from the Marievale Project area after reclamation is completed.

Figure 7-70: Modelled prediction of the highest 24-hour average PM2.5 concentrations resulting from the Marievale Project area after reclamation is completed.

Conclusions drawn from the modelling results

An air quality impact assessment was undertaken for the reclamation of the Marievale TSFs called 7L5, 7L6 and 7L7. PM2.5 and PM10 represent the main criteria pollutants of concern. The following conclusions can be made from the modelling results:

❖ Emissions from the TSFs in the current, undisturbed state are expected to be causing elevated ambient

concentrations of both PM10 and PM2.5 in downwind areas on windy days. Exceedances of the NAAQS may be expected up to 1 200 m to the west of 7L5, up to 800 m to the south and west of 7L7 and up to 650 m to the east of the TSFs. The affected areas include agricultural land, parts of the Marievale Bird Sanctuary, parts of the Marievale golf course and nearby residences. ❖ The modelling of the TSFs indicates that, if reclamation of the TSFs is conducted conservatively, with the band stripped of vegetation not exceeding a width of 40 m, the area of exceedances is likely to increase by approximately 150 m beyond the status quo emission situation. However, as reclamation progresses, if all mitigation methods are adhered to, the area of impact is expected to progressively decrease from the status quo emission situation. ❖ Once all tailings material has been removed down to ‘red earth’ ambient concentrations due to emissions from the denuded land are expected to be well below the NAAQS. ❖ The modelling indicates that the removal of the Marievale Project TSFs as a permanent pollution source will, in the long term, improve the air quality of the surrounding areas

7.9 Heritage and Palaeontology

Refer to Appendix D6 for the Heritage Impact Assessment (HIA)

Site Description in terms of Heritage Resources

The greater Springs-Nigel region is part of the Ekurhuleni Metropolitan Municipality and has been known historically as the Far East Rand. The region has been associated with historical mining activities since first coal was discovered in 1887 in the area of Nigel, followed shortly after by the discovery of gold and the establishment of the Nigel Gold Mining company. Existing surrounding land uses associated with the project area include a combination of:

❖ informal settlements, low-cost residential areas; ❖ community and municipal facilities; ❖ industrial areas; ❖ manufacturing and distribution facilities, commercial businesses; ❖ historical mine housing and historical mine infrastructure (slimes dams, shafts, derelict/abandoned buildings and water dams); ❖ illegal informal mining activities, formal mining activities; ❖ open land, and ❖ road infrastructure.

As a result, most of the Marievale Reclamation Project footprint overlays highly disturbed and developed terrain (including existing mining activities). There is also evidence of illegal mining and dumping activities within the project area. Overall, the accessibility of the project footprint area was variable, with some sections more accessible than others. Some areas were located on private property, including an SANDF Military base. In the accessible areas, the site detection visibility was relatively good, although other areas were obscured by dense vegetation (including areas of vlei land and areas with maize fields)

Previous Archaeological and Heritage Studies in and around the Study Area

The archival and historical research has revealed that the entire area of the proposed Marievale Reclamation project, on which the historical slimes dams are located, has been affected on a continual basis by historical mining activities, since c.1887 and was associated with several historical gold mine companies. These mining activities have continued to the present day, both formally and informally (illegal). The ground affected by the proposed environmental authorisation application is therefore extremely disturbed. There is also high potential for the existence of heritage sites associated with the historical mining activities (e.g. historical mining structures, historical residential structures, and historical graves and burial grounds).

Marievale Fieldwork Findings

A controlled surface survey was conducted on foot and by vehicle over a period of two days by a heritage team from PGS, including an archaeologist, heritage specialist and field assistant. The fieldwork was conducted on 8 and 15 January 2020. Due to the fieldwork being undertaken in summer after a period of prolonged rainfall,

large parts of the project area were covered with dense vegetation. The track logs (in dark red) for the survey are indicated in Figure 7-71.

The fieldwork identified 36 heritage features in total, four of which were burial grounds (three informal and one municipal), with the remainder of sites (32) being historical structures or remains associated with the historic mines or residential areas. The four burial ground sites (MV005, MV009, MV025 and MV033) are considered to have very high significance and would require mitigation measures. Of the historical structures, 12 sites are considered to have medium heritage significance and would require mitigation measures. The remaining historical structure sites are considered to be of low to no heritage significance and would require no mitigation, unless those likely to be 60 years or older (require a permit for destruction).

Most of the sites identified are located in the vicinity of the two pipeline alternatives, while a few are located in the region of the three slimes dams or the three processing plants.

Figure 7-71: Tracklogs of the fieldwork undertaken (red line)

Table 7-29: Medium to High Significance Heritage sites identified during the Marievale fieldwork

8 SITE7F7F HERITAGE HERITAGE LAT LON DESCRIPTION SIGNIFICANCE RATING NUMBER The site consists of an extensive historical residential area that is associated with the Marievale Gold Mining company. Some of the houses visible have brick walls, with corrugated iron roofs; a few are semi-detached. A few houses in a different style (red brick with concrete lintels) were also noted. There are also some newer buildings visible. The residential buildings are in different states of preservation. There are also several rectangular barrack/compound buildings which are constructed of modern brick. A GPS point was also taken at the entrance MV001-1 S 26,36283 E 28,49462 gate structure of the area, this was constructed of modern bricks with tall metal openwork gates. Site extent: approx. 151ha (estimated from satellite imagery). Historical maps show

structures present in the area by 1944, with a more structured layout by 1960 and more buildings depicted by 1976. The structures are associated with the Marievale Consolidated MV001-2 S 26, 35869 E 28,49684? Medium Grade IIIB Gold Mines.

MV001-3 S 26, 35777 E 28, 49661 Important: the entire residential area is now used as an SANDF military base. Access into the area was restricted by armed soldiers. The structures are rated as having a medium heritage significance with a heritage rating of IIIB.

8 Site in this context refers to a place where a heritage resource is located and not a proclaimed heritage site as contemplated under s27 of the NHRA.

8 SITE7F7F HERITAGE HERITAGE LAT LON DESCRIPTION SIGNIFICANCE RATING NUMBER The southern pipeline runs across the northern portion of this residential area. If some will would be impacted by the proposed pipeline and possible access road upgrade, further research into the site should be undertaken:

❖ Archival research on the village and associated Marievale Gold Mine ❖ Recording through photographs and possible drawings of selected structures to be impacted

SITE HERITAGE HERITAGE LAT LON DESCRIPTION SIGNIFICANCE RATING NUMBER The site consists of two old buildings, one of which could be a historical shop. Now called MV002 S 26,36169 E 28,49588 Medium Grade IIIB “Antioch Place of shelter”, occupied. The buildings are situated across the road (on the east of

8 SITE7F7F HERITAGE HERITAGE LAT LON DESCRIPTION SIGNIFICANCE RATING NUMBER the residential village/military base). Historical map dated 1960 shows three structures in this location.

The structures are rated as having a medium heritage significance with a heritage rating of IIIB.

If the structures are affected by upgrading the existing road for access to the 7L7 dump, then the structures may require recording.

SITE HERITAGE HERITAGE LAT LON DESCRIPTION SIGNIFICANCE RATING NUMBER

8 SITE7F7F HERITAGE HERITAGE LAT LON DESCRIPTION SIGNIFICANCE RATING NUMBER The site consists of an informal burial ground, which contains mainly stone-packed graves, a few have formal headstones, some of which are inscribed with dates and African names. The site is unfenced and very overgrown. It is situated very close to the edge of the existing gravel road (less than 10m). Approximately 50 graves could be present. A working quarry is located approx. 50m to the north. The site is located approx. 715m to 740m south of the proposed MV005-1 S-26.35703 E28.50209 pipeline to Daggafontein and the southern pipeline alternative. Site extent: approx. 521 m2.

High Grade IIIA Historical maps show no graves depicted in this location, but one structure is depicted on the 1966 map. MV005-2 S-26,35732 E28,50196

The graves are rated as having a high heritage significance with a heritage rating of IIIA.

It is recommended that the area is avoided and demarcated as a cemetery with at least a 50 metre buffer.

8 SITE7F7F HERITAGE HERITAGE LAT LON DESCRIPTION SIGNIFICANCE RATING NUMBER

SITE HERITAGE HERITAGE LAT LON DESCRIPTION SIGNIFICANCE RATING NUMBER The site consists of a historical substation comprising 2-3 brick buildings. According to signage MV006 S 26,35416 E 28,50182 on the fence this is/was the Marievale Gold Mine Substation. Medium Grade IIIB

8 SITE7F7F HERITAGE HERITAGE LAT LON DESCRIPTION SIGNIFICANCE RATING NUMBER Historical maps show structures present in this location by1966 and 1980.

The structures are rated as having a medium heritage significance with a heritage rating of IIIB.

The structures should be avoided but if they would be affected by upgrading the existing road for access to the 7L7 dump then they may require recording.

SITE HERITAGE HERITAGE LAT LON DESCRIPTION SIGNIFICANCE RATING NUMBER MV009-1 S 26,31166 E 28,48833 The site consists of a large burial ground, which contains approx. 300-400 graves. Most of the graves are stone-packed, with only a few having formal inscribed head stones (1953, 1964). High Grade IIIA

The site has been demarcated by several concrete markers. It is situated approx. 635m west of

8 SITE7F7F HERITAGE HERITAGE LAT LON DESCRIPTION SIGNIFICANCE RATING NUMBER MV009-2 S 26,31226 E 28, 48829 the proposed Daggafontein pipelines and approx. 1.20 km south of the proposed Daggafontein to Ergo pipeline. The site extent is 4509m2.

The burial ground is depicted on the historical maps (1944, 1960 and 1976) and is likely to contain several graves that are 76-60 years old.

The graves are rated as having a high heritage significance with a heritage rating of II!A.

It is recommended that the site is avoided and retained in situ with a buffer of at least 50m.

SITE HERITAGE HERITAGE LAT LON DESCRIPTION SIGNIFICANCE RATING NUMBER The site consists of a long rectangular building, constructed of brick, in the style of a mine MV011 S 26,3195 E 28,48230 Medium Grade IIIB compound. The brick-work shows header and stretcher bond which indicates that it is likely to

8 SITE7F7F HERITAGE HERITAGE LAT LON DESCRIPTION SIGNIFICANCE RATING NUMBER be 60 years or older. It is located approx. 1.38km east of the proposed Daggafontein to Ergo pipeline and approx. 1.23km west of the proposed Daggafontein pipeline.

Historical maps (1944, 1960) depict a compound building in this location, associated with the Vogelstruisbult Gold Mine. By 1976, only a portion of the building is depicted.

The finds provisionally rated as having a low heritage significance with a heritage rating of IIIB.

SITE HERITAGE HERITAGE LAT LON DESCRIPTION SIGNIFICANCE RATING NUMBER E28,49292 The site contains several buildings constructed of yellow brick that could be 60 years or older. Other more modern buildings are also present. However, the site is surrounded by a concrete palisade fence and is occupied by an organisation, “Vita Nova Centre”. It is located right on the MV018 S 26,29510 TCTA pipeline route just outside the Daggafontein plant footprint (122m west). Medium Grade IIIB

Historical maps (1944 and 1960) depict a few structures in this location.

8 SITE7F7F HERITAGE HERITAGE LAT LON DESCRIPTION SIGNIFICANCE RATING NUMBER The older structures are rated as having a medium heritage significance with a heritage rating of IIIB. The site should be avoided if possible.

SITE HERITAGE HERITAGE LAT LON DESCRIPTION SIGNIFICANCE RATING NUMBER The general area is a residential area containing several scattered houses. Some of them are historical in construction style and material: square, brick with hipped corrugated iron roofs. Mostly occupied. The houses on Nettleton Avenue are situated 138m west of the proposed TCTA pipeline (yellow).

MV021 S--26.258454° E 28.488012° Historical maps (from 1944, 1960 and 1976) depict scattered structures present in the area. Medium Grade IIIB

The structures are rated as having a medium heritage significance with a heritage grading of IIIB. If the site cannot be avoided by the proposed activities, mitigation measures may require:

▪ Archival research on the structures and photographic recording

8 SITE7F7F HERITAGE HERITAGE LAT LON DESCRIPTION SIGNIFICANCE RATING NUMBER ▪ An application for destruction must be lodged under s34 of the NHRA.

SITE HERITAGE HERITAGE LAT LON DESCRIPTION SIGNIFICANCE RATING NUMBER The site consists of a large informal community cemetery containing +400-500 graves. Most of the graves are dressed in packed stones, with some formal brick, concrete or granite dressings. A few (7) had headstones with legible inscriptions (African names and dates of 1949, 1951 and 1964). The site is situated approx. 740-7909m west of the proposed TCTA pipeline MV025-1 S-26.289832° E 28.484277° (yellow).

High Grade IIIA

MV025-2 S-26.288126° E 28.484368° The historical map dated 1960 depicts a “Kerkhof” in this location, and the 1976 map depicts a church and other structures. The 1944 map doesn’t depict graves but does depict a few structures to the south. It is likely that several graves are 60 years or older.

8 SITE7F7F HERITAGE HERITAGE LAT LON DESCRIPTION SIGNIFICANCE RATING NUMBER The site is rated as having a high heritage significance with a heritage grading of IIIA.

The area should be avoided and demarcated with at least a 50 m buffer

SITE HERITAGE HERITAGE LAT LON DESCRIPTION SIGNIFICANCE RATING NUMBER The site consists of a residential area containing historical houses, especially along Tarentaal Street (which is located between 35-60m East of the proposed Daggafontein to Ergo pipeline – purple).

MV028 S -26.306898° E 28.470073° Historical maps (from 1944-1960) depict structures in a residential area. No structures seem Medium Grade IIIB to be depicted close to the railway line.

The structures are rated as having a medium heritage significance with a heritage rating of IIIB.

8 SITE7F7F HERITAGE HERITAGE LAT LON DESCRIPTION SIGNIFICANCE RATING NUMBER If the site cannot be avoided by the proposed activities, mitigation may include:

▪ Archival research on the area and possible photographic documentation ▪ An application for destruction must be lodged under s34 of the NHRA.

SITE HERITAGE HERITAGE LAT LON DESCRIPTION SIGNIFICANCE RATING NUMBER The site consists of two red-brick historical sub-station buildings, with a sign reading “Eskom Vlakfontein Substation”. There is also a name on the building which says, “Springs Reduction”. The property is fenced. The substation is situated approx. 154m south-west of the existing MV031 Ergo pipeline. (GPS from S -26.312896° E 28.433102° Medium Grade IIIB road) Historical maps (from 1944, 1960 and 1976) depict a corresponding structure in this location.

The structure is rated as having a medium heritage significance with a heritage grading of IIIB.

8 SITE7F7F HERITAGE HERITAGE LAT LON DESCRIPTION SIGNIFICANCE RATING NUMBER The site should be avoided by the proposed activities:

SITE HERITAGE HERITAGE LAT LON DESCRIPTION NUMBER SIGNIFICANCE RATING The site consists of the several historical house structures, within the same property as the substation at MV031. The house structures are located approx. 133m south-west of the existing Ergo pipeline (blue).

MV032 S -26.313533° E 28.433905° Historical maps (from 19 44, 1960 and 1976) depict structures present in this location. Medium Grade IIIB

The structures are rated as having a medium heritage significance with a heritage rating of IIIB.

The site should be avoided by the proposed pipeline.

8 SITE7F7F HERITAGE HERITAGE LAT LON DESCRIPTION SIGNIFICANCE RATING NUMBER

SITE HERITAGE HERITAGE LAT LON DESCRIPTION SIGNIFICANCE RATING NUMBER The site comprises a large municipal cemetery. It is surrounded by a concrete palisade fence. Approx. 328m west of the existing pipeline to Ergo route (blue).

The historical map from 1944 does depict a grave in this approximate location, however, the maps dated 1960 and 1976 do not depict any graves or structures in this location. [check later MV033 S-26.307200° E 28.413067° High Grade IIIA maps)

The cemetery is rated as having a high heritage significance with a heritage rating of IIIA.

It is recommended that the area is avoided with at least a 50m buffer.

8 SITE7F7F HERITAGE HERITAGE LAT LON DESCRIPTION SIGNIFICANCE RATING NUMBER

SITE HERITAGE HERITAGE LAT LON DESCRIPTION SIGNIFICANCE RATING NUMBER The site comprises the remaining sections of a mining compound. The structures are rectangular brick buildings with corrugated iron roofs. Solar geysers have been added to some of the roofs. The site extent is approx. 7.65ha (from satellite imagery). It is located approx. MV036 140m south-west of the existing Ergo pipeline. (from S -26.283109° E 28.403317° Medium IIIB road) Historical map (1976) depicts a large number of compound structures in this location. There are no structures depicted on the 1960 map. However, the structures could be between 44- 59 years old. The structures are rated as having medium heritage significance with a heritage rating of IIIB.

8 SITE7F7F HERITAGE HERITAGE LAT LON DESCRIPTION SIGNIFICANCE RATING NUMBER

SITE HERITAGE HERITAGE LAT LON DESCRIPTION SIGNIFICANCE RATING NUMBER The site contains two structures: an old building currently used as a training centre and an old church. The site is situated approx. 120m east of the existing Ergo pipeline (blue).

MV037 The historical map dated 1960 depicts two structures in this location, marked K for “kerk” and (from S -26.287525° E 28.387384° the 1976 map depicts the area as built-up with one structure marked as Winkel (but not clear). Medium Grade IIIB road) The structures are rated as having a medium heritage significance with a heritage rating of IIIB.

The site should be avoided by the proposed pipeline

8 SITE7F7F HERITAGE HERITAGE LAT LON DESCRIPTION SIGNIFICANCE RATING NUMBER

Defined Heritage Impacts

7.9.1.1 Historical Structures – Residential and Non-Mining

Of the 32 historical structures identified, 12 were single or groups of residential buildings or other non-mining related structures (e.g. electrical sub-stations). Nine of these sites were in a good state of preservation and had a medium heritage significance with a heritage grading of IIIB (MV001, MV006, MV018, MV021, MV023, MV028, MV031, MV032, MV036).

The impact significance before mitigation on these nine historical residential structures will be Medium negative before mitigation. Implementation of the recommended mitigation measures will modify this impact rating to an acceptable LOW negative.

The remaining sites consisted of dilapidated or demolished remains and had a low or negligible heritage significance and were rated as Not Conservation Worthy. Most of these will not require any mitigation measures. However, a destruction permit may be required if the structure remains are likely to be 60 years or older

7.9.1.2 Historical Structures – Mining

Of the 32 historical structures identified, 14 were single or groups of mining-related buildings. However, only three of these sites were in a good state of preservation and had a medium heritage significance with a heritage grading of IIIB (MV003, MV011 and MV036).

The impact significance before mitigation on these three historical mining structures will be Medium negative before mitigation. Implementation of the recommended mitigation measures will modify this impact rating to an acceptable LOW negative.

Most of the remaining sites consisted of the demolished or ruined remains of mining structures, which had a low or negligible heritage significance and were rated as IIIC or Not Conservation Worthy. Most of these will not require any mitigation measures. However, a destruction permit may be required if the structure remains are likely to be 60 years or older

7.9.1.3 Burial Grounds and Graves

The three informal burial grounds and the municipal cemetery all have a high heritage rating and a heritage grading of IIIA.

The impact significance before mitigation on the cemetery and graves sites will be High negative before mitigation. Implementation of the recommended mitigation measures will modify this impact rating to an acceptable Medium to Low negative.

It should be noted that, in addition to the three informal burial grounds identified during the fieldwork for this project, there is some potential for historical graves of mineworkers to exist under the three slimes dams that

are proposed for reclamation. An example of a mineworker burial ground exposed after reclamation of a slimes dam is known from the Crown Mines/ Langlaagte area in Johannesburg. According to the archival research by the archaeologist involved in the rescue excavations of some of these graves, this was apparently a common practice (Anton Pelser 2012 and pers.comm.; Esterhuysen et al 2018).

7.9.1.4 Recent and Modern Structures

Seven of the identified sites are recent/modern structures or remains (MV008, MV013, MV019, MV022, MV030, MV035, MV037). They all have a negligible heritage rating and a grading of Not Conservation Worthy.

The impact significance before mitigation on these sites will be Low negative and no mitigation measures are required from a heritage perspective.

Defined Paleontological Impacts

According to the desktop PIA compiled by Butler (2019), the proposed Marievale Tailings Storage facilities and two pipeline alternatives in the Ekurhuleni Metropolitan Municipality, Gauteng Province are underlain by the Malmani Subgroup, (Chuniespoort Group, Transvaal Supergroup), Dwyka Group, Vryheid Formation (Ecca Group) and Karoo Dolerite Suite. According to the PalaeoMap of South African Heritage Resources Information System the Palaeontological Sensitivity of the Malmani Subgroup is High, the Dwyka Group has a Moderate Palaeontological Sensitivity, the Vryheid Formation has a Very High Palaeontological Sensitivity and Karoo Dolerite Suite has a Zero Palaeontological Sensitivity. The expected duration of the impact is long term. In the absence of mitigation procedures (should fossil material be present within the affected area) the damage or destruction of any palaeontological materials will be permanent as fossils are irreplaceable. Impacts on palaeontological heritage during the construction phase could potentially occur are regarded as having a high possibility. This would usually require a field-based assessment to be undertaken on the specific impacts expected.

However, since the proposed pipelines will be constructed overland or within existing servitudes and road reserves, it is anticipated that there should be no excavation into the underlying geology. In addition, the area around the three slimes dams has been disturbed extensively by previous mining-related activities. Therefore, the impacts on palaeontological heritage are anticipated to be minimal and it is recommended that an application for exemption from the standard requirement for a field-based Palaeontological Impact Assessment be made to SAHRA

7.10 Social

Please refer to Appendix D7 to view the Social Impact Assessment (SIA)

The International Principles for Social Impact Assessment (SIA) (2015:iv) defines SIA as being “the processes of analysing, monitoring and managing the intended and unintended social consequences, both positive and negative, of planned interventions and any social change processes invoked by those interventions”.

The following social parameters were considered to determine the likely social impacts:

❖ Demographic processes refer to the movement and structure of the local community; ❖ Geographic characteristics refer to the processes that affect the land uses of the local area; ❖ Economic processes refer to the economic activities with the affected project area; ❖ Socio-cultural wellbeing- refer to the processes that affect the local culture of an affected area, i.e. the way in which the local community live; and ❖ Institutional, legal, political and equity-refers to the processes that affect service delivery of the study area.

Without repeating what is contained in the SIA, this section aims to describe the socio-economic characteristics of the potentially affected area to develop an understanding of the broad social and economic conditions of the affected environment. 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.

Project Area Demographics and Population characteristics

The project area falls under the jurisdiction of City of Ekurhuleni Metropolitan Municipality (EMM).

The EMM IDP (2017/2018- 2020/2021:13) states that the City of Ekurhuleni has an estimated population of 3 379 1042, up 200 634 people from 3 178 470 in the 2011 census. The population growth rate has slowed from as high as 4% in the period between 1996 and 2001 to 2.47% between 2001 and 2013. An important feature of the growth in the Ekurhuleni population is the net migration into the City as together with Tshwane and Johannesburg are the largest recipients of in-migration in the country.

EMM has a total surface area of 1 979 square kilometres and it is reported that there are about 1 707 people per square kilometre (Community Survey 2016). The City of Ekurhuleni comprises of communities such as Tembisa, Katlehong, Vosloorus, Duduza, Daveyton and Thokoza that collectively house over 68% of the City’s total population (ibid).

The population of the City is mostly made up of an age group between 18-64, this group accounts for about 66% of the population.

Housing and Household Demographics

According the (Community survey, 2016) there are approximately 1 299 490 households within EMM, about one-quarter of the figure in Gauteng: 4 951 135. Over 18% of the households in the are considered to be informal dwellings (shacks) which is slightly higher compared to the rate of informal dwellings in entire Province Gauteng (17.74%).

A residential area (Happiness Village) approximately 1.8 kilometres south of the proposed reclamation site was identified. Happiness Village is situated about 200 metres from Marievale and although it is on state land it is separate from Marievale and used by civilians for residential purposes.

Household sizes in Happiness Village varies for each household. In some cases, 4-5 individuals occupy a shack and more than 5 people can be found in some households. James (2014: 55) states that household sizes play one of the major roles in determining the living conditions and standards in poor communities. Depending on their incomes, household sizes determine the amount of resources consumed and the surplus accumulated. Bigger households dwelling in small housing spaces such as shacks are often affected by more problems compared to smaller ones due to easy disease spread and contamination

Figure 7-72: Type of dwelling within the project area

Education

Education is central to community wellbeing, has strong linkages to future economic development and can be a strong driver of retention of workforce. According to the IDP (2018:37), about half of the population within EMM have completed matric or higher which is about 20% higher compared to the national statistic. Approximately 4% of the population have post graduate qualification. The number of people with 'matric and a certificate/diploma' increased with an average annual rate of 4.82%, with the number of people with a 'matric and a Bachelor's' degree increasing with an average annual rate of 6.3% (ibid).

In terms of Happiness Village, key informant interviews determined that most individuals from 99 households have a formal schooling, and some have post matric qualification. Transport issues and drop-out rates remain key concerns for this community.

Economy and Livelihoods

According to the Community survey 2016, about 49% of the population is employed which is almost similar to Gauteng (51%) below provides an overview of the employment status within City of Ekurhuleni (Figure 7-73).

In terms of sector of employment, about 78% of the population within Ekurhuleni is employed in the formal sector and about 9% is employed in the informal sector. The structure of the City of Ekurhuleni’s economy is dominated by four sectors: manufacturing, finance and business services, community services and general government and to a lesser extent the trade and hospitality sector. In recent years there has been a significant decline in the success of the manufacturing sector.

Population by employment status 60%

49% 50%

40%

30% 27% 20% 20%

10% 4% 0% 0% Discouraged work- Employed Other not economically Unemployed Unspecified seeker active

Figure 7-73: Population by employment status (Source: Census 2011)

Most respondents from Happiness Village area are unemployed, however some are employed by local businesses such Brikor and domestic sectors. Military sector was identified for residents currently residing in the military barracks.

7.10.1.1.1 Zama-zama operations

During SIA interviews with community members in Happiness Village, the team was referred to Mr Maphotha (not his real name)- a renowned leader for illegal mining operations in the area. Mr Maphotha indicated that he has been actively involved in illegal mining for over ten years. He indicated that he does not need to go underground to extract gold, since only shallow holes are made to access available gold. He views illegal mining as his form of livelihood which enables him to provide for his family based in Mozambique. He adds that in a good week he can make between R 1 000-R1 500.

7.10.1.2 Local Employment Status

Based on the interviews with community members, it was noted most of the residents are unemployed and others are self-employed. Self -employed residents resorted to survivalist enterprises, which represent a set of activities undertaken by people unable to secure regular wage employment or access to an economic sector of their choice. Survivalist enterprise in this community include spaza-shop, illegal mining and child minding

and garden services. For those who are working, their incomes are insufficient and too irregular to cover for both domestic services and transportation costs.

Respondents relayed their challenges with regards to putting food on the table. In probing the livelihood strategies, it was clear that most households were not earning salaries as they were not in a job to help them improve their awful conditions. To cope with such unstable livelihood conditions, residents are constantly hunting down temporary jobs.

Service Delivery in the Project Area

Majority of the Marievale project area is surrounded by informal settlements / villages. Informal settlements in South Africa are characterized by poor sanitation perpetuated by lack of service delivery (James, 2014), this has resulted in prevailing poor environmental conditions in settlements. Happiness Village is not unique to this situation, with approximately 99 shacks relying on two water access taps and lack of adequate sanitation is evident. The Happiness Committee indicated that communities must constantly fetch water from the communal taps to fill up their water buckets to be used household purposes. This was also raised as a concern for the elderly group

As with water accessibility, reliable electricity supply is infrequent. Residents of the Happiness Village must rely on fossil fuels such as wood, gas for cooking, solar panels and candles for lighting.

Sanitation service delivery is lacking; however, respondents of Happiness Village indicate that refuse was collected on regular basis by a private company.

Vulnerable Groups

A vulnerable population can be defined as a subgroup of the overall population who are at higher risk of problem(s). They may be defined by age, gender, ethnicity, health status etc. Some examples of vulnerable populations are children, economically disadvantaged and disabled, elderly, culturally and people with mental illness (Wells et al, 2006: 35).

Communities within the project area are considered vulnerable due to high levels of unemployment and poverty which poses significant challenges when related to the quality of life. People living below the poverty line, women, the elderly, children and people with disabilities represents vulnerable groups. Surrounding community members from the Happiness Village have been identified as the vulnerable group. Happiness Village is a former mining village and military base situated between Nigel and Springs. The area comprises of formal and informal settlement. Some residents had been living there for almost two decades. Some are former soldiers, military employees and their families; others have no connection to the SANDF. The plight of residents living in the informal settlement has been widely reported in the media. Most of the families that were evicted from the Military residence now live in squalor in a makeshift informal settlement. The socio- economic state of informal settlement dwellers renders them vulnerable since they are generally economically disadvantaged, thus their resilience to the unhealthy environment they are often exposed to is very low.

Anticipated Social Impacts

The following social impacts are anticipated for the Marievale Project:

Table 7-30: Anticipated Social Impacts of the proposed project

POSITIVE IMPACTS NEGATIVE IMPACTS Job creation and skills development Creation of informal settlements Increased economic revenue Safety impacts Availability of alternative land uses. Disruption in daily movement patterns Town planning and residential interface Intrusive impacts Impacts associated with future end land use

7.10.1.3 Job Security and Skills Development

Receptors: Host community and residents within the broader parts of City of Ekurhuleni Metropolitan Municipality.

In terms of economic benefits associated with the proposed project, it is expected that approximately 45 – 50 employment positions will be made available and some personnel from the current Ergo operations will be deployed for the proposed project. Skills development and capacity building for workers is perceived as a positive impact. However, due to the relative short length of the construction phase it is doubtful that comprehensive skills training programmes could be undertaken over the short-term.

It should be noted that the number of opportunities offered is subject to the company’s financial situation and employment need. According to the company’s existing SLP (2018-2022), Ergo intends to implement the following strategic actions with regards to bursaries and experiential work:

❖ Allowing individuals to work as apprentices to skilled people on the mine; ❖ Providing equitable access to bursary and internship opportunities; and ❖ Integrating in the internship candidate or the bursar as operating member of the company should suitable vacancies exist.

The company as a subsidiary of DRDGold, has access to the Ergo Business Development Academy (EBDA).The academy is a facility that has been launched by Ergo Mining (Pty) Ltd to address the critical shortage of skills in the country, create jobs, empower people and uplift the quality of life of all South Africans (http://www.ebda.co.za/).

7.10.1.4 Stimulation of Economic Growth

Receptors: Surrounding communities and residents within the City of Ekurhuleni Metropolitan Municipality

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. Most 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 Ergo.

Stimulation of economic growth is not only limited to multiplier effects stimulated by capital expenditure and construction activities. According to the existing company’s SLP (2018-2022:76), the company recognises that entrepreneurship is an effective and viable strategy to overcome the current desperate economic situation. In light of this, the company has a Broad-Based Entrepreneurship Programme that is open to all individuals that have a business, interested in improving their profitability or those who are interested in starting their own businesses.

In addition, the proposed project could also have an impact on government revenues and expenditures. In particular, payment of business and personal tax could contribute to government revenue at a national level, while rates and payment for services could strengthen the income base of the local municipality.

7.10.1.5 Availability of Alternative Land Uses

From an environmental and social perspective, the reclamation of the Marievale TSFs has a positive impact in terms of opening the land for alternative land uses. As indicated by van Rensburg (2016: 367), 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 area and also to release the land back for redevelopment.

Rehabilitation envisaged for the project has been explained in Section 3.5.3.

The positive impact associated with the removal of the dumps can only materialise once the land has been successfully rehabilitated and obtain an approved radiation land clearance certificate in terms of the National Nuclear Regulations Act, (Act No. 47 of 1999) from the National Nuclear Regulator (NNR). Therefore, this study has assessed the impact (availability of alternative land use) for post decommissioning.

7.10.1.6 Creation of Informal Settlements

Although the removal of the dumps is seen as a positive impact, there is a possibility that the land (post reclamation process) may be viewed as vacant land. Given the current socio-economic dynamics in Happiness Village, i.e., high unemployment rate, forceful evictions, unstable livelihood and back yarding, these could be key drivers for unplanned development and the rise of informal settlements. The more an informal settlement continues to grow, the more socio-economic conditions will continue to deteriorate (with more people trying to access the same amount of limited resources), and the more the quality of life of other local (neighbouring) residents will be affected. If not carefully managed, this type of uncontrolled development is also likely to result in an increase in an array of social pathologies.

7.10.1.7 Safety Impacts for Employees

Receptors: Surrounding communities, Zama-zamas and Ergo employees.

It is also possible that an opportunistic criminal element may occur due to the increased activities in certain areas during construction and operational phases. Illegal miners are active in the project area, they are perceived to be part of the Happiness Village. During interviews with key informants, Mr Mathoma, a renowned Zama-zama in the area, indicated that it is difficult for them to access gold from the TSFs as the sand is made up of fine material and requires advanced technology to reclaim gold. He admitted that they often work on areas surrounding the TSFs, this could pose health and safety risk for Zama-zamas during the construction and operational phases.

Stakeholders have raised the concern about spillages of pipes and the associated impacts. The concern of pipeline spillages is addressed by the company stating that key areas of the Ergo operation and network are under 24-hour telemetric surveillance to optimise procedures, including safety and security. Pipeline spillages are thus monitored, with spillage paddocks in place along the pipeline network for this eventuality(https://www.drdgold.com/ergo-showcase/.

7.10.1.8 Disruption in Movement Patterns

Receptors: Happiness village-Zama-zama, Stone Crusher company, Marievale Military personnel/ Bird watchers visiting the Marievale Bird Sanctuary

It is anticipated that there will be an increase in traffic volumes on existing traffic network. The increase in the number of road users is not an impact, but a change process. The number of construction vehicle road users may change the movement patterns of other road users in such a way that their movement patterns are disrupted, their safety levels are impacted on, and their stress and/or frustration levels increase.

Depending on access routes that are used, construction vehicles could impact on the safety and daily movement patterns of residents in the surrounding communities. Disruptions in daily living and movement patterns for road users could manifest in the form of traffic resulting in short term intrusion and safety hazards.

7.10.1.9 Town planning and residential interface

Receptors: Prospective developers, property owners, City of Ekurhuleni Metropolitan Municipality

During interviews with stakeholders and the associated public participation process it has been indicated that various developers have a desire to develop within the proposed project area. It is understood that the proposed project (especially the pipelines) could interface with other proposed mining operations, residential development, agricultural activities and privately owned properties. It is not anticipated that the proposed project will hamper on the proposed developments, however careful planning and effective consultation with the relevant parties (ie) Ilangabi Coal Mine, Proposed Bloemendal Mine, Brikor proposed mining of clay, sand and coal, Vereeniging Properties, private landowners and the Marievale Military personnel is undertaken.

Careful planning and zoning is required if different land uses are to co-exist. This is largely the responsibility of local government, but it is informed by regularly liaising with relevant parties.

7.10.1.10 Intrusive Impacts: Traffic and Air Quality

In terms of Traffic Impacts, the receptors are: Road users, Happiness Village, Marievale military barracks.

According to the Traffic statement (2020:13) the planned activities are supported from a traffic flow and traffic safety viewpoint, provided that the recommendations detailed in the Traffic Statement and Site Traffic Assessment (2020) are implemented.

In terms of Air Quality, the receptors are the affected areas include agricultural land, parts of the Marievale Bird Sanctuary, parts of the Marievale golf course and nearby residences - Happiness Village and the Marievale military barracks.

Based on the discussions held with residents from Happiness Village, the dust from the TSFs was not a major challenge as they are further away from the dumps. The effects of dust are mostly experienced during windy days, since wind action often blows clouds of dust. This statement is confirmed the Air Quality Impact Assessment report (2020:55) that emissions from the TSFs in the current, undisturbed state are expected to be causing elevated ambient concentrations of both PM10 and PM2.5 in downwind areas on windy days.

It is noted in the AQIA report that as reclamation progresses (provided all if all mitigation methods are adhered to) the area of impact is expected to progressively decrease from the status quo emission situation. Findings from the AQIA further state that the removal of the Marievale Project TSFs as a permanent pollution source will, in the long term, improve the air quality of the surrounding areas.

7.10.1.11 Impacts on Ecosystem Services

It should be noted that informants did not mention their reliance on the ecosystem services, only one respondent raised a concern about the impacts the proposed project might pose on the birdlife which could impact on recreational services enjoyed by birdwatchers who often visit the area. Although the value of ecosystem services was not highlighted by informants, this study will highlight the importance of the ecosystem services by drawing insight from Mharakurwa (2016) study.

Mharakurwa’s (2016) study found that people from the surrounding communities in Marievale are interacting with the wetland in different ways. The provisioning services from the Blesbokspruit wetland to the surrounding communities include water used for both domestic and agricultural activities. Both subsistence and commercial farming are taking place along the wetland (crop farming and livestock rearing). The wetland is therefore providing a safety net to disadvantaged households who are able to supplement their food. The wetland also supports high biodiversity (flora and fauna) such as within the Marievale Bird sanctuary. Marievale as a bird reserve offers recreational and aesthetic services to the surrounding community.

Identified Social Risks

There are three identified social risks associated with the Marievale project. These are:

1. The lack of Basic Services and security of tenure; 2. Infringement of Human Rights; and 3. Tensions over limited employment opportunities.

The current challenges in Happiness Village are not created as a result of Ergo’s operational Impacts – this means that they are not a direct consequence of Ergo’s operations and do not require a direct intervention from Ergo but government intervention is required. While Ergo is required to address operational impacts directly, understanding the current dynamics in the project area is also necessary to underpin a strong social licence to operate.

The discussion of issues relating to infringement of human rights does not suggest that Ergo must conduct a Human Right Impact Assessment but rather to assist Ergo to understand the social dynamics of the communities in its immediate footprint. The Social Impact Assessment has made the following recommendation for Ergo to consider:

❖ From a social perspective, it is recommended that a community forum is established to provide the stakeholders - including the applicant with a platform to discuss issues of concern, identify risks and opportunities

Employment opportunities have a potential to draw communities together based on a shared purpose. Limited employment opportunities (especially in areas with a high unemployment rate) may produce divisions and tension in communities. Community cohesion and social capital is not the sole responsibility of the applicant; however, it is closely linked to the company’s social license to operate. Unrealistic demands are usually a result of a lack of information and communication between mining companies and local communities (SA Human Rights Commission, 2016). To avoid potential tensions over job opportunities, the SIA recommends the following:

❖ Consider working with community representatives to prepare open and transparent recruitment procedures that are disclosed to community members; ❖ Formalise local employment procedures in Human Resources policies (HR Management Plan) and contractors’ agreements; ❖ Use various mechanisms to advertise employment opportunities in neighbouring communities; and ❖ Although this application is not a Mining Right Application, it is recommended that as part of Ergo’s approved SLP programme and the Ergo Business Development Academy (EBDA, the contractor makes use of local labour as and when required.

Cumulative Impacts

There are three identified cumulative social impacts associated with the Marievale project. These are:

1. Economic Investment; 2. Industry Training; and 3. Tensions over limited employment opportunities.

It is anticipated that the proposed projects will result in increased expenditure, which will most likely benefit smaller businesses, suppliers and contractors. Economic investment and industry training are rated as positive cumulative impacts for the proposed project. An enhancement measure to ensure that the anticipated positive cumulative impacts materialise, the applicant advised to work in close collaboration with local business chambers and EMM’s LED departments to improve business development in the local area.

An increase in nuisance factors namely, noise, air pollution and increased number of vehicles could further impact negatively on the sense of place for some receptors. It is likely that the levels of traffic usage will increase particularly during the construction phase, when there are construction vehicles travelling to and from the construction sites. This increase in traffic will have a cumulative impact for other surrounding mines, businesses and private individuals using the roads in the area.

7.11 Noise Impact Assessment

Refer to Appendix D8 of this EIA report for a review of the Noise Study.

The current Environmental Sound Character

Season plays a pivotal role in influencing the sound character of a project site. Wind, temperature and humidity are able to influence sound propagation across the landscape during daytime and night-time.

Wind: Wind alters sound propagation by the mechanism of refraction; that is, wind bends sound waves. Wind nearer to the ground moves more slowly than wind at higher altitudes due to surface characteristics such as hills, trees, and man-made structures that interfere with the wind.

Temperature: Generally, sound propagate better at lower temperatures (down to 10oC) and with humidity being constant, a decrease in temperature from 30oC to 10oC would increase the sound level at a listener 600m away with ±2.5 dB (at 1 000 Hz).

Humidity: The effect of humidity on sound propagation is quite complex, but effectively relates how increased humidity changes the density of air. With temperature being the same, an increase in humidity from 20% to 80% would increase the sound level at a listener 600 m away by ±4 dB (at 1 000 Hz).

Ambient Sound Measurements

Ambient (background) noise levels were measured at appropriate times in accordance with the South African National Standard SANS 10103:2008 "The measurement and rating of environmental noise with respect to land use, health, annoyance and to speech communication". The standard specifies the acceptable techniques for sound measurements including:

❖ type of equipment (Class 1); ❖ minimum duration of measurement; ❖ microphone positions and height above ground level; ❖ calibration procedures and instrument checks; and ❖ supplementary weather measurements and observations.

Short-term measurements were collected at a total of three locations. The measurements were collected during the day and night of 23 January 2020. A summary of the sound levels as well as the measurement locations are illustrated on Table 7-31.

One class-1 sound level meter was used for measurements. The internal clock was set to GMT+2. The sound level meter would measure “average” sound levels over 10 minutes periods, save the data and start with a new 10 minute measurement until the instrument was stopped. Refer to Appendix B for photos of measurement localities.

The equipment defined in Table 7-31 was used for gathering data. A summary of the sound levels (various sound descriptors) are presented in

Table 7-31: Equipment used to gather data

EQUIPMENT MODEL SERIAL NO CALIBRATION

SLM Svan 977 34160 Mar 2019 Microphone ACO 7052E 54645 Mar 2019 Calibrator Quest CA-22 J 2080094 June 2019

* Microphone fitted with the RION WS-03 outdoor all-weather windshield.

Figure 7-74: Measurement Localities

Table 7-32: Summary of ambient sound levels measured onsite

SHORT TERM MEASUREMENT LOCATION NAME LA,MAX LAIEQ LA,MIN LAEQ,F LA90,F COMMENTS dBA dBA dBA dBA dBA90 Daytime measurements (Cloudy, light winds with gusts. Air temperature 32 oC, 25%)

Birds dominating sound. Engine or plant (crushers) running in distance with mobile equipment audible at times (Marievale Crushers – Aggregate quarry). Grinding at KEMSTSL01 (d) 52.1 43.8 37.9 42.3 39.2 times from Marievale Military base (MMB). Voices at times. Soft breeze but no wind-induced noises. Hammering for a few seconds from MMB. Birds dominating. Sounds from aggregate crusher in area constant. Bird close to KEMSTSL02 (d) 60.2 47.3 34.2 42.8 37.1 microphone raising sound level. Birds dominant noise source with wind induced noises at times. Crusher audible KEMSTSL03 (d) 54 40.1 32.3 38.2 35 during quiet periods. Dogs barking from MMB at times. Vehicles audible in distance at times. Voices from MMB at times.

Night-time measurements (Clouds in sky with gusty winds. Air temperature 26 oC, 51%)

Crickets dominant noise source. Light winds with some wind-induced noises with KEMSTSL01 (n) 60.1 42.5 27.6 41.1 31.3 wind gusts. Dogs barking in far distance. Music from MMB just audible. Mining activities from Ilangabi Colliery just audible. Crickets dominant noise source. Light winds with wind-induced noises with wind KEMSTSL02 (n) 51.6 39.2 28.7 36.4 29.3 gusts significant at times. Mining activities from Ilangabi Colliery just audible. Vehicle travelling on road in far distance. Crickets dominant noise source. Light winds with wind-induced noises. Mining KEMSTSL03 (n) 57.3 37.3 26.8 35.7 30.3 activities from Ilangabi Colliery just audible. Truck travelling on road in far distance.

Ambient Sound Findings

A summary of noise levels based on the onsite measurements are illustrated on Figure 7-74, with the sound levels and observations defined in Table 7-32. The following can be summarized from this data:

❖ Considering the average daytime LAeq,f descriptor, ambient sound levels are less than sound levels typical of a rural noise district. ❖ Considering the average night-time LAeq,f descriptor, ambient sound levels are higher than a typical rural noise district. This higher ambient sound levels are mainly due to natural sounds. ❖ No access could be gained into the MMB to assess the ambient sound levels in the vicinity of NSD01. It is assumed the ambient sound levels will be similar at these dwellings than at the other measurement locations. Noise levels may be slightly higher due to the operational colliery in the area. ❖ Considering the sound levels measured, the acceptable zone sound level will be typical of a rural noise district.

Potential Noise Sources

Maximum noise generated can be audible over a large distance. However, it is generally of very short duration for reclamation projects.

If maximum noise levels however exceed 65 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 7-33.

Average or equivalent sound levels are another factor that impacts on the ambient sound levels and are the constant sound levels that the receptor can experience. Typical sound power levels associated with various activities that may be found at an industrial (such as a mine or reclamation operation) construction site are presented in Table 7-34.

Table 7-33: Potential maximum noise levels generated by construction equipment

EQUIPMENT IMPACT MAXIMUM OPERATIONAL NOISE LEVEL AT GIVEN DISTANCE CONSIDERING POTENTIAL MAXIMUM NOISE LEVELS 9 DESCRIPTION8F8F DEVICE? SOUND POWER LEVELS (DBA) (CUMULATIVE AS WELL AS THE MITIGATORY EFFECT OF POTENTIAL BARRIERS OR OTHER MITIGATION NOT INCLUDED –

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 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 Front End Loader 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 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

Table 7-34: Potential equivalent noise levels generated by various equipment

EQUIVALENT (AVERAGE) OPERATIONAL NOISE LEVEL AT GIVEN DISTANCE CONSIDERING EQUIVALENT (AVERAGE) SOUND POWER EMISSION LEVELS

EQUIPMENT DESCRIPTION SOUND LEVELS (CUMULATIVE AS WELL AS THE MITIGATORY EFFECT OF POTENTIAL BARRIERS OR OTHER MITIGATION NOT INCLUDED –

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

(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 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 JBL 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 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 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

Project Noise Rating Levels for Marievale

Noise contours are illustrated from 35 (night-time) and 45 (daytime) dBA upwards. This may represent the potential audibility of the project activities. Three different colours are used to illustrate the potential noise impact, namely:

❖ Green: Zone where the noises due to reclamation activities may change ambient sound levels sufficiently for surrounding receptors to detect this change. This change in ambient sound levels may be measurable and audible; ❖ Yellow: Zone where reclamation activities may be clearly audible and potentially disturbing during quiet periods. Receptors may start to complain about noises. The noise-generating activities will change the ambient sound levels and this change can be measured; ❖ Red: Noise level exceed the permissible noise limit adopted in this report during the relevant time period (night or day). Noises will be clearly audible and the noise level can be considered disturbing. ❖ For the zone outside the green area: noises from the reclamation activity are unlikely to change the ambient sound levels even though the reclamation activities may be audible at times.

This assessment mainly focusses on dump 7L7, as dumps 7L6 and 7L5 are located far from any potential noise sensitive receptors.

7.11.1.1 Proposed Construction Phase Noise Impact

This section investigates the conceptual construction activities of the project. Two conceptual noise models were developed considering the activities, namely:

❖ Construction of the proposed reclamation infrastructure. It was assumed the plant infrastructure will be developed at the lowest location at the dump to allow the slurry to run down from the mining area to the pump infrastructure; and ❖ Temporary noises associated with maintenance and repair of the pipeline (arbitrary location).

The applicant confirmed that construction activities will only take place during the day. It is assumed that construction equipment would be operating under full load (generate the most noise) and that atmospheric conditions would be ideal for sound propagation. This is likely the worst-case scenario that can occur during the construction phase of the project. Noise rating level contours are illustrated in:

❖ Figure 7-76 (daytime) – Construction of plant infrastructure at Dump 7L7.

7.11.1.2 Operational Phase Noise Impact

This section investigates the conceptual operational activities of the Marievale Project. A conceptual noise model was developed considering potential noises due to the operation of the slurry pumps, vibration screens, and a water cannon. This assessment considers both day- and night-time activities. This is likely the worst

10 case scenario9F9F that can occur during the operational phase of the project. Noise rating level contours are illustrated in:

❖ Figure 7-77 (daytime) – Reclamation activities at Dump 7L7; and ❖ Figure 7-78 (night-time) – Reclamation activities at Dump.

7.11.1.3 Potential Decommissioning Noise Impacts

The potential for a noise impact to occur during the decommissioning phase will be much lower than that of the construction and operation phases and noise from the decommissioning phase will not be investigated further.

10 Night time operations will not take place for this project

Figure 7-75: Aerial image indicating potentially noise-sensitive developments close to proposed reclamation activities

Figure 7-76: Projected conceptual daytime construction noise levels – Pump station infrastructure at Dump 7L7

Figure 7-77: Projected conceptual daytime operational noise rating levels – Reclamation at Dump 7L7

Figure 7-78: Projected conceptual night-time operational noise rating levels – Reclamation at Dump 7L7

Conclusions of the Noise Impact Study

The potential noise rating levels were calculated using a sound propagation model. Conceptual scenarios were developed for the construction and operational phase with the output of the modelling exercise indicating:

❖ a low risk of a noise impact for daytime construction activities that are further than 200m from NSD; ❖ a medium risk of a noise impact for construction activities that are closer than 100m from NSD; ❖ a low risk for day-time operational activities (subject to the implementation of mitigation measures recommended for construction phase); and ❖ a potential medium risk for night-time operational activities.

This assessment considered potential day-time and night-time reclamation activities (potential worse-case scenario). Mitigation options included both management as well as technical measures. Options to reduce the noise impact during the construction phase include:

❖ All employees and contractors should receive induction that includes an environmental awareness component (noise). This is to allow employees and contractors to realize the potential noise risks that activities (especially night-time activities) pose to the surrounding environment; ❖ Ensure a good working relationship between Ergo and all potentially noise-sensitive receptors. Communication channels should be established to ensure prior notice to the sensitive receptor if work is to take place close to them (especially if work is to take place within 200 m from them at night); ❖ Ensure that equipment is well maintained and fitted with the correct and appropriate noise abatement measures. Engine bay covers over heavy equipment could be pre-fitted with sound absorbing material. Heavy equipment that fully encloses the engine bay should be considered, ensuring that the seam gap between the hood and vehicle body is minimised.

Should night-time reclamation activities take place, the following measures are recommended:

❖ Minimising night-time activities within 400m from any residential dwellings; ❖ Compliance with the Noise conditions of the Environmental Management Plan that covers: o Potential mitigation measures as defined in this report; o Formal register where receptors can lodge any noise complaints; and o Noise measurement protocol to investigate any noise complaints.

The commitment from the mine to consider reasonable mitigation if the noise complaint investigation indicates the validity of a noise complaint. These measures could include steps ranging from process changes, development of barriers or enclosure of the noise source and even relocation (if no other feasible alternatives exist).

7.12 Traffic Statement

Refer to Appendix D9 of this EIA report for a review of the Traffic Statement.

The current road networks

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. A description of the existing road network is given in Table 7-35.

Table 7-35: Surrounding Road Network

ROAD NAME ROAD MANAGING ROAD FUNCTION GENERAL CLASS AUTHORITY EXISTING ROADS Nigel Springs 2 Gauteng Connecting the larger areas of This road is to the west of the Road (R51) Department of Springs, Dunnottar and Nigel sites and no alignment changes (K179) Roads and are planned for this road Transport Nigel 3 Ekurhuleni Connecting the Nigel Springs Road This road is to the south and Marievale Metropolitan (R51) and Dunnottar with the west of the sites and will provide Road Municipality housing area of Marievale. access to the site. This is a short road of approx. 3.6km in length FUTURE ROADS K181 3 Gauteng This road is planned to be aligned This road is planned approx. Department of north to south and will be connecting 1.8km to the west of the sites. Roads and Welgedacht Road near Bakerton with Transport the mining areas of Largo Colliery and Grootvlei Proprietary Mines with the N17, Daggafontein, Marievale and Nigel. K136 3 Gauteng This road is planned to be aligned east This road is planned to the north Department of to west from the R42 south of Endicott and west of the sites. Roads and to the N3 and Vosloorus. There will be Transport a discontinuity at the K181 with the alignment being stopped at a T‐ junction approx. 1.5km to the west of

ROAD NAME ROAD MANAGING ROAD FUNCTION GENERAL CLASS AUTHORITY EXISTING ROADS Dump 7L5 and continued approx. 1.3km to the northwest of Dump 7L5 from another T‐junction

Figure 7-79: Future roads planned for the project area

Existing Traffic Demand

This report discussion is limited to the access position of the site. The traffic generated by the site do does not warrant traffic surveys as the new traffic 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 period of the development will be during the weekday AM and PM peak traffic hours. The impact will be less than 15kph on each site, even during the construction phase.

Future Traffic Demand

Considering the existing and future planned surrounding road network, as well as the fact that the surrounding area is mostly undeveloped, with large portions reserved for environmental protection, traffic growth at the proposed access position to the site will be average (2.0% ‐ 3.0%). There are no future roads planned near the access position, according to the Ekurhuleni Road Master Planning and Gautrans Master Planning.

Trip Generation Conclusions

The expected trips to be generated by the proposed activities were based the maximum processing capacity of the Ergo Plant and COTO TMH17. The document recommends the following splits for Heavy Industry (reclamation and rehabilitation) and trips are based on details provided by the client for the construction period:

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

Based on the project description provided during the EIA phase, the expected trips to be generated by the development during the weekday AM and PM peak traffic hours are indicated in Table 7-36 below. It is expected that all trips will be primary trips, and no adjustment factors were applied for mixed land‐ use, low vehicle ownership or transit.

Table 7-36: Development Peak Hour Generated Trips

TMH17 AM PEAK PM PEAK LAND USE EXTENT CODE In Out Total In Out Total Reclamation and 120 Heavy Industry 9 3 12 3 7 10 rehabilitation

Proposed Sites Access:

Two (2) accesses to the sites are proposed:

❖ Access to Site 1 (Dumps 7L5 and 7L6) is proposed by means of an existing small gravel access road from the Zincor Plant Access Road, this road will need to be widened to 10m with a 2% camber, as indicated on ❖ Figure 7-80. This road will have to be realigned when the construction of the K135 is started, to comply with the minimum access spacing of 600m required by Gautrans for class 2 roads. ❖ Access to Site 2 (Dump 7L7) is proposed by means of a proposed access road from the Marievale Sanctuary Road, as indicated on Drawing 19059/KP/01. Traffic from the main road and established mining activities will have the right of way and a ‘STOP’ condition will be implemented for the proposed access road. Proposed access details are shown on Figure 7-81.

Typically, the entrance lane width should be at least 5 m to accommodate a Single Unit + Trailer Heavy Vehicle. For light vehicles a minimum width of only 3.5m is required. Both access roads are proposed as 10m wide gravel roads. It can be concluded that the proposed Access layout will be able to accommodate the aforementioned vehicles.

Figure 7-80: Key plan and road sign locations

Figure 7-81: Proposed access road details

7.12.1.1 Parking on site

The Ekurhuleni Metropolitan Municipality Town‐Planning Scheme was consulted to determine the parking requirement for the proposed development. The number of parking bays required is not specified for a reclamation project. The number of bays required are based on the number of employees expected to be on the site and is shown in Table 7-37 below.

Table 7-37: Site parking requirements

LAND USE EXTENT PARKING REQUIRED NO. BAY NO. BAYS

PROPOSED PROVIDED Reclamation 10‐22 vpd ‐ 10 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

Access Safety (For all Sites)

The following safety measures are proposed by the Traffic impact specialists:

❖ The current Speed limit of 60km/h will be maintained, and the proposed Speed Limit Sign (R201_B) is to be erected on the Marievale Sanctuary Road within 200m to the west of the proposed access road position. ❖ The proposed Heavy Vehicles Turning Sign (W344) is to be erected on the western side of the proposed access road at least 100m from the proposed access road position. ❖ The Sight Distance from the proposed access positions are 180m in both directions, this is more than the required sight distance for a 60km/h road as per COTO TMH16. ❖ In the event of slow‐moving vehicles (abnormal sized trucks or loaded trucks) exiting the proposed access road, a Flag man will need to warn the traffic of the approaching danger and control the traffic approaching the proposed access road to provide a safe and acceptable gap for the truck(s) to enter the traffic. ❖ U‐turn space will need to be provided on the sites to avoid dangerous movements on the road or within the sites. ❖ A minimum stacking space of 24m (space for one truck) will need to be provided at the proposed accesses in front of any gate or boom, to avoid queueing onto the road and disrupting the traffic, as shown in the Queueing Analysis.

CHAPTER 8: IMPACT ASSESSMENT 8.1 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 DHSWS’s Best Practice Guideline: G4 – Impact Prediction, there are three basic components that define an impact (or a risk). Figure 8-1 represents the relationship between these three components and their influence on the significance of a certain impact of a project.

Figure 8-1: Impact prediction model.

The impact significance rating system is presented in Table 8-1, Table 8-2 and Table 8-3, 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.

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

Use these definitions to define the consequence in Part B.

Table 8-1: Consequence rating definitions.

IMPACT DEFINITION CRITERIA CHARACTERISTICS Substantial deterioration or harm to receptors; receiving environment has an inherent value to stakeholders; receptors of Magnitude Major - impact are of conservation importance; or identified threshold often exceeded

IMPACT DEFINITION CRITERIA CHARACTERISTICS Moderate/measurable deterioration or harm to receptors; Moderate - receiving environment moderately sensitive; or identified threshold occasionally exceeded

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

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

Moderate improvement; within or better than the threshold; or Moderate + 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 Spatial scale or May be defined in various ways, e.g. cadastral, catchment, Regional population topographic National/ International Nationally or beyond Short term Up to 18 months.

Duration Medium term 18 months to 5 years

Long term Longer than 5 years

Part B: Determining Consequence Rating

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

Table 8-2: 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 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

Part C: Determining Significance Rating

Rate significance based on consequence and probability.

Table 8-3: Significance rating methodology.

PROBABILITY (OF CONSEQUENCE NEGATIVE CONSEQUENCE POSITIVE EXPOSURE TO Low Medium High Low Medium High IMPACTS) Definite Medium Medium High Medium Medium High Possible Low Medium High Low Medium High Unlikely Low Low Medium Low Low Medium

8.2 Impacts and Cumulative Impacts Identified

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

Construction Phase

Ergo will commence with the pre-construction and construction phase for its project related infrastructure in line with its approved environmental authorisations. During the construction phase the following activities will take place on site:

Table 8-4: Summary table of the Activities associated with the construction phase of the project

ACTIVITY DESCRIPTION Pre-Construction 1 Conduct a pre-construction Radiation walk-over survey 2 Removal of vegetation and site clearance 3 Preparation of access roads should this be required 4 Initiation of a community forum for engagement throughout the project life cycle Construction Phase 5 Employment of workers (minimal) 6 Operation of construction machinery and vehicles 7 Temporary storage of construction materials and hazardous material such as contaminated soil 8 Instatement of waste management and dust control measures on site 9 Desilting of existing facilities 10 Instatement of traffic signage, access, parking bays

8.2.1.1 Biodiversity (Fauna, Flora and Herpetology)

The following potential impacts on the biodiversity were considered for the construction phase of the proposed development. This phase refers to the period during construction when the proposed features are constructed or upgraded. This phase is considered to have the largest direct impact on biodiversity. The following potential impacts to terrestrial biodiversity were considered:

❖ Destruction, further loss and fragmentation of the remaining natural vegetation community, including CBA: Important and ESA, protected areas (Nature reserve and Ramsar site); ❖ Habitat disturbance; ❖ Spread and/or establishment of alien and/or invasive species, especially plants; ❖ Erosion; ❖ Oil spills from the construction vehicles; ❖ Loss of protected species; and ❖ Displacement of faunal community due to habitat loss, direct mortalities, reduced dispersal/migration and disturbance (road collisions, noise, dust, vibration and possible poaching).

Table 8-5: Assessment of significance of potential construction impacts on Biodiversity

NATURE OF IMPACT 1: Construction of roads: Loss of areas classified as CBA and ESA; Disturbance of habitat and species of ecological importance; Displacement of fauna; Loss of migration corridors; Direct loss of floral species/vegetation types and biodiversity; Alien vegetation encroachment; Erosion. 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) Medium term Short 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) Irreversible Irreplaceable loss of resources: (Yes or No) No Can impacts be enhanced: (Yes or No) Yes Residual impacts

❖ Storm water flooding; ❖ Change of hydrology of the Blesbokspruit and polluting Marievale Nature Reserve.

Mitigation measures

❖ Demarcate the project area and avoid surrounding areas; ❖ Dust-reducing mitigation measures must be put in place and must be strictly adhered to. This includes wetting of exposed soft soil surfaces; ❖ An erosion control plan must be compiled and implemented;

❖ Faunal species must be allowed to move out of the area unharmed; ❖ Install signs restricting the speeds of the vehicles; ❖ Install culverts below the roads to assist with erosion control, leave green corridors for species to move along.

Table 8-6: Assessment of significance of potential construction impacts on Biodiversity

NATURE OF IMPACT 2: Temporary infrastructure: Clearance of vegetation, dust, encroachment by alien vegetation, displacement of fauna and endemic 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 term) Medium term Short 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) Irreversible Irreplaceable loss of resources: (Yes or No) No Can impacts be enhanced: (Yes or No) Yes Residual impacts

❖ Human encroachment into surrounding areas, including litter and sewage.

Mitigation measures

❖ The temporary infrastructure needs to be placed in the low sensitivity areas; ❖ Implementation of alien invasive plant management plan needs to be continued during operation to prevent the growth of invasive on cleared areas; ❖ Dust-reducing mitigation measures must be put in place and must be strictly adhered to. This includes wetting of exposed soft soil surfaces; ❖ An erosion control plan must be compiled and implemented; ❖ Allow species to move out of the area safely, if they do not move on their own get a qualified person to assist with the relocation of the species; ❖ Waste management must be a priority and all waste must be collected and stored adequately. It is recommended that all waste be removed from site on a weekly basis to prevent rodents and pests entering the site.

Table 8-7: Assessment of significance of potential construction impacts on Biodiversity

NATURE OF IMPACT 3: Slurry receiving facility, screening facility at pump station: Clearance of vegetation, dust, encroachment by alien vegetation, displacement and destruction of fauna and endemic plant species, habitat loss for species, loss of migratory corridors, mortalities of faunal 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 Medium term Short 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) Irreversible Irreplaceable loss of resources: (Yes or No) No Can impacts be enhanced: (Yes or No) Yes Residual impacts

❖ Drainage of the polluted water into the surrounding area; ❖ Diseases due to the increase in the dust levels; ❖ Faunal mortality (direct and indirectly); ❖ Groundwater pollution; ❖ Loss of ecosystem services.

Mitigation measures

❖ All dumping and storage must be within the existing infrastructure footprint and the low sensitivity areas; ❖ Implementation of alien invasive plant management plan needs to be continued during operation to prevent the growth of invasive on cleared areas; ❖ Dust-reducing mitigation measures must be put in place and must be strictly adhered to. This includes wetting of exposed soft soil surfaces; ❖ An erosion control plan must be compiled and implemented; ❖ Allow species to move out of the area safely, if they do not move on their own get a qualified person to assist with the relocation of the species; ❖ Demarcate the area to be utilised and restrict any activities into surrounding habitats; ❖ A stormwater management plan which has been compiled must be implemented.

Table 8-8: Assessment of significance of potential construction impacts on Biodiversity

NATURE OF IMPACT 4: Powerlines and transformers: Loss of avifauna species due to electrocutions, bird strikes, disturbance of fauna and flora species due to construction of lines, loss of 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 Long term Medium term term) Magnitude (Major, Moderate, Minor) Major Moderate 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

❖ Faunal mortality (direct and indirectly).

Mitigation measures

❖ If any faunal are recorded during construction, activities should temporarily cease, and time permitted for the species to move away. In the event the species does not move away (voluntarily), the species must be removed safely from the area and relocated to a suitable area that will not be directly disturbed by the project; ❖ Bird flappers must be installed on the powerlines; ❖ Spikes must be installed on the poles to prevent bird electrocutions; ❖ An erosion control plan must be compiled and implemented; ❖ An alien invasive species control plan must also be compiled and implemented for the footprint of the project area.

Table 8-9: Assessment of significance of potential construction impacts on Biodiversity

NATURE OF IMPACT 5: Slurry pipeline Option A: Clearance of vegetation, dust, encroachment by alien vegetation, displacement of fauna and endemic plant species, habitat loss for species, loss of migratory corridors, mortalities of faunal species, Destruction, further loss and fragmentation of the remaining natural vegetation community, including CBA: Important and ESA. 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 Short 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) Irreversible Irreplaceable loss of resources: (Yes or No) No Can impacts be enhanced: (Yes or No) Yes Residual impacts

❖ Drainage of the polluted water into the surrounding area; ❖ Faunal mortality (direct and indirectly); ❖ Groundwater pollution; ❖ Loss of ecosystem services.

Mitigation measures

❖ A spill management plan must be put in place to ensure that should there be any chemical spill out or over that it does not run into the surrounding areas; ❖ If any faunal are recorded during construction, activities should temporarily cease, and time permitted for the species to move away. In the event the species does not move away (voluntarily), the species must be removed safely from the area and relocated to a suitable area that will not be directly disturbed by the project; ❖ Implementation of alien invasive plant management plan needs to be continued during operation to prevent the growth of invasive on cleared areas; ❖ Dust-reducing mitigation measures must be put in place and must be strictly adhered to. This includes wetting of exposed soft soil surfaces; ❖ An erosion control plan must be compiled and implemented; ❖ Demarcate the area to be utilised and restrict any activities into surrounding habitats.

Table 8-10: Assessment of significance of potential construction impacts on Biodiversity

NATURE OF IMPACT 6: Slurry pipeline Option B: Clearance of vegetation, dust, encroachment by alien vegetation, displacement of fauna and endemic plant species, habitat loss for species, loss of migratory corridors, mortalities of faunal species, Destruction, further loss and fragmentation of the remaining natural vegetation community, including CBA: Important and ESA, protected areas (IBA, Ramsar, Nature reserve); 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 Short term term) Magnitude (Major, Moderate, Minor) Major Moderate Probability (Definite, Possible, Unlikely) Definite Possible Calculated Significance Rating (Low, High Medium 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

❖ Drainage of the polluted water into the surrounding area ❖ Faunal mortality (direct and indirectly) ❖ Groundwater pollution ❖ Loss of ecosystem services

Mitigation measures

Table 8-11: Assessment of significance of potential construction impacts on Biodiversity NATURE OF IMPACT 7: Protected Species: Loss of habitat for protected species, mortalities of protected species Impact Rating Without Impact Rating With Mitigation Mitigation Impact Status: (positive or negative) Negative Negative Extent (Local, Regional, International) Regional Regional Duration (Short term, Medium term, Long Long term Medium term term) Magnitude (Major, Moderate, Minor) Major Moderate Probability (Definite, Possible, Unlikely) Definite Possible Calculated Significance Rating (Low, High Medium 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

❖ Loss of protected species

Mitigation measures

❖ A qualified zoologist must accompany the construction team (before any work commence) to ensure that none of the species of conservation concern are present during construction; ❖ Should Bullfrogs be found in the project area, all activities should cease, and a relocation of these species needs to be performed after obtaining permits from GDARD and a relocation plan can be compiled and implemented; ❖ A 200-metre buffer has been added to the wetland delineations due to the sensitivity of these areas as well as the SCC that rely on these habitats; ❖ All staff must complete induction, where species of conservation concern are highlighted. Should these species be observed during the operational phase this must be reported to the EAP and necessary actions must be followed.

8.2.1.2 Wetlands

A risk assessment was conducted in line with Section 21 (c) and (i) of NWA to investigate the level of risk posed by the project namely the reclamation of gold bearing tailings sediments from the project area as well as the construction, operation and decommissioning of pipelines proposed to transport tailings material.

Table 8-12 lists the potential risks posed by the project to wetlands within the project area as well as those within the 500 m regulated area surrounding it. The risk matrix provides risk significance ratings for scenarios both without and with successful implementation of mitigation. Of greater significance will be the operational risks associated with the reclamation of the site as it is situated within close proximity to a Ramsar wetland (Blesbokspruit) which will be directly be impacted upon by the reclamation process. As such, a severity rating of 5 is mandatory following the DHSWS risk assessment protocol.

Three highly probable and potentially significant impacts were identified for which mitigation is limited and the residual impact considered Moderate. These include loss of wetland and hydromorphic vegetation habitat through site excavation, exacerbated contamination of downstream watercourses through the upheaval and liberation of accumulated toxins trapped in the sediments and sedimentation and increased turbidity in downstream watercourses. However, these impacts ought to be temporary and should only last the lifetime of the reclamation activities with the long-term benefits associated with rehabilitation outweighing the short- term impacts associated with reclamation (in theory). However, this is entirely contingent on the responsible party's commitment (in this case, Ergo) to rehabilitation.

Table 8-12: Potential risk posed by the reclamation activities (including pipelines)

RISK ASSESSMENT COMPLETED BY ANDREW HUSTED

PHASE ACTIVITY ASPECT IMPACT

Traffic

Clearing vegetation (outside wetland areas)

Clearing wetland vegetation

Construction of laydown yard

Construction of Pipelines Stormwater management ❖ Loss of aquatic/wetland habitat; Operation of machinery & equipment ❖ Erosion of watercourses; Storage of chemicals, mixes and fuel ❖ Loss of indigenous vegetation; ❖ Exotic vegetation proliferation; Ablution facilities ❖ Sedimentation of the watercourses; ❖ Flow sediment equilibrium change; Construction Phase Excavations within wetlands ❖ Water quality impairment; Traffic ❖ Flow modifications; Clearing vegetation (outside riparian and wetland ❖ Loss of biodiversity; areas) ❖ Loss of ecosystem services; and Clearing wetland vegetation ❖ Loss of hydromorphic soils.

Construction of laydown yard Reclamation Site Set-Up Digging Cut-Off Trenches

Operation of machinery & equipment

Storage of chemicals, mixes and fuel

Ablution facilities

Blasting and pumping of tailings by means of Reclamation of Waste hydraulic system Impoundments Spills and Leaks Operational Phase Management of Pipeline Operation of Pipelines Impeding Flows

Excavation within wetlands

Decommissioning Decommissioning Pipelines Removal of Pipelines

Increased Traffic

Increased Traffic Rehabilitation of Tailing Facilities Reshaping the Landscape Rehabilitation Rehabilitation of Pipeline Footprint Increased Traffic Areas Reshaping the Landscape

Table 8-13: DWS Risk Impact Matrix for the proposed project

SEVERITY CONSEQUENCE FLOW WATER SPATIAL ASPECT HABITAT BIOTA SEVERITY DURATION CONSEQUENCE REGIME QUALITY SCALE CONSTRUCTION PHASE

Construction of pipelines

Traffic 1 1 2 1 1,25 1 1 3,25 Clearing vegetation (outside 1 1 2 2 1,5 1 1 3,5 wetland areas) Clearing wetland vegetation 5 5 5 5 5 1 1 7

Construction of laydown yard 2 2 2 2 2 1 2 5

Stormwater management 2 2 2 2 2 2 2 6 Operation of machinery & 2 2 2 2 2 1 1 4 equipment Storage of chemicals, mixes and 1 2 2 2 1,75 3 3 7,75 fuel Ablution facilities 1 2 2 2 1,75 3 3 7,75

Excavations within wetlands 5 5 5 5 5 1 1 7

Reclamation site set-up

Traffic 3 2 3 3 2,75 2 1 5,75 Clearing vegetation (outside 1 1 2 2 1,5 1 1 3,5 wetland areas) Clearing wetland vegetation 5 5 5 5 5 2 1 8

Construction of laydown yard 2 2 2 2 2 2 2 6

Digging cut-off trenches 5 5 5 5 5 2 1 8 Operation of machinery & 2 2 2 2 2 2 1 5 equipment Storage of chemicals, mixes and 1 2 2 2 1,75 3 3 7,75 fuel Ablution facilities 1 2 2 2 1,75 3 3 7,75

Table 8-14: DWS Risk Impact Matrix for the proposed project continued

FREQUENCY FREQUENCY LEGAL WITHOUT WITH ASPECT OF DETECTION LIKELIHOOD SIG. OF IMPACT ISSUES MITIGATION MITIGATION ACTIVITY Construction phase

Construction of pipelines

Traffic 1 2 1 1 5 16,25 Low Low

Clearing vegetation (outside wetland areas) 1 2 1 1 5 17,5 Low Low

Clearing wetland vegetation 1 3 5 2 11 77 Moderate Moderate

Construction of laydown yard 2 2 1 2 7 35 Low Low

Stormwater management 2 3 1 2 8 48 Low Low

Operation of machinery & equipment 1 2 1 1 5 20 Low Low

Storage of chemicals, mixes and fuel 2 2 1 3 8 62 Moderate Low

Ablution facilities 2 2 5 2 11 85,25 Moderate Low

Excavations within wetlands 2 4 5 3 14 98 Moderate Moderate

Reclamation site set-up

Traffic 1 2 5 2 10 57,5 Moderate Low Clearing vegetation (outside riparian and 1 2 1 1 5 17,5 Low Low wetland areas) Clearing wetland vegetation 1 3 5 2 11 88 Moderate Moderate

Construction of laydown yard 2 2 5 3 12 72 Moderate Moderate

Digging cut-off trenches 2 2 5 3 12 96 Moderate Moderate

Operation of machinery & equipment 1 2 1 2 6 30 Low Low

Storage of chemicals, mixes and fuel 2 2 5 3 12 93 Moderate Low Moderate Ablution facilities 2 2 5 3 12 93 Low

8.2.1.3 Surface Water

During the construction phase vegetation will be cleared and temporary infrastructure will be erected. The construction phase will be less than 5 years. The activities and impacts that are likely to occur during the construction phase are summarised in Table 8-15.

Table 8-15: Summary of activities and impacts for the construction phase

ACTIVITY IMPACT DESCRIPTION Erosion and wash off of exposed soils leading to Removal of vegetation and alteration to the topography. siltation in down gradient watercourses.

Table 8-16: 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 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 Short term 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

❖ Clearance of vegetation must be limited as far as possible; ❖ The SWMP must be implemented as a first step during the construction phase; and ❖ Water quality sampling must be implemented upstream and downstream of construction sites. It is recommended that Total Suspended Solids (TSS) and turbidity are included in the current water quality monitoring programme.

8.2.1.4 Groundwater

Historical negative groundwater quality impacts have been observed in boreholes around the Marievale dumps. The groundwater presents salt and metal concentrations that exceed SANS 241 Drinking Water Limits for some elements, as well as the Blesbokspruit Water Quality Objectives.

The sampled surface and groundwater indicate existing quality impacts, but due to dilution and precipitation the quality impacts seem to reduce further away from the slimes dams and sand dumps. No additional impact is expected on the groundwater quantity and quality during the construction phase. Construction will be conducted in a relatively short period compared to the operational and post-decommissioning phases. Additional impacts on the groundwater environment are therefore rated as Low (Table 8-17).

Drilling of dedicated groundwater monitoring boreholes downstream from the two TSF reclamation areas are recommended to quantify the current groundwater quality and level status and define a better understanding of possible surface water – groundwater interactions. The boreholes need to be in place at least 1 year before excavation starts and monitoring has to happen on a quarterly basis. Based on good time-series monitoring data the impacts can be defined and delineated and additional mitigation measures implemented.

In the long term, the reclamation of the tailings and sand dumps will have a positive impact on the groundwater environment as the current negative pollution sources will be removed and with time the pollution concentrations will reduce.

Table 8-17: Construction Phase water quality impacts.

NATURE OF THE IMPACT: Impact on the local groundwater quality Impact Rating with Impact Rating Without 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, Low Low High) Reversibility: (Reversible or Irreversible) Reversable Irreplaceable loss of resources: (Yes or No) No Yes. Combined impact with other mining activities in the area, Cumulative impacts (yes or no) including the Vlakfontein Quarry, industrial activities and waste and sanitation management problems. Residual Impacts

❖ None.

Mitigation measures

NATURE OF THE IMPACT: Impact on the local groundwater quality ❖ Implement a groundwater monitoring programme at dumps 7L5, 7L6 and 7L7 before reclamation starts. Additional groundwater monitoring boreholes are required between Sites 1 and 2 and downstream from Site 2 to effectively measure the current groundwater status, impacts of the reclamation activities on the groundwater environment and changes in groundwater qualities and levels post decommissioning. Refer to Section 13.1 of the Groundwater report. ❖ Boreholes are also required along the eastern perimeter to monitor water quality in the shallow alluvial zone. ❖ Develop sound surface runoff management plans to ensure that all dirty runoff is contained and diverted to the paddocks. No pooling of water on surface allowed. The groundwater table is near surface and contaminated seepage will quickly enter the underlying aquifers if not managed effectively. ❖ Ensure that paddocks are designed to contain all dirty water generated during the reclamation process, to prevent overflows and spillages.

8.2.1.5 Air Quality

An air quality impact assessment was undertaken to evaluate the impact on ambient air quality caused by the

Marievale Project. PM2.5 and PM10 represent the main criteria pollutants of concern.

Table 8-18: All project Phases - Air Quality impacts.

IMPACT ASSESSMENT MATRIX Stripping of vegetation from the surface of TSFs and wind erosion from exposed areas causes the Impact emission of particulate matter into the air, thus increasing existing ambient air concentrations of Description 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

Activity With Mitigation Moderate negative: Although the reclamation of the TSFs is expected to cause exceedances of Magnitude the NAAQS, the undisturbed TSFs are already significant emission sources. Long Term: There is a possibility of the ambient air concentrations exceeding the NAAQS for the Duration duration of reclamation activities taking place. Local: Worst-case conditions may lead to the NAAQS being exceeded over approximately 600 m Spatial Scale further from the project footprint than the current status quo emission Consequence Medium Probability Possible: The undisturbed TSFs are already emitting PM. Significance Medium

Restriction of the stripped band to a width of 40 metres; restriction of the use of storage piles; Mitigation 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 Marievale Project TSFs are predicted to only produce a Cumulative limited increase in ambient concentrations of PM10 and PM2.5. In the long term, removal of the Impact dumps will improve the air quality of the surrounding areas.

8.2.1.6 Heritage and Palaeontology

Defined Heritage impacts are discussed in Section 7.9.4 of Chapter 7. Impacts are expected to occur in construction.

The fieldwork identified 38 heritage features in total, four of which were burial grounds (three informal and one municipal), with the remainder of sites (33) being historical structures or remains associated with the historic mines or residential areas. Note that two sites are the existing TCTA Plant and Ergo Plant, (MV019 and MV037 respectively), which previously contained historical structures, however most of these have been replaced by modern structures over time. The four burial ground sites (MV005, MV009, MV025 and MV033) are considered to have extremely high significance and would require mitigation measures. Of the historical structures, 12 sites are considered to have medium heritage significance and would require mitigation measures. The remaining historical structure sites are considered to be of low to no heritage significance and would require no mitigation, unless those likely to be 60 years or older (require a permit for destruction).

Most of the sites identified are located in the vicinity of the two pipeline alternatives, while a few are located in the region of the three slimes dams or the three processing plants.

Table 8-19: Impacts on possible heritage resources during the construction phase: Historical Structures – Mining

BEFORE MITIGATION AFTER MITIGATION Affected Impact Cumulative Mitigation measures No. Activity Spatial Spatial Environment Description Magnitude Duration Consequence Probability SIGNIFICANCE Impact / Recommendations Magnitude Duration Consequence Probability SIGNIFICANCE Scale Scale Construction Damage or Demarcation and Proposed Medium MV001 - destruction avoidance; pipeline Long Term Site or Term > 18 Site or 1 historical of historical Moderate - Medium Definite Medium Yes documentation, Minor - Low Possible Low (Southern > 5 years Local months < Local village residential permit required if alternative) 5 years structures alteration/destruction Damage or Demarcation and Medium MV002 - Two destruction avoidance; Long Term Site or Term > 18 Site or 2 historical Access road of historical Minor - Medium Possible Medium Yes documentation, Minor - Low Possible Low > 5 years Local months < Local buildings residential permit required if 5 years structures alteration/destruction Damage or Medium MV006 - Demarcation and destruction Long Term Site or Term > 18 Site or 3 Marievale Access road Moderate - Medium Definite Medium Yes avoidance; Minor - Low Possible Low of historical > 5 years Local months < Local Substation documentation structures 5 years MV012 - Pipeline Destruction Medium Municipal Short Term (Proposed of historical Term > 18 Site or No mitigation Site or 4 building Minor - Low Unlikely Low Yes Minor - < 18 Low Unlikely Low Daggafontein structure months < Local required Local (demolished months to Ergo) remains 5 years remains) Damage or Demarcation and Medium MV018 - destruction avoidance; Daggafontein Long Term Site or Term > 18 Site or 5 Historical of historical Moderate - Medium Possible Medium Yes documentation, Minor - Low Possible Low plant > 5 years Local months < Local houses residential permit required if 5 years structures alteration/destruction Damage or MV021 - destruction Short Term Historical Pipeline Long Term Site or Demarcation and Site or 6 of historical Moderate - Medium Unlikely Low Yes Minor - < 18 Low Unlikely Low houses (TCTA) > 5 years Local avoidance Local residential months (scattered) structures Damage or MV023 - destruction Short Term Historical Pipeline Long Term Site or Demarcation and Site or 7 of historical Moderate - Medium Unlikely Low Yes Minor - < 18 Low Unlikely Low houses (TCTA) > 5 years Local avoidance Local residential months (scattered) structures MV028 - Damage or Demarcation and Medium Historical Pipeline destruction avoidance; Long Term Site or Term > 18 Site or 8 houses (proposed of historical Moderate - Medium Definite Medium Yes documentation, Minor - Low Possible Low > 5 years Local months < Local (residential Ergo) residential permit required if 5 years area) structures alteration/destruction

MV029 - Pipeline Destruction Medium Short Term Remains of 2 (proposed of historical Term > 18 Site or No mitigation Site or 9 Minor - Low Possible Low Yes Minor - < 18 Low Possible Low railway Daggafontein structure months < Local required Local months structures to Ergo) remains 5 years Damage or MV031 - Pipeline Short Term destruction Long Term Site or Demarcation and Site or 10 Vlakfontein (existing Moderate - Medium Unlikely Low Yes Minor - < 18 Low Unlikely Low of historical > 5 years Local avoidance Local substation Ergo) months structures Damage or MV032 - Pipeline destruction Short Term Moderate Long Term Site or Demarcation and Site or 11 Historical (existing of historical Medium Unlikely Low Yes Minor - < 18 Low Unlikely Low - > 5 years Local avoidance Local houses Ergo) residential months structures MV036 - Damage or Historical Pipeline Short Term destruction Moderate Long Term Site or Demarcation and Site or 12 church and (existing Medium Unlikely Low Yes Minor - < 18 Low Unlikely Low of historical - > 5 years Local avoidance Local training Ergo) months structures centre

Table 8-20: Impacts on possible heritage resources during the construction phase: Burial Grounds and Graves

BEFORE MITIGATION Mitigation AFTER MITIGATION Affected Impact Cumulative No. Activity Spatial measures / Spatial Environment Description Magnitude Duration Consequence Probability SIGNIFICANCE Impact Magnitude Duration Consequence Probability SIGNIFICANCE Scale Recommendations Scale

Construction

Damage or Medium MV005 - Small Construction Long Demarcation and destruction Site or Term > 18 Site or 1 Informal burial of access Major - Term > 5 High Definite High Yes avoidance; social Moderate - Medium Possible Medium of historical Local months < 5 Local ground road years consultation graves years MV009 - Damage or Medium Long Demarcation and Medium Construction destruction Site or Term > 18 Site or 2 Major - Term > 5 High Possible High Yes avoidance; social Moderate - Medium Possible Medium Informal Burial of pipeline of historical Local months < 5 Local years consultation ground graves years Damage/ Medium MV025 - Large Long Demarcation and destruction Site or Term > 18 Site or 3 Community pipeline Major - Term > 5 High Possible High Yes avoidance; social Moderate - Medium Possible Medium of historical Local months < 5 Local Burial ground years consultation graves years Damage/ Medium MV033 - Long destruction Site or Demarcation and Term > 18 Site or 4 Municipal pipeline Major - Term > 5 High Unlikely Medium Yes Moderate - Medium Possible Medium of historical Local avoidance months < 5 Local cemetery years graves years

8.2.1.7 Social Impact

Refer to Chapter 7, section 7.10.7 for a description of the anticipated social impacts of the proposed project.

Table 8-21: 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 Medium term Long term Magnitude Moderate + Major + Probability Definite Definite Calculated Significance Rating Low 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

❖ It is recommended that as part of the Ergo’s approved SLP programme and the Ergo Business Development Academy (EBDA), targets for employment and training are established; ❖ Effective implementation of training and skills development initiatives through EBDA; ❖ It is recommended that as part of the CSI programme, the contractor makes use of local labour as and when required; ❖ Communication with locals regarding job opportunities and skills requirements to manage expectations; ❖ Equipped employees with the required skills and competencies to effectively implement their employment responsibilities and progress to higher levels of employment within the company; ❖ Comply with the Skills Development Act, (Act No.97 of 1998).

Table 8-22: Impacts of stimulating economic growth.

NATURE OF THE IMPACT: INCREASED ECONOMIC REVENUE Impact Rating Without Mitigation Impact Rating with Mitigation Impact Status: (positive or negative) Positive Positive Extent Local Local Duration Medium term Long term Magnitude Low + Major + Probability Definite Definite Calculated Significance Rating Medium High 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 and local community members.

Mitigation measures

❖ Preference should be given to capable subcontractors who based within the local municipal area; ❖ Ergo to source local suppliers, HDSAs and Small, Medium and Micro-sized Enterprises (SMMEs); ❖ Encourage the company’s existing suppliers to enter into a Joint Venture (JV) with local SMMEs to aid with the transfer of skills; ❖ Use the Department of Trade and Industry’s (DTI) codes of good practice to guide the procurement process; ❖ Align skills development to build capacity of SMMEs.

Table 8-23: Safety impacts for employees and communities

NATURE OF THE IMPACT: SAFETY IMPACTS Impact Rating Without Impact Rating with Mitigation Mitigation Impact Status: Negative Negative Extent Local Local Duration Medium term Medium term Magnitude Major - Moderate- Probability Possible Definite Calculated Significance Rating High Medium 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;

❖ All project infrastructure should be contained in a secured area to prevent unauthorized access and therefore potential health and safety risks;

❖ Ergo to collaborate with local authorities (City of Ekurhuleni Metropolitan Municipality, the local South Africa Police Services, the relevant landowner and the Community Policing Forum to establish standard operating procedures for the control and/or removal of unauthorised individuals;

❖ Community members, including illegal miners, should be made aware of the hazards of accessing mine dumps through safety signs at the reclamation and deposition sites;

❖ Develop a comprehensive safety management plan to protect the health and safety of all personnel and the property on or near the site.

Table 8-24: Town planning and residential interface

NATURE OF IMPACT: IMPACT ON SPATIAL DEVELOPMENT FUTURE LAND USE Impact Rating Without Impact Rating With Mitigation Mitigation Impact Status: (positive or negative) Negative Negative Extent Local Local Duration Long term Medium Term Magnitude Major- Minor - Probability (Definite, Possible, Unlikely) Possible Possible Calculated Significance Rating High Medium Reversibility: (Reversible or Irreversible) Irreversible Irreplaceable loss of resources: (Yes or No) No Can impacts be enhanced: (Yes or No) No Residual impacts

❖ Delayed development and increase on current housing backlogs

Mitigation measures

❖ As far as possible avoid encroachment of pipelines on other development opportunities. ❖ Pipelines to be constructed far away from homesteads, buildings and railway lines. ❖ Applicant to undertake communicative planning with the relevant stakeholders, (i.e., Ilangabi Coal Mine, proposed Bloemendal Mine, proposed Brikor’s mining of clay, sand and coal, Vereeniging Properties, private landowners and the Marievale Military personnel). Communicative planning entails the flow of information or a direct contact between all the stakeholders, the planner and the beneficiaries. In so doing, there are high chances of keeping all the stakeholders informed with the decisions being taken and the progress made.

❖ Applicant to consider engaging regularly with EMM, and actively contribute to a variety of planning documents.

Table 8-25: Exposure to dust fallout and health impacts

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 Medium term Short Term Magnitude Moderate- Minor - Probability Definite Definite Calculated Significance Rating High Medium 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 air quality monitoring must be undertaken to monitor emissions from 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.

Table 8-26: Ecosystem Services impacts

NATURE OF IMPACT: ECOSYSTEM 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- Minor -

NATURE OF IMPACT: ECOSYSTEM SERVICES Probability Definite Definite Calculated Significance Rating Medium Low Reversibility: (Reversible or Irreversible) Irreversible Irreplaceable loss of resources: (Yes or No) Yes Can impacts be enhanced: (Yes or No) No Residual impacts

❖ Affected ecosystem services- loss of recreation/aesthetic services.

Mitigation measures

❖ Consider implementation of the mitigation measures as indicated in the Biodiversity report; ❖ Where possible, reduce the impact on ecosystem services through project design (minimising project footprint and disturbance on ecosystems); ❖ Impact can be managed through Environmental Management Programme.

Table 8-27: Impacts on movement patterns

NATURE OF THE IMPACT: DISRUPTION IN DAILY MOVEMENT PATTERNS Impact Rating Without Impact Rating with Mitigation Mitigation Impact Status: (positive or negative) Negative Negative Extent Local Local Duration Short Term Short Term Magnitude Medium - Minor- Probability Possible Definite Calculated Significance Rating Medium Low Reversibility: (Reversible or Irreversible) Not applicable Irreplaceable loss of resources: (Yes or No) Not applicable Can impacts be enhanced: (Yes or No) No Residual impacts

❖ Restricted access which might disrupt daily movement patterns.

Mitigation measures

❖ A grievance management mechanism should be in place to receive incident related queries. ❖ The applicant should keep the residents informed on a day-to-day basis regarding construction progress and when to expect the site to be blocked.

Table 8-28: Informal settlements

NATURE OF THE IMPACT: CREATION OF INFORMAL SETTLEMENTS Impact Rating Without Impact Rating with Mitigation Mitigation Impact Status: (positive or negative) Negative Negative Extent Local Local Duration Short Term Short Term Magnitude Medium - Minor- Probability Possible Definite Calculated Significance Rating Medium Low Reversibility: (Reversible or Irreversible) Not applicable Irreplaceable loss of resources: (Yes or No) Not applicable Can impacts be enhanced: (Yes or No) 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. ❖ Security patrols should be implemented to monitor the perimeters of the project site thereby providing an increased security presence to prevent unauthorized access. ❖ Communicate upfront the proposed end land uses envisaged for the area once the reclamation process has been completed. ❖ Ergo to collaborate with local authorities (EMM, the local South Africa Police Services, the relevant landowner and the Community Policing Forum to establish standard operating procedures for the control and/or removal of unauthorised individuals. ❖ Ergo to collaborate with the EMM and implement EMM’s land use management system to prevent illegal settlements.

8.2.1.8 Noise

The potential significance of the noise impacts is summarized in the table below for the construction of the reclamation pump station and for potential daytime maintenance or repair activities (for an arbitrary location).

The findings of will also be valid for the larger project, as the pipeline will be constructed over a larger area than considered in this report.

Table 8-29: Numerous simultaneous construction activities during the day

IMPACT DESCRIPTION: Increased total noise levels in the area, changing existing ambient sound levels at receptors

Acceptable Rural noise district. Use LReq,D of 45 dBA

Rating Level Before Mitigation After Mitigation Magnitude Minor negative: Daytime noise levels will be less than the acceptable noise rating level for an urban area. Duration Short Term: Noise levels will be elevated for the construction phase. Extent Local: The project will not impact on the ambient sound levels further than (ΔLAeq,D>7dBA) 1,000 m from the activity during the day. Probability Unlikely: Urban environment with high ambient sound levels at times. Consequence Low No mitigation Significance Low required. Mitigation: Significance of the noise impact is Low and no additional mitigation measures are required.

Table 8-30: Potential construction, maintenance and repair activities during the day

IMPACT DESCRIPTION: Increased total noise levels in the area, changing existing ambient sound levels at receptors Increased total noise levels in the area, changing existing ambient sound levels at receptors. Noise levels may be higher than: ❖ 45 dBA within 220 m from the activity; ❖ 50 dBA within 190 m; and ❖ 55 dBA within 110 m Acceptable Rural noise district (worst-case scenario).

Rating Level Use LReq,D of 45 dBA Before Mitigation After Mitigation Magnitude Major negative: Daytime noise levels may be higher than 60 dBA at the closest receptors living close to the proposed pipeline alignment. Duration Short Term: Noise levels will be elevated for the construction phase. Extent Local: The project will not impact on the ambient sound levels further than (ΔLAeq,D>7dBA) 1 000 m from the activity during the day. Probability Unlikely: The activity will be very temporary and the activities may be disturbing during the event. However, the activity will only be required for No mitigation maintenance or repair (unlikely to occur). required. Consequence Medium Significance Low Mitigation: Significance of the noise impact is Low and no additional mitigation measures are required.

8.2.1.9 Traffic Statement

Table 8-31: Construction and Operation Traffic Impacts

NATURE OF IMPACT 1: Extra Heavy Vehicle Traffic 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, 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

❖ None

Table 8-32: Construction and operation traffic impacts

NATURE OF IMPACT 2: Increased Congestion 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, Medium Low 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

❖ None

Table 8-33: Construction and operation traffic impacts

NATURE OF IMPACT 3: Vehicle Impact and Damage 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) Moderate Moderate Probability (Definite, Possible, Unlikely) Possible 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) Yes Residual impacts

❖ Extended congestion and delays on the road.

Mitigation measures

❖ Sufficient sight distance at access position. ❖ Warning and speed restrictions to be erected.

Operational Phase

This section comprises of the description of potential impacts associated with the proposed operation of the reclamation project 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.

The following activities are planned by the Applicant for the operation phase of the project.

Table 8-34: Summary table of the Activities associated with the operational phase of the project

ACTIVITY DESCRIPTION Operational Phase 1 Reclamation of tailings. 2. Pumping of slurry to Ergo Plant and process water to the Proposed Project Site

8.2.1.10 Biodiversity

The following potential impacts were considered on biodiversity (fauna and flora) during operational phase:

❖ Continued encroachment and displacement of the natural vegetation community due to alien invasive plant species; ❖ Habitat disturbance; ❖ Disturbances due to excavation works in CBA: Important and ESA watercourse; ❖ Erosion and dust dispersal; ❖ Water runoff and acid mine drainage; and ❖ Continued displacement and fragmentation of the faunal community.

Table 8-35: Significance rating of operational impacts on Biodiversity during operation

NATURE OF IMPACT 1: Use of roads: Disturbance of habitat and species of ecological importance; Displacement of fauna; Loss of migration corridors; Direct loss of floral species/vegetation types and biodiversity; Alien vegetation encroachment; Erosion Impact Rating Without Impact Rating With

❖ Storm water flooding;

❖ Change of hydrology of the Blesbokspruit and polluting Marievale Nature Reserve.

Mitigation measures

❖ Demarcate the project area and avoid surrounding areas;

❖ Dust-reducing mitigation measures must be put in place and must be strictly adhered to. This includes wetting of exposed soft soil surfaces; ❖ An erosion control plan must be compiled and implemented; ❖ Faunal species must be allowed to move out of the area unharmed; ❖ Install signs restricting the speeds of the vehicles;

❖ Install culverts below the roads to assist with erosion control, leave green corridors for species to move along.

Table 8-36: Significance rating of operational impacts on Biodiversity during operation

NATURE OF IMPACT 2: Temporary infrastructure: Clearance of vegetation, dust, encroachment by alien vegetation, displacement of fauna and endemic plant species, increase in pest species and associated diseases 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) Medium term Short 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) Irreversible Irreplaceable loss of resources: (Yes or No) No Can impacts be enhanced: (Yes or No) Yes Residual impacts

❖ Human encroachment into surrounding areas, including litter and sewage

Mitigation measures

❖ The temporary infrastructure needs to be placed in the low sensitivity areas. ❖ Implementation of alien invasive plant management plan needs to be continued during operation to prevent the growth of invasive on cleared areas; ❖ Dust-reducing mitigation measures must be put in place and must be strictly adhered to. This includes wetting of exposed soft soil surfaces; ❖ An erosion control plan must be compiled and implemented; ❖ Allow species to move out of the area safely, if they do not move on their own get a qualified person to assist with the relocation of the species;

❖ Waste management must be a priority and all waste must be collected and stored adequately. It is recommended that all waste be removed from site on a weekly basis to prevent rodents and pests entering the site.

Table 8-37: Significance rating of operational impacts on Biodiversity during operation

NATURE OF IMPACT 3: Slurry receiving facility, screening facility at pump station: dust, encroachment by alien vegetation, displacement of fauna and endemic plant species, habitat loss for species, loss of migratory corridors, mortalities of faunal 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 term) Medium term Short 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) Irreversible Irreplaceable loss of resources: (Yes or No) No Can impacts be enhanced: (Yes or No) Yes Residual impacts

❖ Drainage of the polluted water into the surrounding area; ❖ Diseases due to the increase in the dust levels; ❖ Faunal mortality (direct and indirectly); ❖ Groundwater pollution;

❖ Loss of ecosystem services.

Mitigation measures

❖ All dumping and storage must be within the existing infrastructure footprint and the low sensitivity areas; ❖ Implementation of alien invasive plant management plan needs to be continued during operation to prevent the growth of invasive on cleared areas; ❖ Dust-reducing mitigation measures must be put in place and must be strictly adhered to. This includes wetting of exposed soft soil surfaces; ❖ An erosion control plan must be compiled and implemented; ❖ Allow species to move out of the area safely, if they do not move on their own get a qualified person to assist with the relocation of the species; ❖ Demarcate the area to be utilised and restrict any activities into surrounding habitats; ❖ Polluted water runoff must be limited by installing a lined base below the silt that will be piled and drainage system must accompany this to restrict the spreading to the now concentrated polluted water;

❖ The stormwater management plan must be implemented.

Table 8-38: Significance rating of operational impacts on Biodiversity during operation

NATURE OF IMPACT 4: Powerlines and transformers: Loss of avifauna species due to electrocutions, bird strikes, disturbance of fauna and flora species due to construction of lines, loss of 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 term) Long term Medium term Magnitude (Major, Moderate, Minor) Major Moderate Probability (Definite, Possible, Unlikely) Definite Possible Calculated Significance Rating (Low, Medium, High 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

❖ Faunal mortality (direct and indirectly).

Mitigation measures

❖ Bird flappers must be installed on the powerlines; ❖ Spikes must be installed on the poles to prevent bird electrocutions; ❖ An erosion control plan must be compiled and implemented. ❖ An alien invasive species control plan must also be compiled and implemented for the footprint of the project area.

Table 8-39: Significance rating of operational impacts on Biodiversity during operation

NATURE OF IMPACT 5: Slurry pipelines option A: Clearance of vegetation, dust, encroachment by alien vegetation, displacement of fauna and endemic plant species, habitat loss for species, loss of migratory corridors, mortalities of faunal species, Destruction, further loss and fragmentation of the remaining natural vegetation community, including CBA: Important and ESA 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) Medium term Short 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) Irreversible Irreplaceable loss of resources: (Yes or No) No Can impacts be enhanced: (Yes or No) Yes Residual impacts

❖ Drainage of the polluted water into the surrounding area; ❖ Faunal mortality (direct and indirectly); ❖ Groundwater pollution; ❖ Loss of ecosystem services.

Mitigation measures

❖ A spill management plan must be put in place; ❖ If any faunal are recorded during construction, activities should temporarily cease, and time permitted for the species to move away. In the event the species does not move away (voluntarily), the species must be removed safely from the area and relocated to a suitable area that will not be directly disturbed by the project; ❖ Implementation of alien invasive plant management plan needs to be continued during operation to prevent the growth of invasive on cleared areas; ❖ Dust-reducing mitigation measures must be put in place and must be strictly adhered to. This includes wetting of exposed soft soil surfaces; ❖ An erosion control plan must be compiled and implemented; ❖ Demarcate the area to be utilised and restrict any activities into surrounding habitats.

Table 8-40: Significance rating of operational impacts on Biodiversity during operation

NATURE OF IMPACT 5: Slurry pipeline Option B: Clearance of vegetation, dust, encroachment by alien vegetation, displacement of fauna and endemic plant species, habitat loss for species, loss of migratory corridors, mortalities of faunal species, Destruction, further loss and fragmentation of the remaining natural vegetation community, including CBA: Important and ESA, protected areas (IBA, Ramsar, Nature reserve); 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 Short term term) Magnitude (Major, Moderate, Minor) Major Moderate Probability (Definite, Possible, Unlikely) Definite Possible Calculated Significance Rating (Low, Medium, High 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

❖ Drainage of the polluted water into the surrounding area; ❖ Faunal mortality (direct and indirectly); ❖ Groundwater pollution; ❖ Loss of ecosystem services.

Mitigation measures

❖ A spill management plan must be put in place ❖ If any faunal are recorded during construction, activities should temporarily cease, and time permitted for the species to move away. In the event the species does not move away (voluntarily), the species must be removed safely from the area and relocated to a suitable area that will not be directly disturbed by the project; ❖ Implementation of alien invasive plant management plan needs to be continued during operation to prevent the growth of invasive on cleared areas; ❖ Dust-reducing mitigation measures must be put in place and must be strictly adhered to. This includes wetting of exposed soft soil surfaces; ❖ An erosion control plan must be compiled and implemented; ❖ Demarcate the area to be utilised and restrict any activities into surrounding habitats.

8.2.1.11 Wetlands

The tables below indicate the impacts posed to the Blesbokspruit wetland as a result of the Marievale Project.

Table 8-41: Potential risk posed by the reclamation activities (including pipelines)

RISK ASSESSMENT COMPLETED BY ANDREW HUSTED

PHASE ACTIVITY ASPECT IMPACT Blasting and pumping of tailings by means of ❖ Loss of aquatic/wetland habitat; Reclamation of Waste hydraulic system ❖ Erosion of watercourses; Impoundments Spills and Leaks ❖ Loss of indigenous vegetation; ❖ Exotic vegetation proliferation; Management of Pipeline ❖ Sedimentation of the watercourses; ❖ Flow sediment equilibrium change; Operational Phase ❖ Water quality impairment; Operation of Pipelines ❖ Flow modifications; Impeding Flows ❖ Loss of biodiversity; ❖ Loss of ecosystem services; and ❖ Loss of hydromorphic soils.

Table 8-42: DWS Risk Impact Matrix for the proposed project

SEVERITY CONSEQUENCE WATER SPATIAL ASPECT FLOW REGIME HABITAT BIOTA SEVERITY DURATION CONSEQUENCE QUALITY SCALE Operational phase

Reclamation of waste impoundments Blasting and pumping of tailings 5 5 5 5 5 2 4 11 by means of hydraulic system Spills and leaks 5 5 5 5 5 2 3 10

Operation of pipelines

Management of pipeline 1 1 1 1 1 1 4 6

Impeding flows 2 1 1 1 1,25 1 4 6,25

8.2.1.12 Surface Water

During the operational phase, hydraulic reclamation of the TSFs will take place. The operational phase will be approximately 10 years. Mining will start TSF 7L7, moving to 7L6 and then to 7L5.

The mixing of water with the tailings material during hydraulic mining, will add water and oxygen to the material, which is likely to result in acidic water with leaching of metals and salts. Due to the close proximity of the TSFs to the Blesbokspruit, it is of outmost importance that runoff from the operation is contained.

Poor maintenance of stormwater infrastructure such as the silting up of channels and paddocks, as well as the erosion of berms, can result in spills from the operation. It is therefore important that stormwater infrastructure is regularly monitored and maintained.

The floodline determination indicated that Dumps 7L6 and 7L7 are at risk of flooding under a 1:100 year flood. It is recommended that suitably designed flood protection berms are placed along the eastern and southern sides of Dump 7L6, as well as along the northern and eastern sides of Dump 7L7.

Ergo have an existing authorisation to abstract 5 ML/day from the Blesbokspruit. Abstraction will result in a reduction of water quantity in the Blesbokspruit for downstream users. According to the WR2012 study, the simulated MAR at the outlet of quaternary catchment C21E was 132.4 mcm. Assuming 5 ML/day would be abstracted for the proposed project 365 days per a year, this equates to 1.83 mcm. This would result in a 1.4 % reduction in the MAR.

The pipelines conveying slurry from the site may potentially result in unforeseen spills. The activities and impacts that could potentially occur during the operational phase are summarised in Table 8-43.

Table 8-43: Summary of activities and impacts for the operational phase

ACTIVITY IMPACT DESCRIPTION Uncontained runoff from the operational areas at the Impact 1: Runoff into the downslope watercourses TSFs. impacting on water quality. Impact 2: Silted paddocks and channels as well as eroded Poor maintenance of stormwater infrastructure. berms which lead to spills into the downslope watercourses impacting on water quality. Flooding of the operation as result of the TSFs being Impact 3: Flooding of the operation resulting in located within close proximity to the Blesbokspruit. downstream water quality impacts. Abstraction of water from the Blesbokspruit within Ergo’s Impact 4: Reduction in water quantity in the authorization of 5 ML/day for hydraulic mining. Blesbokspruit for downstream users. Impact 5: Spills running off into down gradient Leaks from the proposed pipelines. watercourses impacting on water quality.

The ratings and proposed mitigation measures for the impacts indicated in Table 8-43, are indicated in Table 8-44 to Table 8-48.

Table 8-44: Significance rating of operational impact 1.

NATURE OF IMPACT 1: Uncontained runoff from the operational areas at the TSFs running off into the downslope watercourses impacting on water quality 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) Long term Long term Magnitude (Major, Moderate, Minor) Major Moderate Probability (Definite, Possible, Unlikely) Definite Possible Calculated Significance Rating (Low, Medium, High 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, as the impact will cease provided that rehabilitation is done appropriately.

Mitigation measures

❖ Implementation of the proposed SWMP. It must be ensured that stormwater measures are designed, constructed and operated, to ensure that stormwater does not spill more than once in 50 years, to be compliant with GN R704 regulations; and ❖ Water quality sampling must be implemented upstream and downstream of the mining and stockpiling areas. It is recommended that Total Suspended Solids (TSS) and turbidity are included in the current water quality monitoring programme.

Table 8-45: Significance rating of operational impact 2

Mitigation Mitigation Impact Status: (positive or negative) Negative Negative Extent (Local, Regional, International) Regional Local Long term (operational phase is 6 Long term (operational phase Duration (Short term, Medium term, Long term) years) is 6 years) Magnitude (Major, Moderate, Minor) Major Moderate Probability (Definite, Possible, Unlikely) Possible Possible Calculated Significance Rating (Low, Medium, High Medium High)

NATURE OF IMPACT 2: Poor maintenance of stormwater infrastructure resulting in silted paddocks and channels as well as eroded berms, leading to spills into the downslope watercourses impacting on water quality. 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 detailed in the EMPr.

Table 8-46: Significance rating of operational impact 3

NATURE OF IMPACT 3: Flooding of the operation as a result of being located within close proximity to the Blesbokspruit and consequent downstream water quality issues 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) Long term Short term Magnitude (Major, Moderate, Minor) Major Minor Probability (Definite, Possible, Unlikely) Possible Possible Calculated Significance Rating (Low, Medium, High 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 flood protection measures around the eastern and southern sides of TSF 7L6, as well as along the northern and eastern sides of TSF 7L7.

Table 8-47: Significance rating of operational impact 4

NATURE OF IMPACT 3: Abstraction of water from the Blesbokspruit within Ergo’s authorization of 5 ML/day for hydraulic mining resulting in a reduction in water quantity for downstream users 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) Long term Long term Magnitude (Major, Moderate, Minor) Minor Minor Probability (Definite, Possible, Unlikely) Possible Unlikely 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

❖ The reduction in the MAR of quaternary catchment C21E if 5 ML/day is abstracted from the Blesbokspruit, was calculated to be 1.4 %. This is a small reduction. It is however recommended that alternative dirty water sources are used other than the Blesbokspruit.

Table 8-48: Significance rating of operational impact 5

NATURE OF IMPACT 4: Leaks from the proposed pipelines impacting on down gradient water 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) Long term Medium term Magnitude (Major, Moderate, Minor) Major Minor Probability (Definite, Possible, Unlikely) Possible Possible Calculated Significance Rating (Low, Medium, High 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

NATURE OF IMPACT 4: Leaks from the proposed pipelines impacting on down gradient water quality ❖ None, as the impact will cease after the operational phase.

Mitigation measures

❖ Regular inspections of the pipelines; and ❖ Immediate fixing of the pipeline and clean ups should spills occur.

8.2.1.13 Groundwater 8.2.1.13.1 Groundwater Quality

The groundwater quality near the various TSF footprints and also the water in the Blesbokspruit is already impacted. Historically the sources of pollution associated with the Marievale area include:

❖ Contaminated storm water runoff from the various TSFs; ❖ Seepage water from the various slimes dams and RWD, possibly containing high sulphates and metals; and ❖ Recharge of contaminated water by means of seepage from the dumps and any unlined storm water channels.

Groundwater quality will be negatively affected with potential increase in salt loads, especially sulphate concentrations during the reclamation activities. The old tailings material contains pyrite minerals and when exposed to oxygen and water during reclamation will result in the formation of acidic conditions. The risk of groundwater contamination during the hydraulic mining will be moderately negative in view of the existing impacts, as long as the surface water management and containment guidelines are followed during the reclamation process.

The implementation of sound house-keeping during the operational phase of the project, including the containment, reuse and recycling of stormwater, is expected to reduce impacts on groundwater quality, associated with the project, possibly resulting in an impact of medium significance. Groundwater mitigation measures proposed are listed below.

It is further important that all tailings material is removed, and that no selective tailings reprocessing takes place. Simulations completed as part of the impact prediction indicates that partially removed TSF material would result in unacceptable long-term impacts on groundwater and the wetlands. Complete removal of the Marievale dumps should however have a long-term positive impact on the groundwater quality, as the source of contamination is removed. Simulations completed as part of the impact assessment suggests that salt loads from the Marievale dumps could be reduced by more than 80% through the removal of the tailings, even if the footprint soils are not ameliorated. A significant reduction in long-term impacts can furthermore be achieved if the footprint soils are ameliorated to reduced salt and metal concentrations in the impacted soils to within tolerable interim targets, as set for the Blesbokspruit water quality.

Monitoring of groundwater quality and water levels is recommended (downgradient of the different slimes dams) with continuous review and updating of the monitoring network based on the monitoring results. Monitoring of the existing hydrocensus boreholes upgradient of TSF 7L5 and 7L6 must be included.

Mitigation options include the removal of tailings material, currently on top of alluvium or dolomite sections last to limit negative impacts on the exposed alluvium / dolomite. If these portions are taken away first, it is recommended to install cut-off trenches on the Karoo formation to ensure protection of the alluvium and downstream receptors. The pump station and ponds at each TSF must be placed along the southwestern perimeter of the TSF footprint to increase the distance from the Blesbokspruit and associated wetlands, thereby limiting the impacts associated with overflowing ponds, spills and seepage into the surface.

Table 8-49: Operational 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 Positive Extent (Local, Regional, International) Local Local Duration (Short term, Medium term, Long term) Long term Long term Magnitude (Major, Moderate, Minor) Major - Moderate + 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. Residual Impacts

❖ Combined impact with other mining activities in the area, including the Vlakfontein Quarry, industrial activities and waste and sanitation management problems

Mitigation measures

❖ Develop sound surface runoff management plans to ensure that all dirty runoff is contained and diverted to the paddocks. No pooling of water on surface allowed. The groundwater table is near surface and contaminated seepage will quickly enter the underlying aquifers if not managed effectively; ❖ Commit to remove all tailings material and to monitor the quality of soils in the footprint areas. If soil monitoring suggests unacceptably high salt and metal concentrations, soil amelioration should be considered; ❖ The alluvial aquifer is at greatest risk and as a result the Blesbokspruit. Monitoring boreholes, specifically in the alluvium, is required, with the condition that intercept trenches and later, contamination capture wells will have to be installed in the alluvial if the monitoring shows deterioration during operations; ❖ Monitor groundwater quality in all boreholes installed. The groundwater monitoring network efficiency must be assessed, and new monitoring boreholes drilled, if required. Additional mitigation measures need to be implemented if pollution is found migrating off site; ❖ Ensure that paddocks can contain all dirty water generated during the reclamation process to prevent

NATURE OF THE IMPACT: Impact on the local groundwater quality overflows and spillages.

8.2.1.13.2 Groundwater Quantity

The proposed dump reclamation will not have any significant impacts on the groundwater quantity, provided ponding is not allowed in the paddocks. 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 negligible and should have no impact on the groundwater table elevation. New groundwater monitoring boreholes are required to monitor groundwater level fluctuations over time.

Table 8-50: Operational Phase water quantity impacts.

NATURE OF THE IMPACT: Reduction in aquifer yield 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) Medium Term Medium 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) Yes. Refer to Chapter 10 of the groundwater impact assessment Mitigation measures

8.2.1.14 Air Quality

See Table 8-18 in the construction phase.

8.2.1.15 Heritage and Palaeontology

See Table 8-19 and Table 8-20 in the construction phase.

8.2.1.16 Social Impact

Refer to Chapter 7, section 7.10.7 for a description of the anticipated social impacts of the proposed project.

Table 8-51: 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 Long term Long term Magnitude Moderate + Major + Probability Possible Definite Calculated Significance Rating Low 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 operational phase is that it benefits the local economy; ❖ Acquired transferable skills that could potentially be used with other businesses; ❖ 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

❖ Although this application is not a Mining Right Application, it is recommended that as part of the Ergo’s approved SLP programme and the Ergo Business Development Academy (EBDA), targets for employment and training are established; ❖ Aim to absorb the youth (as the area has a high dependency ratio); ❖ Communication with locals regarding job opportunities and skills requirements to manage expectations ❖ Effective implementation of training and skills development initiatives through EBDA; ❖ It is recommended that as part of the CSI programme, the contractor makes use of local labour as and when required; and ❖ Comply with the Skills Development Act, (Act No.97 of 1998).

Table 8-52: Impacts of stimulating economic growth.

❖ Local suppliers will have gained experience and exposure to meeting standards of quality and scale that could be transferrable to business opportunities.

Mitigation measures

❖ Preference should be given to capable subcontractors who based within the local municipal area; ❖ Consider measures recommended to maximise bene fits from local employment, skills and economic development.

Table 8-53: Safety Impacts for employees and communities

❖ Increased perception of unsafety

Mitigation measures

❖ Security patrols should monitor the perimeters of the project site thereby providing an increased security presence. ❖ All project infrastructure should be contained in a secured area to prevent unauthorized access and therefore potential health and safety risks. ❖ Ergo to collaborate with local authorities (City of Ekurhuleni Metropolitan Municipality, the local South Africa Police Services, the relevant landowner and the Community Policing Forum to establish standard operating procedures for the control and/or removal of unauthorised individuals. ❖ Community members, including illegal miners, should be made aware of the hazards of accessing mine dumps through safety signs at the reclamation and deposition sites. ❖ Develop a comprehensive safety management plan protect the health and safety of all personnel and the property on or near the site.

Table 8-54: Town planning and residential interface

NATURE OF IMPACT: IMPACT ON SPATIAL DEVELOPMENT FUTURE LAND USE Impact Rating Without Impact Rating With Mitigation Mitigation Impact Status: (positive or negative) Negative Negative Extent Local Local Duration Long term Medium Term Magnitude Major- Minor - Probability (Definite, Possible, Unlikely) Possible Possible Calculated Significance Rating High Medium Reversibility: (Reversible or Irreversible) Irreversible Irreplaceable loss of resources: (Yes or No) Can impacts be enhanced: (Yes or No) No Residual impacts

❖ Delayed development and increase on current housing backlogs

Mitigation measures

❖ As far as possible avoid encroachment of pipelines on other development opportunities; ❖ Pipelines to be constructed far away from homesteads, buildings and railway lines; ❖ Applicant to undertake communicative planning with the relevant stakeholders (ie, Ilangabi Coal Mine, proposed Bloemendal Mine, proposed Brikor’s mining of clay, sand and coal, Vereeniging Property, private landowners and the Marievale Military personnel). Communicative planning entails the flow of information or a direct contact between all the stakeholders, the planner and the beneficiaries. In so doing, there are high chances of keeping all the stakeholders informed with the decisions being taken and the progress made; ❖ Effective strategic land-use planning, communication and engagement are central to managing the current and future social impact on town planning and residential interface;

❖ Applicant to consider engaging regularly with EMM, and actively contribute to a variety of planning documents.

Table 8-55: Exposure to dust fallout and health 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 air quality monitoring must be undertaken to monitor emissions from 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.

Table 8-56: Ecosystem Services impacts

NATURE OF IMPACT: ECOSYSTEM SERVICES Reversibility: (Reversible or Irreversible) Irreversible Irreplaceable loss of resources: (Yes or No) Yes Can impacts be enhanced: (Yes or No) No Residual impacts

❖ Affected ecosystem services- loss of recreation/aesthetic services

Mitigation measures

❖ Consider implementation of the mitigation measures as indicated in the Biodiversity report. ❖ Where possible, reduce the impact on ecosystem services through project design (minimising project footprint and disturbance on ecosystems). ❖ Impact can be managed through Environmental Management Programme.

Table 8-57: Impacts to movement

NATURE OF THE IMPACT: DISRUPTION IN DAILY MOVEMENT PATTERNS Impact Rating Without Impact Rating with Mitigation Mitigation Impact Status: (positive or negative) Negative Negative Extent Local Local Duration Short term Short term Magnitude Medium - Minor- Probability Possible Definite Calculated Significance Rating Medium Low Reversibility: (Reversible or Irreversible) Not applicable Irreplaceable loss of resources: (Yes or No) Not applicable Can impacts be enhanced: (Yes or No) No Residual impacts

❖ Restricted access which might disrupt daily movement patterns.

Mitigation measures

❖ A grievance management mechanism should be in place to receive incident related queries; ❖ The applicant should keep the residents informed on a day-to-day basis regarding construction progress and when to expect the site to be blocked.

Table 8-58: Informal Settlements

NATURE OF THE IMPACT: CREATION OF INFORMAL SETTLEMENTS Impact Rating Without Mitigation Impact Rating with Mitigation Impact Status: (positive or negative) Negative Negative Extent Local Local Duration Short Term Short Term Magnitude Moderate - Major- Probability Possible Definite Calculated Significance Rating Medium Low Reversibility: (Reversible or Irreversible) Not applicable Irreplaceable loss of resources: (Yes or No) Not applicable Can impacts be enhanced: (Yes or No) No Residual impacts

❖ Increased perceptions of unsafety. Mitigation measures

8.2.1.17 Noise

Table 8-59: Numerous simultaneous operational activities during the day

IMPACT DESCRIPTION: Increased total noise levels in the area, changing existing ambient sound levels at receptors

Acceptable Rural noise district. Use LReq,D of 45 dBA

Rating Level Before Mitigation After Mitigation Magnitude Moderate negative: Daytime noise levels will be slightly higher than the acceptable noise rating level for a rural area. Duration Long Term: Noise levels will be elevated for the operational phase.

Extent Local: The project will not impact on the ambient sound levels further than (ΔLAeq,D>7dBA) 1,000 m from the activity during the day. Probability Unlikely: Ambient sound levels could be low at times and the activities may be audible, but it will not be disturbing considering typical daytime sound levels. No mitigation Consequence Low required. Significance Low Mitigation: Significance of the noise impact is Low and no additional mitigation measures are

required.

Table 8-60: Numerous simultaneous operational activities during the night

IMPACT DESCRIPTION: Increased total noise levels in the area, changing existing ambient sound levels at receptors Acceptable Rural noise district. Use LReq,N of 35 dBA

Rating Level Before Mitigation After Mitigation Major negative: Night-time noise levels will be Moderate negative: Night-time noise levels higher than the urban rating level at the closest may be higher than the urban rating level at Magnitude NSD. times at the closest NSD. Duration Medium Term: Noise levels will be elevated for Long Term: Noise levels will be elevated for the the operational phase. operational phase. Extent Local: The project will not impact on the Local: The project will not impact on the (ΔLAeq,D>7dBA) ambient sound levels further than 1,000 m ambient sound levels further than 1,000 m from from the activity during the day the activity during the day. Probability Possible: While ambient sound levels may be Possible: Activities may be clearly audible and high at times, activities would be clearly could impact on the closest NSD at times. audible and could impact on the closest NSD at times. Consequence Medium Low Significance Medium Low Mitigation The significance rating is due to the very precautious significance rating criteria. There have been a number of other reclamation projects at various locations without noise complaints, with a site visit to other existing projects highlighting that actual noises from the pump system are low. The use of heavy machinery may create noises at night that some NSDs may find disturbing. Ideally no night-time activities should be planned closer than 400m from any NSD

Decommissioning Phase

This section comprises of the description of potential impacts associated with the 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.

The following activities are planned by the Applicant for the decommissioning phase of the project.

Table 8-61: Summary table of the Activities associated with this decommissioning phase of the project

ACTIVITY DESCRIPTION Decommissioning Phase 1 Demolition of temporary infrastructure and Rehabilitation of the project area. Ergo aims to rehabilitate the Marievale area by shaping the areas where silt was removed and make the area free draining. Thereafter, appropriate species will be planted to stabilise the soil. 2 Decommissioning forum to be established with key stakeholders.

8.2.1.18 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; ❖ Continued displacement, direct mortalities and disturbance of faunal community (including multiple threatened species) due to habitat loss and disturbances (such as dust and noise); and ❖ 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 8-62: Assessment of significance of potential decommissioning of the development pre- and post- mitigation

NATURE OF IMPACT 1: 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 term) Long term Medium 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) Irreversible Irreplaceable loss of resources: (Yes or No) No Can impacts be enhanced: (Yes or No) Yes Residual impacts

❖ Loss of habitat for indigenous species.

Mitigation measures

❖ Implementation of alien invasive plant management plan needs to be continued during decommissioning to prevent the growth of invasive on rehabilitated areas;

❖ Rehabilitation of site with indigenous vegetation that occurs in the vicinity of project area.

Table 8-63: Assessment of significance of potential decommissioning of the development pre- and post- mitigation

NATURE OF IMPACT 2: Continued displacement, direct mortalities and disturbance of faunal community (including multiple threatened species) due to habitat loss and disturbances (such as dust). 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) Medium term Medium 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) Irreversible 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 (silt drying area sheeting etc) needs to be decommissioned and removed

Table 8-64: Assessment of significance of potential decommissioning of the development pre- and post- mitigation

NATURE OF IMPACT 3: 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. Impact Rating Without Impact Rating With Mitigation Mitigation Impact Status: (positive or negative) Negative Positive Extent (Local, Regional, International) Local Local Duration (Short term, Medium term, Long term) Medium term Medium 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

❖ Areas other than the footprint areas and existing surface infrastructure areas, should be declared as ‘no-go’ areas to vehicles (only). All essential operational staff – machinery must be limited to development area (no need to go outside area; ❖ All infrastructure not part of the end land use planning must be removed. The foundations must be removed up to a depth of 1m and the rubble must be discarded at the nearest landfill that allows waste of this kind. Access roads that will not be used must be ripped and revegetated; ❖ Areas were infrastructure was demolished must be landscaped back to original contours and rehabilitated to the designated land capability; ❖ Limiting the impact area and rehabilitation activities to the proposed footprint area and the associated infrastructure; ❖ The replacement of the topsoil must be done within the rehabilitated areas. The topsoil will be ripped and reseeded. Any contamination of the topsoil must be avoided by ensuring machinery is well maintained and leak free. If contamination has occurred the area must be ameliorated immediately; ❖ The rehabilitated areas must be revegetated as soon as possible to reduce the risk of increased runoff from bare areas. Vehicles will be driving around on site and must stay within the designated routes. This will prevent compaction of soils outside of the disturbed area. If areas have been compacted the soil must be ripped to remedy the effects of compaction; ❖ Monitoring of Alien Invasive Plant species and their presence, in conjunction with the alien invasive plant management plan for the life of the project; ❖ Infringement by humans as well as livestock into the rehabilitation areas must be prevented; ❖ Rehabilitation must reduce the radium activity to acceptable levels and action should be taken to prevent the emanation of radon from the soil; ❖ Implementation of rehabilitation plan; and

❖ Dust-reducing mitigation measures must be put in place and must be strictly adhered to. This includes wetting of exposed soft soil surfaces.

8.2.1.19 Wetlands

The following potential impacts were considered during the decommissioning, particularly during rehabilitation. Potential loss or degradation of wetlands or adjoining terrestrial habitat through inappropriate decommissioning.

Table 8-65: Potential risk posed by the reclamation activities (including pipelines)

RISK ASSESSMENT COMPLETED BY ANDREW HUSTED

PHASE ACTIVITY ASPECT IMPACT

Excavation within wetlands ❖ Loss of aquatic/wetland habitat; ❖ Erosion of watercourses; Decommissioning Decommissioning Pipelines Removal of Pipelines ❖ Loss of indigenous vegetation; Increased Traffic ❖ Exotic vegetation proliferation; ❖ Sedimentation of the watercourses; Increased Traffic Rehabilitation of Tailing Facilities ❖ Flow sediment equilibrium change; Reshaping the Landscape ❖ Water quality impairment; ❖ Flow modifications; Rehabilitation Increased Traffic ❖ Loss of biodiversity; Rehabilitation of Pipeline Footprint ❖ Loss of ecosystem services; and Areas Reshaping the Landscape ❖ Loss of hydromorphic soils.

Table 8-66: DWS Risk Impact Matrix for the proposed project

SEVERITY CONSEQUENCE WATER SPATIAL ASPECT FLOW REGIME HABITAT BIOTA SEVERITY DURATION CONSEQUENCE QUALITY SCALE Decommissioning phase

Decommissioning of pipelines

Excavation within wetlands 5 5 5 5 5 1 1 7

Removal of pipelines 1 1 1 1 1 1 1 3

Increased traffic 1 1 2 2 1,5 1 1 3,5

Rehabilitation

Rehabilitation of tailing facilities

Increased traffic 2 2 2 2 2 1 1 4

Reshaping the landscape 3 2 2 2 2,25 2 2 6,25

Rehabilitation of pipeline footprint areas

Increased traffic 1 1 1 1 1 1 1 3

Reshaping the landscape 2 1 1 1 1,25 2 2 5,25

8.2.1.19.1 Biodiversity and Wetlands Mitigation Measures

According to the mitigation hierarchy (DEA, 2013) (Figure 8-2), the preferred option is to avoid wetlands and their buffer zones. The majority of the wetlands that have been identified is located outside of the prescribed buffer zones, which emphasises the fact that avoidance is not possible for some of the wetlands (see Figure 8-3 to Figure 8-6 for wetlands identified within buffer range of the proposed pipeline and reclamation activities).

Figure 8-2: The mitigation hierarchy as described by the DEA (2013)

Figure 8-3: Wetland systems located within the assigned buffer proximity of the proposed reclamation sites

Figure 8-4: Wetland systems located within the assigned buffer proximity of the proposed pipeline areas (northern portion of the project area)

Figure 8-5: Wetland systems located within the assigned buffer proximity of the proposed pipeline areas (south-eastern portion of the project area)

Figure 8-6: Wetland systems located within the assigned buffer proximity of the proposed pipeline areas (western portion of the project area)

The second step according to the mitigation hierarchy is to minimise the significance of impacts to ensure “No” or Low” risks. This could be achieved for the following aspects:

❖ Storage of chemicals, mixes and fuel (Construction of pipelines); ❖ Ablution facilities (Construction of pipelines); and ❖ Traffic (Construction phase of reclamation site).

The third step according to the mitigation hierarchy, is rehabilitation of degraded wetland areas. It is the opinion of the specialist that rehabilitating areas degraded by the construction, operation and decommissioning of the pipelines as well as the construction and operation of the reclamation activities will be sufficient, and that a wetland offset will not be required. Emphasis should therefore be placed on the rehabilitate of the HGM units illustrated in Figure 8-3 to Figure 8-6, these include;

❖ HGM 2; ❖ HGM 3; ❖ HGM 5; ❖ HGM 6; ❖ HGM 7; ❖ HGM 9;

❖ HGM 10; ❖ HGM 12; ❖ HGM 13; ❖ HGM 14; and ❖ HGM 15.

Even though the entire wetland system must be investigated for rehabilitation purposed due to potential indirect impacts that could impede far into wetlands, the areas highlighted in Figure 8-3 to Figure 8-6 must be focussed on, due to the fact that these areas will be directly impacted upon.

8.2.1.19.2 Reclamation Specific Mitigation

❖ Rehabilitation of the above-mentioned wetlands must be conduct concurrent to the project phases, and be initiated from the onset of the project where possible; ❖ It is imperative that a budget be allocated for the planned rehabilitation efforts and likewise that it be approved by the relevant authorities; ❖ Given the nature of the project mitigations limited and contamination of downstream watercourses is highly probable. However, as above this is likely to be a temporary impact which, following effective implementation of planned rehabilitation, should ultimately result in the removal / reduction of an existing source of wetland contamination; ❖ Excavate a temporary cut-off trench around the active reclamation area to help contain contaminants that are mobilised during the reclamation process from ending up in the downstream watercourses; ❖ Stay within the proposed reclamation areas and avoid extending earthmoving activities outside of these areas; ❖ Work systematically targeting one area at a time while rehabilitating the recently completed area as the operation progresses. Rehabilitating in this manner will allow for problems or inadequacies to be identified and rectified in the successive rehabilitation phases; ❖ Monitor water quality upstream and downstream of the site along the Blesbokspruit. Begin several months prior to construction commences to establish the pre-construction baseline; ❖ Within the reclamation areas identify areas of higher soil saturation and the preferential flow paths. Take measures to effectively steer clear of these areas or divert these flows around the reclamation area; and ❖ Water leaving the site should do so via appropriately engineered stormwater structures that serve to spread and dissipate flows to prevent the erosion of downstream watercourses.

8.2.1.19.3 Pipeline Specific Mitigation

❖ Lighter vehicles (small trucks and other vehicles) required for the proposed activities should only be allowed to use existing roads (including dirt roads); and ❖ No heavy machinery must be allowed within the delineated sensitive areas (especially the northern grassland areas). All excavations must be carried out via manual labour instead of heavy machinery/vehicles, if feasible.

❖ Erosion prevention and sediment control measures are imperative and need to be implemented throughout the entire project footprint area of the proposed pipeline, access roads and temporary laydown / storage sites; ❖ Contamination of the wetland systems with unset cement or cement powder should be negated as it is detrimental to aquatic biota. It is preferable that on-site mixing is avoided and that only prefabricated materials are used; ❖ As far as possible, the proposed pipelines should be placed in areas that have already been disturbed/transformed, and no further loss of secondary vegetation should be permitted. Areas to be developed must be specifically demarcated so that during the construction phase, only the demarcated areas be impacted upon; ❖ The areas rated as sensitive in the project area as defined in this report should be treated as such and the movement of construction vehicles and construction workers within these areas should be prohibited, unless required for the project (controlled access); and ❖ Where possible, existing access routes and walking paths must be made use of, and new routes limited.

8.2.1.20 Surface Water

As reclamation progresses to ground level, the dump areas will be sectioned off into a series of paddocks. This will be a short-term measure to prevent contaminated runoff from flowing offsite. The area will be assessed for contamination (particularly in terms of radiation). Contaminated soil will be removed and backfilled with uncontaminated soil. The land will be levelled to its original functioning topography, followed by revegetation with indigenous grass species.

Kongiwe’s preferred end land use is recommended as to be the extension of the Marievale Bird Sanctuary and the Blesbokspruit wetland, however, this would be at the discretion of the end landowner. To achieve this preferred end land use, the land will be levelled, and remnants of contaminated slime removed. Infiltration and dust generation will be minimised by planting of the soil with appropriate plant/grass species. Lastly, paddocks will remain as a short-term method of containing the surface migration of contaminants into the Blesbokspruit and will be removed once rehabilitation has proven to be successful. Since the TSFs lie within close proximity to the wetland system, it is expected that the flat lying areas directly adjacent to the Blesbokspruit will fill with water once again, thereby extending the Marievale Bird Sanctuary and contributing to ecological success and sustainability

The activities and impacts that are likely to occur during the decommissioning and rehabilitation phase are summarised in Table 8-67.

Table 8-67: Summary of activities and impacts for the decommissioning phase.

ACTIVITY IMPACT DESCRIPTION Exposure of potential contaminated soils during the Erosion and wash off of contaminated soils decommissioning and rehabilitation phase once the resulting in water quality issues in the dumps have been removed. surrounding watercourses.

The ratings and proposed mitigation measures for the impact indicated in Table 8-67, are provided in Table 8-68.

Table 8-68: Significance rating of decommissioning impact 1

NATURE OF IMPACT 1: Erosion and wash off of potential exposed contaminated soils resulting in water quality issues in the surrounding watercourses 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) Long term Medium term Magnitude (Major, Moderate, Minor) Major Minor Probability (Definite, Possible, Unlikely) Possible Possible Calculated Significance Rating (Low, Medium, High 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 immediately.

Mitigation measures

❖ Runoff must be contained onsite through the implementation of paddocks until contaminated soils are removed; ❖ Once contaminated soils are removed, the area must be backfilled with uncontaminated soils, and levelled to its original functioning topography and revegetated; and ❖ Water quality monitoring must continue upstream and downstream until the site has been fully rehabilitated.

8.2.1.21 Groundwater 8.2.1.21.1 Groundwater Quality

Groundwater quality is expected to improve over time as the source of contamination will be removed and the dump footprints will be reinstated as far as possible. This is with the assumption that all TSF material is removed and efficient surface water management is maintained.

Due to the relatively short period over which decommissioning will take place, the positive impacts may not be immediately visible in monitoring programmes. The anticipated improvements in groundwater quality are expected to occur post-decommissioning, in the long-term.

Under these conditions, the water table mound under the various footprints should start to level out. The zone of impact over which sulphate concentrations would exceed acute health standards will reduce in the

long-term but is not expected to dissipate. Historical groundwater contamination will most likely continue to move through the aquifers. The removal of the dumps is however expected to reduce the zone of impact in the long-term.

The impact as a result of the reclamation is anticipated to be positive after the waste material and sand have been removed. Soil and groundwater assessment studies are recommended for the footprint areas, when all tailings material has been removed, to determine the status of these environments.

The impact as a result of the desilting is anticipated to be positive after the waste material and sand have been removed

Table 8-69: Decommissioning Phase water quality impacts.

NATURE OF THE IMPACT: Water quality impacts when silt 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 term) Long term Long term Magnitude (Major, Moderate, Minor) Minor + Moderate + Probability (Definite, Possible, Unlikely) Possible Possible Calculated Significance Rating (Low, Medium, Medium Medium High) Reversibility: (Reversible or Irreversible) Reversable Irreplaceable loss of resources: (Yes or No) No Yes. Combined impact with other mining activities in the area, Cumulative impacts (yes or no) including the Vlakfontein Quarry, industrial activities and waste and sanitation management problems Mitigation measures

❖ Monitor groundwater quality in all boreholes, with the condition that intercept trenches and later, contamination capture wells will have to be installed in the alluvial if the monitoring shows deterioration during operations or post decommissioning. ❖ Maintain sound surface runoff management to ensure that all dirty runoff is contained and diverted to the paddocks.

8.2.1.21.2 Groundwater Quantity

There will be no impacts on the groundwater quantity during decommissioning. The reclamation activities and addition of water will have stopped and any form of seepage of contaminated water to the subsurface will reduce and ultimately stop, apart from precipitation.

NATURE OF THE IMPACT: Reduction in aquifer yield

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) Medium term Medium term Magnitude (Major, Moderate, Minor) Minor + Minor + Probability (Definite, Possible, Unlikely) Definite Definite 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 groundwater levels in all boreholes.

8.2.1.22 Air Quality

See Table 8-18 in the construction phase.

8.2.1.23 Heritage and Palaeontology

No impacts are envisioned for decommissioning.

8.2.1.24 Social Impact

Refer to Chapter 7, section 7.10.7 for a description of the anticipated social impacts of the proposed project.

Decommissioning 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 site, and will constitute a reserve of trained workforce.

Table 8-70: Impacts on Job security and skills development

NATURE OF THE IMPACT: JOB CREATION 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 Low Medium Reversibility: Not applicable

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

Mitigation measures

❖ Offer a post retrenchment programme designed to equip those that have been retrenched with knowledge and skills; ❖ Post retrenchment programme can include computer courses, soft skills, construction and moving machinery

Table 8-71: Impact on economic revenue

NATURE OF THE IMPACT: INCREASED ECONOMIC REVENUE Impact Rating Without Impact Rating with Mitigation Mitigation Extent Local Local

Duration Medium term Medium term

Magnitude Moderate+ Major+

Probability Possible Definite

Calculated Significance Rating Medium High Impact Status: Positive Positive Reversibility: Not applicable Irreplaceable loss of resources: Not applicable Can impacts be enhanced: Yes Residual impacts ❖ Developed economy. ❖ Increased capacity to develop and maintain livelihood strategies Mitigation measures ❖ Preference should be given to capable subcontractors who based within the local municipal area; ❖ Ergo to source local suppliers, HDSAs and Small, Medium and Micro-sized Enterprises (SMMEs) ❖ Encourage the company’s existing suppliers to enter into a Joint Venture (JV) with local SMMEs to aid with the transfer of skills; ❖ Use the Department of Trade and Industry’s (DTI) codes of good practice and guidelines from the Mining Charter to guide the procurement process; ❖ Align skills development to build capacity of SMMEs.

Table 8-72: Impacts on the availability of alternative land uses

NATURE OF THE IMPACT: ALTERNATIVE LAND USES Impact Rating Without Mitigation Impact Rating with 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 Medium High Reversibility: (Reversible or Irreversible) N/A Irreplaceable loss of resources: (Yes or No) No Can impacts be enhanced: (Yes or No) Yes 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 as per the MPRDA; ❖ The applicant to apply for a land clearance certificate from the NNR-upon approval of the clearance certificate, the applicant should comply with the conditions stipulated in the clearance certificate

Table 8-73: Creation of informal settlements

NATURE OF THE IMPACT: CREATION OF INFORMAL SETTLEMENTS Impact Rating Without Impact Rating With Mitigation Mitigation Extent Local Local

Duration Short term Short term

Magnitude Moderate - Major-

Probability Possible Definite

Calculated Significance Rating High Medium Impact Status: Negative Negative 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; ❖ Security patrols should be implemented to monitor the perimeters of the project site thereby providing an increased security presence to prevent unauthorized access; and ❖ Ergo to collaborate with local authorities (EMM, the local South Africa Police Services, the relevant landowner and the Community Policing Forum to establish standard operating procedures for the control and/or removal of unauthorised individuals; ❖ Ergo to collaborate with the EMM and implement EMM’s land use management system to prevent illegal settlements.

Table 8-74: Safety impacts

NATURE OF THE IMPACT: SAFETY IMPACTS Impact Rating Without Impact Rating with Mitigation Mitigation Extent Local Local

Duration Medium term Medium term

Magnitude Major - Medium-

Probability Possible Definite

Calculated Significance Rating High Medium

Impact Status: Negative Negative

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;

❖ All project infrastructure should be in secure area to prevent unauthorized access and therefore potential health and safety risks;

❖ Develop a comprehensive safety management plan protect the health and safety of all personnel and the property on or near the site;

❖ Community members, including illegal miners, should be made aware of the hazards of accessing mine dumps through safety signs at the reclamation and deposition sites.

Table 8-75: Impacts on movement patterns

NATURE OF THE IMPACT: DISRUPTION IN DAILY MOVEMENT PATTERNS

Impact Rating Without Impact Rating with Mitigation Mitigation Extent Local Local

Duration Medium term Short term

Magnitude Moderate - Medium-

Probability Possible Definite

Calculated Significance Rating Medium Low Impact Status: Negative Negative Reversibility: Not applicable Irreplaceable loss of resources: Not applicable Can impacts be enhanced: No Residual impacts ❖ Restricted access which might disrupt daily movement patterns Mitigation measures ❖ Adhere to the mitigation measures as recommended in the Traffic Impact Assessment; ❖ A grievance management mechanism should be in place to receive incident related queries; ❖ Safety awareness should be considered - the applicant should consider communicating the risks of wandering to site and the safety aspect with the affected communities.

Table 8-76: Town planning and residential interface

NATURE OF IMPACT: IMPACT ON SPATIAL DEVELOPMENT FUTURE LAND USE Impact Rating Without Impact Rating With Mitigation Mitigation Impact Status: (positive or negative) Negative Negative Extent Local Local Duration Long term Medium Term Magnitude Major- Minor - Probability (Definite, Possible, Unlikely) Possible Possible Calculated Significance Rating Medium Low Reversibility: (Reversible or Irreversible) Irreversible Irreplaceable loss of resources: (Yes or No) No

Can impacts be enhanced: (Yes or No) No Residual impacts

❖ Delayed development and increase on current housing backlogs

Mitigation measures

❖ Maintain relationships with the relevant stakeholders and continue informing stakeholders about the progress of the project and prospects once the reclamation process is completed.

Table 8-77: Intrusive impacts

NATURE OF IMPACT: REDUCED DUST LEVELS AND RISE IN ASSOCIATED HEALTH IMPACTS Impact Rating Without Mitigation Impact Rating with Mitigation Impact Status: (positive or negative) Positive Positive Extent Local Local Duration Medium term Short Term Magnitude Moderate- Minor - Probability Definite Definite Calculated Significance Rating Low Medium Reversibility: (Reversible or Irreversible) Irreversible Irreplaceable loss of resources: (Yes or No) Yes Can impacts be enhanced: (Yes or No) No Residual impacts

❖ Improved quality of life

Mitigation measures

❖ Adhere to all measures implementable in the EIA and EMP reports.

Table 8-78: Ecosystem Services impacts

NATURE OF IMPACT: IMPROVED ECOSYSTEM SERVICES Impact Rating Without Mitigation Impact Rating with Mitigation Impact Status: (positive or negative) Positive Positive Extent Local Local Duration Medium term Short Term Magnitude Moderate- Minor - Probability Definite Definite

Calculated Significance Rating Low Medium Reversibility: (Reversible or Irreversible) Irreversible Irreplaceable loss of resources: (Yes or No) Yes Can impacts be enhanced: (Yes or No) No Residual impacts

❖ Improved ecosystem services

Mitigation measures

❖ Adhere to all measures implementable in the EIA and EMP reports.

8.2.1.25 Noise

Final decommissioning activities will have a noise impact lower than either the construction or operational phases. This is because decommissioning activities normally take place during the day using minimal equipment (due to the decreased urgency of the project). While there may be various activities, there is a very small risk for any additional noise impact.

8.2.1.26 Traffic

Refer to impacts assess in Section 8.2.1.9.

Post-Decommissioning Impacts

The following activities are expected to occur during the post-decommissioning phase of the project.

Table 8-79: Summary table of the Activities associated with this post-decommissioning phase of the project

ACTIVITY DESCRIPTION Post-Decommissioning 1 Rehabilitation and Monitoring.

8.2.1.27 Surface Water

Should rehabilitation be successfully implemented, then it is unlikely that any negative impacts will occur during the post decommissioning phase. The removal of the TSFs is likely to result in a long-term positive impact on the surrounding watercourses, provided that rehabilitation is successfully implemented.

8.2.1.28 Groundwater 8.2.1.28.1 Groundwater Quality

Overall, there should be an improvement in the groundwater qualities post decommissioning as the source of contamination has been removed.

As discussed earlier, salt and metal salt loads to the wetland associated with the Blesbokspruit can be reduced by more than 80% through effective tailings removal and footprint soil amelioration. In addition, the area over which groundwater quality would exceed unacceptable levels in terms of the Blesbokspruit In-stream Water Quality would be reduced. This is as a result of the removal of the source to groundwater contamination and flushing with clean rainwater recharge.

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 8-80: Post Decommissioning Phase water quality impacts

NATURE OF THE IMPACT: Groundwater quality impacts after silt 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 Medium Reversibility: (Reversible or Irreversible) Reversable Irreplaceable loss of resources: (Yes or No) No Cumulative impacts (yes or no) Yes. Mitigation measures

8.2.1.28.2 Groundwater Quantity

No impact is expected on the water quantity post-reclamation.

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 and is 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 project. 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 decommissioning (i.e. such as when the area is operated as another functional entity like agricultural practises).

8.2.1.29 Biodiversity

Cumulative impacts are important for this project. The combined effect of the possible remobilisation of the metals could add to the already existing bioaccumulation of other heavy metals that have leached into the surrounding areas and water of the Blesbokspruit. The increase in human presence in the area can also have a negative effect on the fauna of the nearby protected areas and this could disrupt bird migratory patterns.

Table 8-81: Cumulative impact rating for surface water quality

NATURE OF IMPACT: Reclaiming of gold: Pollution discharge into the stream, bioaccumulation of heavy metals OVERALL IMPACT OF THE PROJECT CUMULATIVE IMPACT OF THE PROJECT AND

CONSIDERED IN ISOLATION OTHER PROJECTS IN THE AREA Impact Status: (positive or Negative Negative negative) Extent (Local, Regional, Local Local International) Duration (Short term, Medium Medium term Medium term term, Long term) Magnitude (Major, Moderate, Moderate Moderate Minor) Probability (Definite, Possible, Possible Possible Unlikely) Calculated Significance Rating Medium Medium (Low, Medium, High) Reversibility: (Reversible or Reversible Reversible Irreversible) Irreplaceable loss of resources: No No (Yes or No)

NATURE OF IMPACT: Reclaiming of gold: Pollution discharge into the stream, bioaccumulation of heavy metals Can impacts be enhanced: (Yes Yes Yes or No) Mitigation measures

❖ The disturbance of the area can be mitigated through the successful rehabilitation of the area. ❖ The surface water is polluted currently, however by using the silt drying process the ground water will also be polluted, this can be mitigated through the use of a successful water drainage system. ❖ Continues dust suppression will be needed, this can be achieved through the spraying of dust suppressants along with the establishment of indigenous grass species

8.2.1.30 Surface Water

Cumulative impacts that result from the incremental impact of the proposed activities on a common resource when added to the impacts of other past, present or reasonably foreseeable future activities. Cumulative impacts can occur from the collective impacts of individual minor actions over a period of time and can include both direct and indirect impacts.

The Project is located in a catchment that is highly impacted by mining, urban and industrial activities. The implementation of a sound SWMP is crucial to contain contaminated runoff from the operational area. The monitoring and maintenance of the implemented SWMP is of utmost importance, to ensure that spillages into the downslope watercourses do not occur. Furthermore, the implementation of a rehabilitation plan that ensures that the area is free draining and appropriately vegetated, could enhance the catchment water quality. Should the above not be done, then in the long term, the proposed project has the potential to cumulatively add to the already deteriorated water quality within the Blesbokspruit catchment.

The cumulative impact of the proposed project on the surface water quality of the catchment is rated in Table 8-82

Table 8-82: Cumulative impact rating for surface water quality

NATURE OF IMPACT: Should dirty water runoff not be contained and an appropriate rehabilitation plan for the area not be undertaken and successfully implemented, then the proposed project has the potential to add cumulatively to the already deteriorated surface water quality of the catchment OVERALL IMPACT OF THE CUMULATIVE IMPACT OF THE PROJECT CONSIDERED IN PROJECT AND OTHER PROJECTS ISOLATION IN THE AREA Impact Status: (positive or negative) Negative Negative Regional Local Extent (Local, Regional, International)

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

Calculated Significance Rating (Low, High 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 this report, and in accordance with GN R704 regulations; • Removal of all tailing’s material and successful rehabilitation of the area to a free draining and vegetated area; and • Water quality monitoring upstream and downstream of the proposed project until rehabilitation is successfully completed

8.2.1.31 Groundwater

Cumulative impacts result from the incremental impact of the proposed activity on a common resource when added to the impacts of other past, present or reasonably foreseeable future activities (e.g. discharges of high salt or metal loads to a river that combine to cause a reduction in the use of the resource that is greater than the additive impacts of each pollutant). Cumulative impacts can occur from the collective impacts of individual minor actions over a period and can include both direct and indirect impacts.

The Marievale project is near other historical tailings deposition sites, current mining activities, industrial activities and formal and informal residential developments. Cumulatively all these activities contribute to the surface and groundwater quality impacts identified during the Marievale study and could also impact the groundwater resources, especially in terms of quality.

The outcome of the Marievale dump reclamation groundwater assessment indicates that the reclamation activities will have an overall positive impact on the receiving environment. During the impact assessment, the other TSFs present to the north of the Marievale dumps were included to assess cumulative impacts. Due to a lack of data and understanding on how these dumps not related to the Marievale project were managed, the cumulative impacts associated with these are indicative and do not represent a detailed assessment.

Establishing monitoring boreholes in-between dumps 7L5/ 7L6 and 7L7 and downstream from dump 7L7 are required to assess the implications that reclamation will have on the aquifers and to identify if poor quality groundwater will reach a sensitive receptor. The monitoring data recorded as operations progress must be used to update the monitoring programme.

Table 8-83: Cumulative impact rating for groundwater

NATURE OF THE CUMULATIVE IMPACT: Cumulative impact of Overall impact of the project considered in the project and other projects isolation in the area 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) Moderate Major Probability (Definite, Possible Unlikely) Definite Definite Calculated Significance Rating (Low, Medium Medium Medium, High) Reversibility: (Reversible or Reversable Reversable Irreversible) Irreplaceable loss of resources: (Yes or No No No) Can impacts be enhanced: (Yes or No) Yes Yes Mitigation measures

❖ Ensure that contaminated surface and groundwater from the adjacent mining and industrial activities are effectively managed and that polluted water is not allowed to enter the Blesbokspruit system.

8.2.1.32 Air Quality

Emissions from the reclamation of the Marievale Project TSFs 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 improve the air quality of the surrounding areas.

8.2.1.33 Heritage and Palaeontology

The following cumulating impacts are expected for the Marievale Project.

Table 8-84: Cumulative impacts on heritage resources in the area

NATURE OF THE CUMULATIVE IMPACT: HISTORICAL STRUCTURES – NON-MINING Overall impact of the project Cumulative impact of the project considered in isolation and other projects in the area

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) Moderate Moderate Probability (Definite, Possible, Unlikely) Possible Possible Calculated Significance Rating Medium Medium Reversibility: (Reversible or Irreversible) irreversible Irreversible Irreplaceable loss of resources: (Yes or No) Yes Yes Can impacts be enhanced: (Yes or No) N/A N/A Mitigation measures

❖ Demarcation and avoidance; documentation, permit required if alteration/destruction

Table 8-85: Cumulative impacts on heritage resources in the area: Historical Structures - Mining

NATURE OF THE CUMULATIVE IMPACT: HISTORICAL STRUCTURES – MINING Overall impact of the project Cumulative impact of the project considered in isolation and other projects in the area 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) Minor Moderate Probability (Definite, Possible, Unlikely) Definite Possible Calculated Significance Rating Medium Medium Reversibility: (Reversible or Irreversible) irreversible Irreversible Irreplaceable loss of resources: (Yes or No) Yes Yes Can impacts be enhanced: (Yes or No) N/A N/A Mitigation measures

❖ Demarcation and avoidance; documentation, permit required if alteration/destruction

Table 8-86: Cumulative impacts on heritage resources in the area: Burial grounds and graves

NATURE OF THE CUMULATIVE IMPACT: BURIAL GROUNDS AND GRAVES Overall impact of the project Cumulative impact of the project considered in isolation and other projects in the area 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 Major Probability (Definite, Possible, Unlikely) Possible Possible Calculated Significance Rating High High Reversibility: (Reversible or Irreversible) irreversible Irreversible Irreplaceable loss of resources: (Yes or No) Yes Yes Can impacts be enhanced: (Yes or No) N/A N/A Mitigation measures

❖ All burial grounds and graves to be avoided and demarcated, with at least a 50m buffer ❖ If there will be a direct, unavoidable impact, then social consultation will be required regarding the possibility of relocation; this is very time-consuming

8.2.1.34 Social Impact

According to the consultations and interviews undertaken, there are proposed developments within the project area such as the Johannesburg Roads Agency. From a social perspective, some of the most significant cumulative impacts relate to the following aspects:

8.2.1.34.1 Industry Training

An increase in the levels of skills present in the community will increase employment opportunities and will strengthen local economic development. Development of skills can be transferred to other sectors which will increase the potential for employment opportunities.

8.2.1.34.2 An increase in Direct Project Nuisance Factors

An increase in nuisance factors namely, noise, air pollution and increased number of vehicles could further impact negatively on the sense of place for some receptors. It is likely that the levels of traffic usage and dust will increase particularly during the construction phase, when there are construction vehicles travelling to and from the construction sites. This increase in traffic will have a cumulative impact for other surrounding businesses and private individuals using the roads in the area.

8.2.1.35 Noise

Noise from the reclamation activities may cumulatively add to existing noise levels in the area. The maximum change would be less than 3 dBA, and this is insignificant.

8.3 Specialist Studies Conclusions and Recommendations

The preceding sections of Chapter 8 of this report together with the specialist studies contained within Appendices D of this EIA provide a detailed assessment of the potential impacts that may result from the reclamation and reprocessing of the Marievale project.

This section aims to conclude the environmental assessment providing a summary of the results and conclusions of the assessment of the project as found in the Specialist Studies. In so doing, it draws on the information gathered as part of the EIA process, the knowledge gained by the environmental specialists and the EAP and presents a combined and informed opinion of the environmental impacts associated with the project.

No environmental fatal flaws were identified in the detailed specialist studies conducted, provided that the recommended mitigation measures are implemented. These measures include, amongst others, the avoidance of highly sensitive features within the project site by the development footprint and the undertaking of monitoring, as specified by the specialists.

The potential environmental impacts associated with Proposed Project identified and assessed through the EIA process include:

Biodiversity and Wetlands

8.3.1.1 Proposed Mitigation Actions

The possibility of the project area (the section to the west) being incorporated into the reserve areas after rehabilitation should be investigated. Currently, the land use classification of these areas is mining according to the Ekurhuleni municipality environmental management framework (Ekurhuleni Metropolitan Municipality, 2008), this will require reclassification. Other options for rehabilitation such as re-grassing of the area and the construction of an artificial wetland should also be investigated. Further recommendations include;

❖ All mitigation measures must be strictly adhered to; and ❖ Rehabilitation of the wetlands expected to be degraded during the proposed activities must be undertaken

8.3.1.2 Conclusion

The completion of a study, in conjunction with the detailed results from the survey, means that there is a high confidence in the information provided. The survey, which was completed, and the corresponding studies resulted in good site coverage, within the proposed footprint area, assessing the major habitats and ecosystems, obtaining a general species (fauna and flora) overview and observing the major current impacts. The wetlands and secondary grasslands still function as an ecosystem, habitat and/or important corridors for various species and as such, it was given a high sensitivity, while the degraded habitat and transformed habitat were given a Low-Moderate and Low sensitivity respectively. Overall, the project area and surrounds are regarded as sensitive due to the proximity to the Marievale Bird Sanctuary and the Blesbokspruit Ramsar site as well as the number of SCCs recorded.

Sixteen (16) HGM units were identified within the 500 m regulated area, all differing in size, extent, level of modification, level of ecosystem services provided, types of services provided and the sensitivity of the wetlands. Various hydrophytic vegetation species were identified with four main hydromorphic soils (Katspruit, Dresden, Kroonstad and Wasbank soil form) were classified within the delineated wetlands. One

main wetland system (HGM 15, the Blesbokspruit system) was identified to be the most valuable system within the 500 m regulated system (in regard to ecosystem services) as well as the highest sensitivity.

8.3.1.3 Impact statement

The proposed activities include the set-up of a reclamation site, the reclamation of tailings facilities, as well as the construction, operation and decommissioning of pipelines proposed to transport reclaimed tailings material.

Considering the findings of the respective studies, from a terrestrial ecology perspective no fatal flaws were identified for the proposed project. Should the avoidance and mitigation measures prescribed be implemented, the significance of the considered impacts for all aspects is expected to be low. It is thus the opinion of the specialists that the project may proceed with caution, but only if the prescribed mitigation measures and recommendations are implemented.

The Biodiversity and Wetland specialists agree with the proposal to allow the Marievale Bird Sanctuary and the Blesbokspruit wetland to extend. Furthermore, various mitigation measures have also been prescribed to ensure the conservation of wetlands that are not within buffer-size proximity to the proposed footprint areas. Given the adherence to these measures and recommendations, it is the specialist’s opinion that the proposed activities may proceed with caution.

Surface Water

In conclusion, 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 mining activities, in accordance with the conditions stipulated in GN R704. Monitoring and maintenance of stormwater measures is of utmost importance and should be conducted as outlined in this report. Furthermore, water quality monitoring must continue upstream and downstream of the proposed mining areas. The removal of the TSFs is expected to have a positive impact in the long-term on the surrounding watercourses, provided that rehabilitation is successfully undertaken.

The following is recommended:

❖ 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. It must be noted that the Marievale TSFs are historical dumps that were created prior to GN R704, however, it is proposed that the required licencing from DHSWS or exemption from GN R704 is obtained for any mine infrastructure proposed within the floodline or within 100 m of a watercourse; ❖ The proposed pipelines are elevated above the 1:100 year floodline with support structures capable of handling a 1:100 year flood; ❖ The floodline determination indicated that Dumps 7L6 and 7L7 are at risk of flooding under a 1:100 year flood. It is recommended that suitably designed flood protection measures are placed along the eastern and southern sides of Dump 7L6, as well as along the northern and eastern sides of Dump 7L7; ❖ The SWMPs are implemented, and all conditions specified in GN R704 are taken into account;

❖ The impact mitigation measures are implemented; ❖ The monitoring plans are implemented; ❖ The existing trench running along the northern side of Dumps 7L5 and 7L6 is desilted and upgraded according to the SWMP; and ❖ The existing toe paddocks around the dumps are desilted and upgraded according to the SWMP

Groundwater

During the 2019 hydrocensus 22 boreholes were identified. Ten of the 22 boreholes include 2 to 3 piezometer tubes, for measuring groundwater quality and water level depths at various depth intervals. The construction and depth information of these sites were not available. No boreholes were identified in-between dumps 7L5/ 7L6 and dump 7L7, or downgradient of dump 7L7.

The groundwater level below surface varied between a maximum depth of 29.65 mbgl (borehole Mari10) and close to the Vlakfontein Quarry, to 1.3 m bgl at Mari1. The correlation between topography and groundwater elevation is approximately 93%. This means that the depth to groundwater correlates well with the surface elevations, indicating that on a local scale groundwater flow follows topography.

Five water samples were collected from the project area during the 2019 hydrocensus. Based on the water quality results, the following conclusions were drawn (SANS 241:2015).

8.3.1.4 Current Water Quality:

Groundwater in the project area represents a Calcium/ Magnesium-sulphate water, indicating contaminated water. Based on the water quality results, the following conclusions were drawn:

1. Chronic Health effects: ❖ Manganese – Borehole Mari1 measured a manganese concentration that could result in chronic health effects (0.683 mg/L). ❖ Nickel – An elevated nickel concentration was measured at borehole Mari10. Borehole Mari10 is downstream from the Vlakfontein Quarry. The 2017 sampling by Aquanzi GeoConsultants CC also yielded elevated nickel concentrations in the pit lake water at the Vlakfontein Quarry. Historical leach tests suggest that the nickel is leaching from the carbonaceous shale horizons. 2. Acute Health effects: ❖ Sulphate – Sulphate concentrations were elevated in boreholes Mari1 and Mari4, both sites are located close to the footprint of a TSF.. 3. Aesthetic effects: ❖ Manganese – Boreholes Mari4 and Mari18D measured manganese concentrations that could pose an aesthetic concern (0.30 and 0.19 mg/L respectively). ❖ Sodium – Borehole Mari4 exceeds the aesthetic limits for drinking water. ❖ Turbidity – Turbidity was high in boreholes Mari1, Mari10 and Mari18S. 4. Magnesium – High magnesium concentrations were measured boreholes Mari1 and Mari4.

5. Total hardness – Very high total hardness values were measured in 4 of the 5 sites. Borehole Mari10 has moderately hard water

Most of these are only elevated in boreholes Mari1 and Mari4. Based on the SANS241 drinking water guidelines and on the sampled water results, the sampled water from Mari1, Mari4 and Mari10 is not fit for human consumption (unless treated). The element concentrations seem to reduce in the groundwater, further away from the TSFs. This relates to dilution and a change in pH conditions – more alkaline further away from the TSF and the buffering effect of the geological formations and associated minerals.

The historical surface and groundwater quality data indicate:

❖ High salt and metal concentrations have been recorded for the various surface water retention ponds / facilities at the Daggafontein TSF. The water is acidic with sulphate concentrations in the order of 4768 mg/L; iron concentrations in the order of 35.8 mg/L and uranium concentrations in the order of 1.5 mg/L, amongst others. pH values are in the order of 3 to 5. ❖ Groundwater concentrations, associated with boreholes near the TSF footprint, indicate already impacted groundwater, with sulphate concentrations varying between 970 and 2400 mg/L at the Marievale TSF project site and approximately 600 to 4000 mg/L at the Daggafontein TSF boreholes. The iron concentrations are predominantly between 0.025 mg/L and 0.6 mg/L, with high concentrations previously measured at DT9 (approx. 220 mg/L). The uranium concentrations were often below the detection limit. pH values are near neutral, except for DT9 where acid conditions prevailed (average pH of 4). The general element concentrations seem lower at the Marievale TSF study area compared to the Daggafontein TSF area. ❖ The ambient groundwater concentrations are much lower compared to groundwater qualities near the various TSFs with sulphate concentrations in the order of 18 mg/L in the Daggafontein area and iron concentrations in the order of 0.04 mg/L; pH levels are near neutral. In the Marievale project area the sulphate concentrations are in the order of 70 mg/L, the iron concentrations in the order of 0.28 mg/L; pH levels are near neutral. ❖ Blesbokspruit water qualities – sulphate concentrations vary between 500 and 600 mg/L. The iron concentrations vary between 0.016 mg/L and 0.53 mg/L. The uranium concentrations were between 0.009 and 0.032 mg/L. pH values are near neutral.

With the exception of the Malmani dolomite, all the 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. The dolomite underlying the area is classified as a major aquifer system, which are viewed as a high yielding aquifer with generally good quality water.

The TSF are all located on shales and clay of the Vryheid and Dwyka Formations of the Karoo Supergroup. These formations are characterised by low permeabilities. The Karoo sediments are underlain by Malmani dolomite, which sub-outcrops against the Karoo sediments in the project area. A regional set of sills, collectively referred to as the Green Sill, have intruded the dolomite from depths of 60 m in this area. It is thought that this sill will retard groundwater flow in vertical direction. Process water for hydraulic mining will

be supplied by Ergo. The water cycle operates essentially as a closed circuit, with water being recovered from the slurry at the Ergo Plant and from tailings at the Brakpan/Withok TSF

8.3.1.5 Impact Assessment:

The outcome of the impact assessment indicates that:

❖ The proposed dump reclamation will not have any significant impacts on the groundwater quantity, provided ponding isn’t allowed in the paddocks; ❖ Removal of the dumps will have a long-term positive impact on the groundwater quality, as the source of contamination will be removed; and ❖ The risk of groundwater contamination during the hydraulic mining is possible due to formation of acidic waters (AMD). This can be mitigated with good surface water management and limiting the time water is allowed to stand on surface before being pumped away.

8.3.1.6 Recommendations

It is recommended that at least three dedicated monitoring boreholes are drilled down gradient of the Marievale dumps to obtain site specific aquifer information. At each of the proposed monitoring borehole targets, a cluster of one shallow and one deep monitoring borehole must be drilled to assess impacts on the shallow weathered and deeper fractured aquifers, and downstream from the various dump sites (Figure 26). The depth of the deeper boreholes must be at least 50 m. The depth of the paired shallow borehole at each monitoring target must be drilled to the depth of weathering, approximately 20 m below surface. This is true for the Karoo/dolomite monitoring only.

In terms of the alluvial aquifer, shallow monitoring boreholes are recommended along the eastern perimeter of the two study areas to monitor groundwater quality changes over time. If there is a continuous negative impact on the alluvial aquifer then cut-off trenches are recommended to intercept poor quality seepage water. This water must be pumped to the pollution control dams and pumped to the Ergo Plant for re-use. In addition, it is recommended that hydrocensus boreholes Mari1 to Mari4 are included in the Ergo monitoring programme.

Soil and groundwater assessments of the dump footprint area are recommended after removal of the tailings material to define the status of these environments and determine mitigation, management and monitoring requirements, post-removal.

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 paddocks and not allowed to freely drain away from the dump areas. Pooling of water must not be allowed on open surfaces, except if lined. The reclaimed slurry and any water must be removed from the exposed surfaces (immediately) to avoid seepage of contaminated water into the shallow weathered and deeper fractured and karst aquifers. Ergo must ensure that paddocks are designed to contain all dirty water generated during the reclamation process to prevent overflows and spillages.

It is the opinion of Groundwater specialist that the reclamation of the Marievale TSF 7L5, 7L6 and 7L7 can proceed, if good surface water / storm water management is in place and maintained. The project must further commit to full tailings removal and not undertake selective tailings reclamation in the short term there could be water quality impacts (increase in salts and metals) if water on the surface is not managed effectively. Overall, the project will deliver a positive impact if the TSFs are removed and footprint areas are rehabilitated

Air Quality

❖ Emissions from the TSFs in the current, undisturbed state are expected to be causing elevated ambient concentrations of both PM10 and PM2.5 in downwind areas on windy days. Exceedances of the NAAQS may be expected up to 1 200 m to the west of 7L5, up to 800 m to the south and west of 7L7 and up to 650 m to the east of the TSFs. The affected areas include agricultural land, parts of the Marievale Bird Sanctuary, parts of the Marievale golf course and nearby residences. ❖ The modelling of the TSFs indicates that, if reclamation of the TSFs is conducted conservatively, with the band stripped of vegetation not exceeding a width of 40 m, the area of exceedances is likely to increase by approximately 600 m beyond the status quo emission situation. However, as reclamation progresses, if all mitigation methods are adhered to, the area of impact is expected to progressively decrease from the status quo emission situation. ❖ Once all tailings material has been removed down to ‘red earth’ ambient concentrations due to emissions from the denuded land are expected to be well below the NAAQS. ❖ The modelling indicates that the removal of the Marievale Project TSFs as a permanent pollution source will, in the long term, improve the air quality of the surrounding areas.

The Marievale Project area lies in the Highveld Priority area for air quality. Therefore, all recommended mitigation measures must be strictly adhered to. Furthermore, emissions must be monitored and if the increase in emissions from the reclamation activities cause the pre-operational phase dustfall levels to rise above the limits set by the National Dustfall Regulations, the mitigation programme will have to be increased until compliance is achieved. This can include reducing the area stripped for reclamation and/or wet suppression of the area stripped for reclamation.

The evaluation of the air quality impacts from mine tailings is based on a series of assumptions. Whilst care has been taken to assess the potential air pollution impact from the mine tailings, further research on tailings emission rates or actual on-site monitoring may result in different conclusions.

Heritage

replaced by modern structures over time. The four burial ground sites are considered to have very high significance and would require mitigation measures. Of the historical structures, nine residential or non- mining structures had a medium heritage significance (grading of IIIB) which would require mitigation measures. Only three historical mining structures sites had a medium heritage significance (grading of IIIB) which would require mitigation measures. The remaining historical structure sites are considered to be of low to no heritage significance.

Most of the sites identified are located in the vicinity of the two pipeline alternatives, while a few are located in the region of the three slimes dams or the three processing plants.

8.3.1.7 Historical structures: Residential or non-mining

Of the 12 single or groups of historical residential or other non-mining related structures, nine of these sites had a medium heritage significance with a heritage grading of IIIB (MV001, MV006, MV018, MV021, MV023, MV028, MV031, MV032, MV036). The impact significance before mitigation on these nine historical residential structures will be Medium negative before mitigation. Implementation of the recommended mitigation measures will modify this impact rating to an acceptable LOW negative.

The remaining sites had a low or negligible heritage significance will not require any mitigation measures. However, a destruction permit may be required if the structure remains are likely to be 60 years or older.

8.3.1.8 Historical structures: Mining

A total of 14 single or groups of mining-related structures were identified. However, only three of these sites had a medium heritage significance with a heritage grading of IIIB (MV003, MV011 and MV036).

8.3.1.9 Burial Grounds and graves

The three informal burial grounds and the municipal cemetery all have a high heritage rating and a heritage grading of IIIA (MV005, MV009, MV025, MV033). However, the Municipal cemetery is anticipated not to be impacted by the project.

The impact significance before mitigation on the three burial ground and graves sites will be High negative before mitigation. Implementation of the recommended mitigation measures will modify this impact rating to an acceptable Medium to Low negative.

8.3.1.10 The historic slimes dams and sand dumps

Although the three slimes dams/dumps are older than 60 years and could technically be described as “man- made structures”, it is the considered opinion of this author that there is no heritage significance attached to the actual slimes dams/sand dumps. However, legally, the historic dumps 7L7, 7L5 and 7L6 may require a permit for their reclamation as they could be 60 years or older. It should also be noted that there is some probability of the presence of historic graves under or adjacent to the historic dumps.

8.3.1.11 Palaeontology

The desktop PIA found that the proposed Marievale Tailings Storage facilities and two pipeline alternatives are underlain by the Malmani Subgroup, (Chuniespoort Group, Transvaal Supergroup), Dwyka Group, Vryheid Formation (Ecca Group) and Karoo Dolerite Suite. The Palaeontological Sensitivity of the Malmani Subgroup is High, the Dwyka Group has a Moderate Palaeontological Sensitivity, the Vryheid Formation has a Very High Palaeontological Sensitivity and Karoo Dolerite Suite has a Zero Palaeontological Sensitivity. This would usually require a field-based assessment to be undertaken on the specific impacts expected.

8.3.1.12 General

It is the heritage specialist’s considered opinion that overall impact on heritage resources is Medium to Low. Provided that the recommended mitigation measures are implemented, the impact would be acceptably low or could be totally mitigated to the degree that the project could be approved from a heritage perspective. The management and mitigation measures as described in the EMP report and have been developed to minimise the project impact on heritage resources.

Social Impacts

The following aspects were considered as part of the assessment of social impacts:

❖ People’s way of life - How they live and work; ❖ Culture - The affected community’s shared beliefs and languages; ❖ Community - Its cohesion, stability, character, services and facilities; ❖ Political systems - The extent to which people are able to participate in decisions that affect their lives, the level of democratisation that is taking place and the resources provided for this purpose; ❖ Environment - The quality of the air and water the community uses, the level of hazard or risk, dust and noise they are exposed, the adequacy of sanitation, their physical safety and their access to and control over resources;

❖ Their fears and aspirations - This relates to the community’s perceptions about their safety, their fears about the future of their community and their aspirations for their future and the future of their children.

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 the 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. The SIA has proposed monitoring and mitigation measures to avoid or minimise negative impacts and enhance positive impacts.

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.

Noise

This EIA determined that the potential noise impact would be of low significance and no additional mitigation is required for the construction and operation phase. The following section highlights potential measures that would reduce the potential noise impact risks.

Ergo must know that community involvement needs to continue throughout the project. Annoyance is a complicated psychological phenomenon; as with many industrial operations, expressed annoyance with sound can reflect an overall annoyance with the project, rather than a rational reaction to the sound itself.

At all stages surrounding receptors should be informed about the project, providing them with factual information without setting unrealistic expectations. It is counterproductive to suggest that the activities (or facility) will be silent or will not impact on them. The magnitude of the sound levels will depend on a multitude of variables and will vary from day to day and from place to place with environmental and operational conditions. Audibility is distinct from the sound level because it depends on the relationship between the sound level from the activities, the spectral characteristics and that of the surrounding soundscape (both level and spectral character).

Environmental Management Objectives are difficult to be defined for noise because ambient sound levels would slowly increase as development pressures increase in the area. This is due to increased traffic and human habitation and is irrespective whether the activity starts. The moment the mine stops noise levels will drop similar to the pre- operation levels (typical of other areas with a similar developmental character).

However, as there are a number of potential noise-sensitive receptors in the area, Environmental Management Objectives will be proposed. These objectives are based on the sound levels criteria for Residential Use (International Best Practice) while considering the National Noise Control Regulations.

As such, the operation may not increase the existing ambient sound levels with more than 7 dB (a disturbing noise and prohibited by the Gauteng Noise Control Regulations).

Traffic Statement

Based on the content of this document, the following summary, conclusions and recommendations are made:

❖ This report is for the planned rehabilitation and silt reclamation of the Marievale Tailing Storage Facilities (Dumps 7L5, 7L6 and 7L7) near Nigel situated on the Remainder of the Farm Vlakfontein 281‐ IR and Remainder of the Farm Vogelstruisbult 127‐IR. ❖ Zoning Rights are already in place for the planned activities. ❖ The site is located approx. 10km north east of Nigel in the Ekurhuleni Metropolitan Municipality. ❖ A total of 12 trips will be generated in the Weekday AM Peak hour and 10 trips during the Weekday PM Peak hour at the site. ❖ Two (2) proposed accesses are proposed. The northern access from the existing Zincor Plant access and the southern access on the Marievale Sanctuary Road. The access roads and geometric details are shown on Drawing 19059/AL/01 and Drawing 19059/KP/01 of the traffic impact assessment. ❖ On‐site traffic circulation was analysed as a swept path analysis for both heavy vehicles and passenger vehicles. Details are shown on Drawing 19059/AL/01 of the traffic impact assessment. ❖ 10 Parking bays are proposed, as well as 2 delivery zones for heavy vehicles are proposed at the site. ❖ A pick‐up and Drop‐off facility needs to be provided with space for at least two minibus‐Taxi’s at the site, as shown on Drawing 19059/AL/01 of the traffic impact assessment.

Access safety measures are as follow:

❖ Speed Limit Signs (R201_B 60km/h) at least 200m from the proposed access road on the Marievale Sanctuary Road to the west of the proposed access road position. ❖ Heavy Vehicles Turning signs (W344) at least 100m from the proposed access road on the Marievale Sanctuary Road to the west of the proposed access road position. ❖ Sight distances of at least 180m in both directions are available on the Marievale Sanctuary Road. This is more than the minimum sight distances required by COTO TMH16. ❖ A Flag Man is proposed in the event of slow‐moving vehicles exiting the proposed access road, a Flag Man will need to regulate traffic and ensure a safe traffic environment with enough space to allow the vehicle(s) to exit. ❖ An internal U‐Turn space needs to be provided to avoid dangerous movements on the road or within the traffic on the Marievale Sanctuary Road and near the Zincor Plant. See Drawing 19059/AL/01 of the traffic impact assessment. ❖ A minimum stacking distance of 24m are required between any gate or boom and the existing mining access at the proposed access road.

The planned activities are supported from a traffic flow and traffic safety viewpoint, provided that the recommendations made in this report are implemented.

8.4 Summarised Environmental Risk Matrix

A detailed description of the methodology utilised to determining the environmental impacts and their respective probability, magnitude and severity is provided in Section 8.1 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.

The EAP and environmental consultants responsible for the compilation of this document, and PPP feel that the Marievale project should be approved, on condition that the Ergo implements all identified management measures and implements the monitoring plan.

Key Findings

RATING PRE- POST RATING POST POST IMPACT CONSTRUCTION OPERATION DECOMMISSIONING CONSTRUCTION OPERATION DECOMMISSIONING MITIGATION DECOMMISSIONING MITIGATION DECOMMISSIONING ❖ Increased ❖ Increased ❖ Availability of Positive (+) Major (high) Major (high) economic economic land use revenue revenue ❖ Improved water ❖ Groundwater ❖ Improved water ❖ Improved water quality ❖ Improved water ❖ Increased ❖ Increased ❖ Job security and quality Moderate quality quality Moderate ❖ Health impacts quality Positive (+) economic economic skills ❖ Job security and (medium) ❖ Availability of land (medium) from dust revenue revenue development skills use Ecosystem development services ❖ Improved water ❖ Dust ❖ Reduction in quantity ❖ Improved water ❖ Job security and aquifer yield ❖ Health impacts quantity ❖ Reduction in Positive (+) Minor (low) skills ❖ Job security and from dust Minor (low) ❖ Disruption of aquifer yield development skills ❖ Ecosystem movement development services patterns

No Impact No Impact No Impact ❖ Loss of CBA and ❖ Habitat ESA areas disturbance ❖ Disturbance of ❖ Fauna habitat displacement ❖ Fauna ❖ Loss of migration displacement corridors ❖ Loss of migration ❖ Loss of floral corridors species ❖ Alien vegetation ❖ Loss of ❖ Alien vegetation encroachment ❖ Vegetation biodiversity encroachment ❖ Faunal clearance for ❖ Alien vegetation ❖ Erosion displacement pipelines outside Negative (-) ❖ Job security and encroachment ❖ Vegetation ❖ Erosion wetlands skills ❖ Erosion clearance ❖ Damage to ❖ Impact on Minor (low) ❖ Daytime Noise development Minor (low) ❖ Vegetation ❖ Loss of avifauna heritage groundwater ❖ Noise clearance due to powerlines structures quality ❖ Vegetation ❖ Loss of CBA and ❖ Spatial ❖ Noise clearance for ESA areas development and ❖ Increased traffic pipelines outside ❖ Flooding of land use ❖ Vehicle impacts wetlands operation ❖ Noise ❖ Impact on ❖ Water quantity groundwater reduction quality ❖ Leaks from ❖ Damage to pipelines heritage ❖ Damage to structures heritage ❖ Ecosystem structures services impacts ❖ Ecosystem

RATING PRE- POST RATING POST POST IMPACT CONSTRUCTION OPERATION DECOMMISSIONING CONSTRUCTION OPERATION DECOMMISSIONING MITIGATION DECOMMISSIONING MITIGATION DECOMMISSIONING ❖ Disruption of services impacts movement ❖ Disruption of patterns movement ❖ Creation of patterns informal ❖ Creation of settlements informal ❖ Noise settlements ❖ Increased traffic ❖ Daytime Noise ❖ Traffic congestion ❖ Nighttime noise ❖ Vehicle impacts ❖ Loss of CBA and ❖ Habitat ESA areas disturbance ❖ Disturbance of ❖ Fauna habitat displacement ❖ Fauna ❖ Loss of migration displacement corridors ❖ Loss of migration ❖ Loss of floral ❖ Alien vegetation corridors species encroachment ❖ Loss of ❖ Alien vegetation ❖ Faunal ❖ Surface water biodiversity encroachment displacement ❖ Loss of habitat for runoff ❖ Alien vegetation ❖ Erosion ❖ Dust protected species ❖ Damage to graves encroachment ❖ Vegetation ❖ Damage to ❖ Dust from and burial sites ❖ Erosion clearance heritage vegetation ❖ Safety impacts ❖ Vegetation ❖ Dust ❖ Damage to graves structures stripping ❖ Land use impacts Moderate clearance ❖ Loss of CBA and Moderate and burial sites Negative (-) ❖ Economic ❖ Damage to graves ❖ Job security and (medium) ❖ Dust from ESA areas (medium) revenue and burial sites skills vegetation ❖ Water quantity ❖ Disruption of ❖ Safety impacts development stripping reduction movement ❖ Land use impacts ❖ Creation of ❖ Damage to ❖ Damage to patterns ❖ Exposure to dust informal heritage heritage ❖ Spatial fallout settlements structures structures development and ❖ Safety impacts ❖ Ecosystem ❖ Ecosystem land use services impacts services impacts ❖ Disruption of ❖ Disruption of movement movement patterns patterns ❖ Creation of ❖ Creation of informal informal settlements settlements ❖ Traffic congestion ❖ Nighttime noise ❖ Loss of habitat for ❖ Loss of avifauna ❖ Erosion protected species due to powerlines ❖ Damage to graves ❖ Damage to graves ❖ Surface water and burial sites Negative (-) Major (high) and burial sites runoff ❖ Creation of Major (high) ❖ Safety impacts ❖ Flooding of informal ❖ Land use impacts operation settlements ❖ Exposure to dust ❖ Leaks from ❖ Safety impacts

CHAPTER 9: INFORMATION FOR CONSIDERATION 9.1 Assumptions, Uncertainties and Gaps in Knowledge

The following assumptions and limitations are applicable to this EIA report:

Biodiversity and Wetlands

The following limitations are relevant for this project:

❖ As per the scope of work, the fieldwork component of the assessment comprised of one assessment only, which was conducted during the wet season (7-8 of January 2020); ❖ GIS data layers might be outdated and with some expected level of inaccuracy; ❖ The use of two of the main wetland indicators namely hydromorphic soils and hydrophytic vegetation was limited selected portions of the project area; ❖ Areas considered to be at risk due to the project were prioritised for inspection. Areas not deemed to be at risk were considered at a higher level, with limited ground-truthing being undertaken; ❖ The proposed pipeline routes were amended after the site assessment, which has resulted in a larger 500 m regulated area which was not assessed; ❖ Access to selected areas was not possible, with unsupervised access not encouraged due to safety concerns. Areas that could not be access have also been considered at a higher level of analysis; ❖ The GPS used for wetland delineations is accurate to within five meters. Therefore, the wetland delineation plotted digitally may be offset by at least five m to either side; and ❖ Despite these limitations, a comprehensive desktop study was conducted, in conjunction with the detailed results from the surveys, and as such there is a moderate confidence in the information provided.

Figure 9-1: Regulated Buffer Area of 500 m

Surface Water

The floodlines have been prepared for the purposes of the EIA and WULA and are indicative. The floodlines should not be used for design purposes.

Groundwater

The groundwater model presented in this report is based on the aquifer conceptualisation discussed earlier in this report. There are however a number of assumptions and limitations that affect the confidence level of the simulations results. These include:

❖ Site-specific aquifer parameters are not available for the project area. To complete an assessment of the impacts of silt excavation on groundwater quality, literature-based aquifer parameters were considered. These are listed in Table 9-1. It is shown that a wide range of values are reported for the affected geological formations and is expected in fractured aquifers, where groundwater flow is complex and changes with time. However, for the purpose of simulations, simplifications are required. For this reason, average, minimum and maximum flow conditions will be evaluated at the hand of

adjusting the permeabilities of the formations to understand groundwater flow under these hypothetical conditions. ❖ Due to the fact that limited on-site groundwater levels are available, model calibration and sensitivity analysis could not be performed to a satisfactory level. Limited calibration was completed with groundwater levels measured in two boreholes situated south of the Marievale project area (Val 1 and CRG B15). The provisional model calibration completed suggests that the average permeability of the fractured crystalline formations is 6,74E-2 m/d and that of the shale is an order of magnitude lower, around 2,78E-3 m/d. Under these conditions the rate of recharge to the aquifers is around 1,5% of MAP. It is shown that groundwater flows regionally in a westerly direction. The Booysens shale band in the central part of the model results in a retardation of groundwater flow patterns due to its lower permeability. ❖ It is noted that the inadequate level of model calibration limits the level of confidence in the output. This needs to be updated before any desilting starts through drilling and testing and evaluating best management options of minimising impacts to the groundwater system and receiving environments.

Table 9-1: Literature-based aquifer parameters considered

PERMEABILITY (M/D) SPECIFIC STORAGE POROSITY (%) (M-1) Irene Lea Freeze & Domenico Irene Anderson Irene Lea Freeze & (2016) Cherry & Lea & (2016) Cherry FORMATION (1979) Schwartz (2016) Woessner (1979) (1990) (1992) Shale 8,64E-09 8,64E-09 1,50E-06 1 0 Shale 8,64E-09 (minimum) (minimum) Shale 8,64E-05 1,73E-04 6,90E-05 5 10 Shale 8,64E-05 (maximum) (maximum) Fractured 8,64E-04 6,91E-04 6,90E-05 0 Fractured 8,64E-04 crystalline crystalline rock rock (minimum) (minimum) Fractured 8,64E+02 2,59E+01 3,30E-06 10 Fractured 8,64E+02 crystalline crystalline rock rock (maximum) (maximum)

❖ To test the model’s sensitivity to possible variations in aquifer permeabilities, average, minimum and maximum flow conditions were evaluated, as mentioned above. The sensitivity to other aquifer parameters were not tested as it is thought that aquifer permeability would play the most significant role in plume movement. ❖ Despite the current low confidence in the model, the water balance error for the flow components considered during simulations is less than 1%, as indicated in Table 9-2. This means that the difference between inflows and outflows simulated are within generally acceptable bounds.

Table 9-2: Model water balance

FLOW TERM INFLOW (M3/D) OUTFLOW (M3/D) BALANCE (M3/D) Storage 1,54E+01 3,80E+02 -3,21E+02 Constant Head 0,00E+00 2,34E+02 -2,34E+02 Drains 0,00E+00 5,11E-02 -5,11E-02 Recharge 4,58E+03 0,00E+00 5,52E+02 River Leakance 1,32E+01 1,43E-01 -1,32E-01 Head Dependent Boundaries 4,61E+03 8,33E-01 -5,87E-01 Total Water Balance Error 6,15E+02 -3,45E+00 (%) Water Balance Error (%) 1,54E+01

❖ The historical impact of tailings deposition is not well understood. Some information is available to define the period over which groundwater quality has been affected in the past, but this is not sufficient to assess historical impacts with confidence. The available information was however incorporated and included during simulations. It is noted that the anticipated historical impact of the tailing’s dams situated south of the Marievale project on groundwater quality plays a significant role in the current and future extent of plume movement. ❖ Only advective transport of contaminants was simulated. While it is acknowledged that attenuation will take place, there is currently no information available to characterise this aspect. Due to the fact that it is assumed that contamination will flow at the same rate as groundwater would in the aquifers, the scenarios represent a worst-case scenario, in line with taking a precautionary approach.

Air Quality

❖ Construction of buildings and roads 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 Marievale Project reclamation process. Access roads will be routed from existing entry points, and much of the basic infrastructure will be of a temporary nature e.g. administration buildings, mobile change houses and ablution facilities. Pipelines will need to be constructed to and from the Ergo Processing 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. ❖ The NPi emission factor for TSFs does not account for differences in vegetation cover, moisture content, salt concentration, surface structure (structural & textural cracks & inhomogeneity), nor weathering of the tailings (NPi, 2006). For this reason, it was assumed that in the 40-metre-wide bands where all vegetation is removed for the reclamation process, the emission rates predicted by the NPi will increase by a factor of 10. ❖ For each area source, Zs (the height of the first vertex) was set as the highest point in the TSF instead of the actual height of the vertex. This was done because AERMOD uses the height of the first vertex as the height of the entire polygon source, but the corners of the TSFs are lower than the centre.

❖ 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. ❖ The Marticorena and Bergametti equations (1995) also indicate that below 6.7 m/s the emission rate and therefore ambient concentrations decrease very rapidly. In the period 2015 to 2017 at O.R. Tambo International Airport, all except two days recorded a maximum gust speed of 6.7 m/s or more, indicating that there will be some emissions of PM10 from the tailings on almost every day of the year. However, the average wind speed of 255 days was less than 5.9 m/s. Lower wind speeds cause the distance of dispersion to decrease. This may result in the modelling incorrectly indicating more exceedances close to the TSFs, as lower wind speeds will reduce the distance of dispersion while the model is unable to reduce emission rates on those days. ❖ It was assumed that reclamation would start in the areas closest to the lowest points of the TSFs and the proposed reclamation stations. For each of the modelling runs it was also assumed that the areas ‘uphill’ from the work face would still be emitting particulates at the same rate as for the status quo scenario. ❖ It was assumed that the face being removed 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’. ❖ 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. However, the position and extent of these areas was not known, and therefore the decrease in emissions from these areas could not be 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.

Heritage and Palaeontology

Not detracting in any way from the comprehensiveness of the research undertaken, it is necessary to realise that the heritage resources located during the impact assessment study do not necessarily represent all the possible heritage resources present within the area.

This is especially true as the fieldwork confirmed that the study area contains the remains of many historical mining and residential structures, as well as marked and unmarked graves and burial grounds. It should be noted that certain areas were not accessible as they were located on private property (existing TCTA and Ergo plants, two SANDF military bases and an existing quarry) or contained informal settlements or the presence of

illegal miners. Certain areas were also covered in dense vegetation, and others contained vlei areas/wet ground and mine discard dumps or illegal dumping.

Any additional observed or located heritage features and/or objects may not be disturbed or removed in any way until such time that the heritage specialist has been able to make an assessment as to the significance of the site (or material) in question. This applies to graves and burial grounds as well.

Social

❖ The study is based on data obtained from Statistics South Africa, which may not reflect accurate information - data should only be viewed as indicative of the broad trends within the area and not as a rigid representation of the area. ❖ Not every individual in the community could be interviewed therefore only key people in the community were approached for discussion. ❖ Reluctance of community members to participate due to fear of disclosure even though they were assured of confidentiality. This was addressed by talking to individuals who were willing and comfortable to disclose information and the Happiness Village Committee members. ❖ There seems to be tension between the residents of Happiness Village and the Marievale Military personnel - this had a bearing on obtaining a clear socio-economic picture of the area. Residents from Happiness Villages provided their perception based on their lived experience which could be counteracted by the SANDF. ❖ Interviews were undertaken during a period where residents from Happiness Village have lodged a court case against the SANDF (Marievale Military base), this led to withholding some information from the team. ❖ Lack of data from the South African National Defence of their personnel residing in the Marievale military barracks limits this study to accurately report on the current socio-economic baseline of the area. ❖ 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; ❖ Projections from the existing Ergo SLP (2018-2022) (for current DRD operations) were used to establish potential benefits that might materialise as part of the proposed operation. It should be noted that the number of opportunities offered are subject to the company’s financial situation.

Noise

Limitations due to environmental acoustical measurements include the following:

❖ Ambient sound levels are the cumulative effects of innumerable sounds generated at various instances both far and near. A high measurement may not necessarily mean that the area is always noisy. Similarly, a low sound level measurement will not necessarily mean that the area is always quiet, as sound levels will vary over seasons, time of day, dependant on faunal characteristics (mating season, dawn chorus(5) early hours of the morning, temperature etc.), vegetation in the area and meteorological conditions (especially wind). This excludes the potential effect of sounds from anthropogenic origin; ❖ Seasonal changes in the surrounding environment can change the measured baseline. Many faunal species are more active during warmer periods than colder periods. Cicada is usually only active during warmer periods. Certain cicada species can generate noise levels up to 120 dB for mating or distress purposes, sometimes singing in synchronisation magnifying noise levels they produce from their tymbals(6); ❖ Measurements over wind speeds of 3 m/s could provide data influenced by wind-induced noises; ❖ Ambient sound levels recorded near rivers, streams, wetlands, trees and bushy areas can be high due to faunal activity which can dominate the sound levels around the measurement point (specifically during summertime, rainfall event or during dawn chorus of bird songs). This generally is still considered naturally quiet and accepted as features of the natural baseline, and in various cases sought after and pleasing; ❖ Considering one or more sound descriptor or equivalent can improve an acoustical assessment. Parameters such as LAMin, LAeq, LAMax, LA10, LA90 and spectral analysis forms part of the many variables that can be considered. The South African Legislation however is the LAeq, setting, and must at all times be considered; ❖ It is technically difficult and time consuming to improve the measurement of spectral distribution of large equipment in an industrial setting. This is due to the many correction factors that need to be considered (e.g. other noise sources active in the area, adequacy of average time setting, surrounding field non-uniformity etc.(7) as per SANS 9614-3:2005); ❖ There exist more limitations and unknowns in the range below 31.5 and above 16,000 Hz due to the calibration certification (for the equipment).

9.2 Aspects for Inclusions as Considerations of the Environmental Authorisation

Should the DMRE grant 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 DMRE; ❖ Ergo must undertake external auditing of the environmental performance as per the conditions of the Environmental Authorisation and provide the DMRE with a copy of the auditing report; ❖ The Applicant must report to the Department, with reason, if requirements of the EA have not been met. ❖ Stakeholder engagement must be maintained during the construction, operational and decommissioning/rehabilitation phases of the project, with the emphasis on the continuing provision of information; ❖ A community forum should be implemented by Ergo, with the aim of engaging Stakeholders and the public; ❖ All laydown, storage areas etc should be restricted to transformed areas close to the preferred option and existing roads should be used as far as possible; ❖ Keep storm water away from the reclamation areas; ❖ Prevent rainwater and the process water that has fallen on site from leaving the site in an uncontrolled and unregulated fashion; ❖ Prevent dust pollution during dry, windy conditions. ❖ All necessary authorisation must be in place prior to commencement of the project activities. ❖ All employees and contractors should receive induction that includes an environmental awareness component (noise). This is to allow employees and contractors to become aware of the potential noise risks that activities (especially night-time activities) pose to the surrounding environment. ❖ Ergo must adhere to the Rehabilitation Plan contained in the EMPr. ❖ The Applicant must maintain all financial responsibility throughout all phases of the project lifespan, including monitoring. ❖ Should the economic gold price diminish and not be seen as favourable to continue reclamation activities, Ergo must continue to implement monitoring and rehabilitation requirements as set out in the EMPr. ❖ The Applicant must ensure that there are sufficient funds set aside to complete the project fully. Partial reclamation and partial rehabilitation should not be accepted. ❖ Exemption from GN R704 is obtained for mining activities and infrastructure proposed to be undertaken within the 1:100 year floodline or within 100 m of a watercourse. ❖ Management and Monitoring plans contained in the EMPr must be strictly adhered to. ❖ A Chance Find procedure for heritage resources and artefacts needs to be in place.

9.3 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 Marievale 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. The EMPr will address the environmental impacts during the construction, operational, decommissioning (where applicable post-decommissioning) phases of the Project. Due regard must be given to environmental protection during the entire Marievale 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 Marievale Project; ❖ Maintain a state of Environmental Quality following completion of the Marievale Project; ❖ Ensure appropriate restoration of areas affected by the Marievale Project; and ❖ Prevent long term environmental degradation.

9.4 Rehabilitation Requirements

Rehabilitation for the Marievale Project is proposed to inform a pre-mining landscape by extending the Marivale Bird Sanctuary/Blesbokspruit Wetland. Final rehabilitation will be carried out once the Marievale Project goes into its decommissioning phase.

The principles for proper rehabilitation, which should be followed, are:

❖ Preparing a comprehensive rehabilitation plan prior to the commencement of any activities on site; ❖ Stormwater management must be in place at the site prior to commencing with any activities; ❖ Landform design (shaping, re-grassing); ❖ Maintenance management and eradication of invader species; ❖ A plan which negates how waste will be managed on site; and ❖ An Emergency Preparedness/Response plan.

The objective of the site rehabilitation (in accordance with the NEMA EIA Regulations of 2014) must be measurable, practical and is feasible to implement through:

❖ Providing the vision, objectives, targets and criteria for final rehabilitation of the project; ❖ Outlining the principles for rehabilitation; ❖ Explaining the risk assessment approach and outcomes and link decommissioning activities to risk rehabilitation; ❖ Detailing the decommissioning and rehabilitation 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 decommissioning; ❖ Identifying knowledge gaps and how these will be addressed and filled; ❖ Outlining monitoring, auditing and reporting requirements.

Rehabilitation has been dealt with throughout this EIA. Mitigation / Management and Monitoring measures are proposed in the EMPr.

9.5 Should the Marievale Reclamation and Reprocessing Project be Approved?

Key findings from the EIA have been incorporated into a high-level summary presented in the risk matrix found in Chapter 8.4.

Conclusions of the report

Chapter 5 outlines the need for the project in a local and regional sense, as well as the overall desirability for the project in a local and regional sense.

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. As a final option, offset strategies should be investigated, if feasible.

The findings of the impact assessment have shown that the Marievale Project would conclusively result in certain negative impacts during the operational phase to the environment, however, none of the specialist studies objected to the project. Impacts are largely Moderate (negative) in significance, being mitigated to Low (negative) Significance. During the decommissioning and post-decommissioning phases, the majority of the impact are expected to be Moderate – High (positive) in significance after mitigation.

The scientific specialist mitigations measures have been included into this EIA and EMP report to reduce the significance of all the identified negative impacts. Most of the negative impacts from the proposed project can be reduced through the implementation of mitigation measures. Based on the information contained in this report, it is the opinion of the EAP that the negative environmental impacts resulting from the Marievale Project can be mitigated to within acceptable limits and that the project should be authorised. This opinion holds provided all the recommendations proposed in the specialist studies and the EIA and EMP report as well as legislative requirements are implemented and adhered to.

The water quality in the Blesbokspruit is already impacted, and there is a possibility of temporary contamination of downstream watercourses during operation of the Marievale project. If authorised, Ergo will need to minimise such contamination by following the prescribed mitigation stipulated in this EIA / EMPr, the water use licence and all relevant best practice guidelines and legislation regarding the rehabilitation of contaminated land. It is anticipated that through carefully planned reclamation efforts the Blesbokspruit could expand to a state where it represents a viable and functioning pre-mining land use.

diligence is required by Ergo to minimise negative impacts and maintain the status quo of the Marievale Bird Sanctuary and Blesbokspruit through the construction and operation of the project. An improvement of the functioning of the wetland is expected following decommissioning and rehabilitation.

CHAPTER 10: 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 Mining (Pty) Ltd. 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

19 March 2020 Date

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