Draft Environmental Impact Assessment Report for the Refurbishment and Recommissioning of Kwasa Colliery

situated on the Remaining Extent of the farm Goedehoop 169 HT in the Mkhondo Magisterial District of the Mpumalanga Province, Republic of South Africa

Ref no: 17/2/3 GS-222

Proponent: Siphiwo Investments (Pty Ltd Report Reference: KPS600 P O Box 652706 Benmore Report Status: Draft EIA/EMPr 2010 Date: February 2016 Tel: +27 (0)11 064 4836 Cell: +27 074 104 0662 [email protected]

uKhozi Environmentalists (Pty) Ltd. (2004/013846/07 t/a “uKhozi”). Building 32, Cambridge Office Park, 5 Bauhinia Street, Centurion. Postnet Suite 1454, Private Bag X1007, LYTTELTON, 0140 Tel +27 (0)12 665 2471 Fax +27 (0)86 767 8072 Web address: www.ukhozi-enviro.co.za Directors: Inus de Wit; Alpha Hadebe; Tommy Olivier; Ken Smith

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Preface This Environmental Impact Assessment Report has been compiled by uKhozi Environmentalists, based on the guidelines provided by the National Environmental Management Act, 1998 (Act no 107 of 1998), Environmental Impact Assessment Regulations. Full acknowledgement is made for use of the NEMA EIA regulations guideline in compiling this report. This document includes uKhozi ‘s own interpretation of the requirements of the National Environmental Management Act (Act 107 of 1998), the regulations, the guidelines and the integration with other statutory and best practice criteria. This Environmental Impact Assessment Report forms part of the process of applying for environmental authorisation for the refurbishment and recommissioning of the underground coal mining operation, Kwasa Colliery.

Contact details: uKhozi Environmentalists (Pty) Ltd . t/a “uKhozi” Registration No. 2004/013846/07

Practitioners

Contact Person for this project: Tommy Olivier

Alternative contact persons: Inus de Wit

Tel.: +27 (0) 12 665 2471 Cell: +27 (0) 82 521 8870 Fax: +27 (0) 86 767 8072

Postnet Suite 1454, Private Bag x 1007, Lyttelton, 0140 [email protected] [email protected]

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Executive Summary

The Mining Right for Kwasa Colliery has recently been applied to be transferred to Siphiwo Investments (Pty) Ltd., for which a S.11 transfer of ownership is required, and has been submitted to the DMR. In line with the policy of operating within the framework of the various, relevant laws, Siphiwo and its various partners has appointed KSE Services to manage the process of applying for the environmental authorisations, and uKhozi Environmentalists as the independent environmental assessment practitioners.

The National Environmental Management Act (107) 1998 (“NEMA”) and Environmental Impact Assessment Regulations, 2010 specifies certain requirements for assessing the impacts of the proposed project with the Public and this is complemented by requirements of the National Water Act (36) 1998 (“NWA”).

This report is the result of fulfilling those requirements with information collected from site visits to the Rem. of Goedehoop 169 HT, previous studies in the area, specialist studies and a public participation process. Kwasa Colliery is situated in the Gert Sibande Magisterial District which falls within the Mkhondo Local Municipality in Mpumalanga. The coal reserve is located approximately 37 km south-west of the town of Piet Retief, 22 km due East of the town of Dirkiesdorp and 58 km East of the town of Wakkerstroom

The Department of Economic Development, Environment and Tourism (DEDET) has accepted the scoping report completed in terms of the National Environmental Management Act, 1998 (Act No. 107 of 1998) and the Environmental Impact Assessment Regulations, 2010 on the 16th September 2014 for the authorization to recommission the underground coal mine. The listed activities applied for by this application are to ensure that the application for environmental authorisations for the envisaged operation is aligned with what is planned in practice. This application focusses on the NEMA requirements: a Water Use licence Application process has started. The mine has been issued with a Mining Right (Reference Number MP 30/5/1/2/2/415MR F2009/04/28/004). An Environmental Impact Assessment Report (EIAR) along with an Environmental Management Programme report (EMPr) is required to be submitted as the next step in the application process.

This report is part of fulfilling the requirements of the NEMA, NWA and NEMA:WA for environmental authorisation and has been compiled with information collected from site visits to portion 0 of Goedehoop 169 HT, previous studies in the area, specialist’s studies and a public participation process conducted during the scoping and EIA phases.

uKhozi: KPS600/0216 Page i of xxi Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

The existing status of the site must be described during the environmental impact assessment in order that the environmental management programme is applied directly to the situation at hand. The Terms of Reference or plan of study for the EIA will need to be verified by the participants in the consultative process, enabling the EIA to proceed smoothly without gaps or duplication in the information generated.

Please note that these conclusions and recommendations have been made for discussion purposes: The Applicant, Authorities, IAPs and specialist consultants will be given the opportunity to comment on this EIAR and EMPr, while the Applicant will be able to make an informed decision as to the management and mitigation commitments that will become necessary.

Project Description Kwasa is a small, underground coal mine. It is planned to establish a wash plant on site. The mining methods will be bord and pillar, using a coal cutter with minimal drill and blast. There will be no secondary mining of the pillars to ensure that the roof will remain competent.

Completed Activities The development of the mine up to this point in time have all been done and funded by Kwasa Mining Services (Pty) Ltd. The following activities had been completed approximately three years ago but would probably need to be refurbished:  Refurbishment of access road to the mine and shafts;  Installation of Eskom power lines and transformers;  Refurbishment of the underground workings, with a) roof stabilisation, b) conveyor system, c) ventilation infrastructure, d) water management.  Fencing of the shafts;  Development of access control;  Setting out of a stockpile and loading area in place;

Infrastructure on site The following infrastructure is currently on site:  Access roads as well as internal roads;  Security berms and palisades;  Old mining equipment;  Abandoned buildings;  Power Lines.

Planned Activities for the Construction Phase The following activities will be carried out during the construction phase: uKhozi: KPS600/0216 Page ii of xxi Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

 Refurbishment and reconstruction of the water pollution control system;  Construction of one fresh water storage dams;  Construction of four pollution control dams (PCDs);  Construction of the silt traps at each PCD;  Transport to site and erection of a modular washing plant;  Preparation of the discard management facility;  Construction of offices and a change house;  Installation of a septic tank system;  Commissioning of an existing weighbridge;  New security house at main gate;  Final trenching and berms;  New runoff water catchment areas;  Three freshwater towers and tanks;  Installation of a new conveyor belt in the Alfred seam belt adit;  Road signs;  Water pumps and piping for PCDs and clean water storage dam;  Security lights at gates.  Five year contractual commitments for the supply and operation of crushing and screening equipment;  Five year contractual commitments for underground mining services.

The facilities inside the operational area will be fenced such as the PCDs, fresh water dam, washing plant area, co disposal site and stockpile areas.

Planned Activities for the Operational Phase Activities to be conducted during the operational phase of the mine are:  Underground board and pillar mining with continuous miner which will not involve blasting;  Transportation of run-off mine from the shaft to crushing and screening area via a conveyor belt system;  Crushing and screening of run-off mine;  Stockpiling of the coal product;  Spraying of water on access roads to suppress dust;  Transportation of coal product to client via trucks;  Cleaning of silt traps;  Disposal of discard and silt at the Co-Disposal site;  Toil stockpiling (hard and softs);  Sewage management;  Solid waste management;  Dirty water handling including pumping water from PCD 3 to the coal washing plant. uKhozi: KPS600/0216 Page iii of xxi Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Planned Activities for the Closure and Post Closure Phases Activities to be conducted during the closure and post-closure phase of the mine are:

 Plugging/sealing of the three adits (ventilation, access and exit);  Removal of storage equipment;  Cleaning and re-vegetation of the discard dump and product stockpile area at the plant;  Removal of coal wastes;  Demolition of unwanted (by the post-mining land users) infrastructure such as offices, change house, pollution control dams, access roads, high wall etc.;  The pollution control dams will be cleaned before it is filled and re-vegetated.  Landscaping and re-vegetation of disturbed areas.  Ground and surface water monitoring.

uKhozi: KPS600/0216 Page iv of xxi Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Layout plan of the washing plant and adit area

uKhozi: KPS600/0216 Page iv of xxi Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Layout of product stockpile area and fresh water dam.

Alternatives There are three main sets of alternatives associated with the recommissioning of this underground coal mining operation, namely: a) The underground operation with no additional washing plant and discard dump, where the Run-of-Mine coal is beneficiated (washed) off site at a remote plant (this proved to be not feasible over the past three years of operation). b) The underground operation together with a wash plant and associated discard dump, in the vicinity of the current operation (preferred). c) The underground operation together with a wash plant and associated discard dump, located at the abandoned Goedehoop colliery, some seven kilometres north of Kwasa.

Legislative Requirements The proposed operation requires a Water Use License in terms of Section 21 of the National Water Act, 1998 (Act 36 of 1998) as well as a full scoping and environmental impact assessment (EIA) in accordance with the requirements of the National Environmental Management Act (NEMA) (2010) triggering activities nr 5, 6 and 20 in GN 545 (Listing notice 2) and National Environmental Management: Waste Act (NEM: WA) triggering listed activity 7 in Category B for the Co-Disposal Dump Site as well as PCDs.

Public Participation During the Scoping/EIA process a public participation process was undertaken to allow IAPs to voice their concerns and issues regarding the project. The key elements of the process included:

uKhozi: KPS600/0216 Page v of xxi Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga  Development and distribution of a background information document (BID);  Informing IAPs of the proposed mining operation through a newspaper advertisement and notification letters.  A key stakeholder meeting held in Piet Retief on the 5th of September 2013 (refer to Appendix A.6.1 for the NfR).  A meeting was held with the landowner Ms Reinette Boshoff’s representatives, Foster Attorneys in Ottosdal on the 24th of February 2014 (refer to Appendix A.6.3 for the NfR).  A public meeting held in Piet Retief on the 25th of February 2014 (refer to Appendix A.6.2 for the NfR).  A 2nd public meeting held in Piet Retief on the 5th of December 2014 (refer to Appendix A.6.5 for the NfR).

During this process a register of IAPs was compiled, together with a record of their comments and responses from the project proponent and the EAP (refer to Issues and Response Report in section 8.6 of this report).

The comments received during the review period will be taken into account in finalising the Environmental Impact Assessment Report for submission to DEDET.

Environmental Baseline, Impacts and Mitigation

Geology This coal reserve falls within the Karoo Super Group and is part of the Vryheid Formation of the Ecca Group. Although there has been much transgressed activity, there are a number of smaller faults within the mining area; no major faults traverse the area. A range of anthracitic and lean to bituminous type coal is found within the reserve.

Main Impacts Altering the geotechnical characteristics of the geological strata.

Main Mitigation Measures  The impact on the geology will be permanent and cannot be mitigated due to the nature of the activity.  Stability of the high wall will be ensured by the use of split blasting techniques.  No secondary mining such as stoping and goafing must take place.

Topography The pre-mining, natural topography of the area is a combination of steep slopes and relatively flat (natural) terraces.

Main Impacts uKhozi: KPS600/0216 Page vi of xxi Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga Altering the characteristics of the existing topography.

Main Mitigation Measures  This area will be kept to the minimum needed for the mining operation.  The various stockpiles will be managed to prevent erosion and will be shaped where required. Soils The soil within the mining area is generally deep, interspersed with dolerite boulders of varying sizes. The dominant soil form in the disturbed area is the Hutton Form which is associated with the dolerite boulder based scree slope as the pedology of the soil.

Main Impacts  Erosion and sedimentation  Contamination of the soil

Main Mitigation Measures  The topsoil will be stockpiled separately, grassed, and used for the construction of berms.  A vegetation layer on the berms will be maintained.  The height of the stockpiles must not exceed 1.5m.  Define routes for the circulation of heavy machinery and vehicles.

Land Capability The land capability can be described as largely grazing and wilderness, with the area under the operational, adit complex, potentially (post-mining) falling into the category of rehabilitated mining land.

Main Impacts Change in existing land capability.

Main Mitigation Measures  The disturbed area will be kept to the minimum required for construction of the adit.  The topsoil and subsoil will be managed to ensure effective rehabilitation back to the pre mining land capability during the decommissioning phase.

Land Use The surface area under application can be divided into the following two categories:  Wilderness used for grazing;  Unrehabilitated mining area.

Coal waste is lying around on the unrehabilitated mining area and has the potential to pollute the surrounding water resources during rainfall events. uKhozi: KPS600/0216 Page vii of xxi Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Main Impacts Changes in land use from a defunct colliery to an operational colliery.

Main Mitigation Measures Control of the area disturbed during the construction phase to ensure no unplanned (and/or unauthorised) expansion, with a direct effect on land use.

Vegetation Kwasa Colliery is situated on the remaining extent of the farm Goedehoop 169 HT on the lower scree slope of the mountain. The lower lying areas do show some signs of being grazed by cattle but the extent of the grazing has been low and so it is not an issue of concern. Plant species diversity is high and basal cover is generally good. While there are some Wattle Trees (Acacia mearnsii) present in places, alien plants are generally not abundant. Soil erosion is largely restricted to the drainage lines and is not extensive at any site seen other than in the actual footprint of the mining area. In the higher lying areas, located generally at or above the level of the mine adits, the vegetation is in pristine or near pristine condition.

In broader terms, Kwasa Colliery falls within the Acocks’ veld type known as Veld-type Number 63, namely Piet Retief Sourveld. The area is used for grazing and bi-annual burning programmes common to the area would suggest that – in general, the veld type is no longer pristine. However, the area on the southern sections of the mining rights area (on top of the mountain range) is part of high altitude grasslands and has been included in the Nkangala Grasslands project.

Main Impacts Loss of vegetation. Proliferation of alien vegetation inside the footprint area.

Main Mitigation Measures  The disturbed areas will be kept to a minimum.  The topsoil containing the seed bank will be used as efficiently as possible.  Implement weed eradication programme.

Animal Life A Highveld Grassland habitat once occurred over much of southern Mpumalanga, but this has now largely been transformed into monocultures by agriculture and forestry. Where pristine grassland remains, the biodiversity needs to be retained. Part of the area has been disturbed by mining thus most of the animals have moved to adjacent areas.

uKhozi: KPS600/0216 Page viii of xxi Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga Main Impact Loss of habitat/faunal diversity.

Main Mitigation Measures  The enclosure fences erected around the operational areas will prevent domestic livestock and discourage larger wild animals from entering the operational sites.  Prohibit activity outside of the demarcated area.

Surface Water The mining area falls in the Usutu Catchment. The study area falls within the farm Goedehoop 169 HT which is in turn is situated in quaternary sub-catchment W51C; the catchment of the Vegkop River is 161km2. The Vegkop River is a tributary of the Annysspruit which flows into the Assegaai (Mkhondo) River, which flows from this drainage region north-eastwards, joining the Great Usutu River in Swaziland, and flowing into the sea in Mozambique.

The water quality in the upper Usutu catchment is excellent, which is why Eskom source their water for the cooling of coal-powered power stations from this catchment. The surface water quality of the Annysspruit is being polluted by the defunct Kwasa Colliery. During rainfall events the water falling onto the disturbed site gets polluted by coal waste and flows downstream into the Annysspruit which in turn flows into the Assegaai River.

The surface water associated with the mining area is mainly used for stock watering, aquatic eco-systems, and also for human (potable) requirements.

There are no registered wetlands associated with the operational area or in close proximity to the site according to SANBI however the landowners have pointed out wetlands found to the north of the site.

Main Impacts Contamination of surface water. Decrease of surface water runoff. Disturbance of the bed and banks of the water courses.

Main Mitigation Measures  All “dirty” water runoff should be kept on site and not allowed to mix and contaminate clean runoff.  Clean storm water run-off will be diverted around the operational areas so as to discharge into the natural surface water courses.  The disturbance footprint should be kept as small as possible in order to minimize the impacts on the riparian habitat;

uKhozi: KPS600/0216 Page ix of xxi Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga Groundwater The mining area is mainly located across the mountain area; however the adit complex is located on a terrace in a lower down the hill-slope.

The lower hill-slopes topographical areas have two principle aquifers. These are the following:

 A weathered aquifer occurring at a depth from 2 to 15 metres.  A fractured Karoo aquifer occurring at depths below 15 metres.

A perched aquifer system occurs above the dolerite sills and that more than one unconfined / semi-confined aquifer system occurs above the regional aquifer system that is associated with the lower topographical system.

The mountain area has various fountains and springs indicating a shallow water table.

The groundwater is mainly used for livestock watering (from fountains and springs) with a limited use for domestic supply.

Main Impacts Contamination of the underlying aquifer. Decrease in the groundwater level.

Main Mitigation Measures  Any groundwater seepage that may flow into the adit during its excavation will be pumped to the pollution control dam.  Separate the aquifer from the facility by lining the pollution control dams with HDPA (2mm) and clay on top.  Ensure the impermeability of all storage areas for fuel, lubricants and other chemicals.  Slope the surface of the stockpile areas to avoid pooling.  Limit groundwater use as much as possible and measure groundwater abstraction levels.

Air Quality In the pre-mining environment, there are no major local sources of air pollution. Adjacent to the site to the south-west of the study area there is an existing coal mining operation (Kiepersol Colliery Operations) which contributes to air pollution through dust as well as diesel fumes from the operational trucks and vehicles. In the immediate vicinity, there is some potential for dust pollution due to traffic on the gravel roads and general agricultural activity.

uKhozi: KPS600/0216 Page x of xxi Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga Main Impacts Creation of fugitive dust.

Main Mitigation Measures  Dust from the internal roads and operational areas will be suppressed with water and a dust inhibitor.  The disturbed area will be rehabilitated in order to prevent the generation of dust.

Sensitive Landscapes The abandoned Kwasa Colliery falls inside the Wakkerstroom Wetlands Grassland proposed exclusion area in terms of Section 49 of the MPRDA.

The Annysspruit along with other small tributaries flowing in close proximity of the Kwasa Colliery is also considered sensitive areas.

The wetland north of Kwasa Colliery’s entrance is considered a sensitive area. According to the landowners there are various different species of waterfowl (spur winged geese, Egyptian geese, crowned cranes, blue cranes) relying on this wetland.

Main Impacts Decrease in the surface water runoff into the downstream wetlands. Degradation/damage to the wetlands and streams due to mining operations.

Main Mitigation Measures  Construct clean water diversion structures prior to construction to divert clean water away from the construction area and prevent damming of clean water.  A 500m buffer zone must be maintained around all wetland areas.  All “dirty” water should be contained in lined pollution control dams.  No polluted water should be allowed to leave the site or flow into the surface water system.

Noise Noise in the area is restricted to routine traffic to and from the surrounding farms and adjacent mining operations conducted by Kiepersol Colliery. Agricultural activities such as the cultivation of lands and harvesting of crops also contribute a low scale source of noise to the ambient level.

Main Impacts Increase in the ambient noise level.

uKhozi: KPS600/0216 Page xi of xxi Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga Main Mitigation Measures  Carry out the noisiest labours as quickly as possible and during normal working hours (07:00 – 17:00) or according to applicable legal criteria.  All vehicles and machines must undergo periodic maintenance and inspection.

Visual The site is visible from the R543 (Piet Retief – Wakkerstroom) district road, lying some twelve kilometres to the north of the site. The un-rehabilitated Kwasa Colliery and the Kiepersol Colliery have already altered the visual character of the Mhlangamvula and Mhlanganpisi Mountains, especially when looking at the mountains from the north and west. However the size of the disturbed area at the Kwasa Colliery is very small compared to the disturbed area at Kiepersol Colliery directly to the west.

Main Impacts Change in the visual aspects of the area. The landscape impacts with the highest significance would occur during the construction phase of the mine as the activities during this stage involve clearing of grassland vegetation for the establishment of the discard dump, fresh water dam and coal product stockpile areas. This would leave exposed soil and associated construction components.

Main Mitigation Measures  Demarcate vegetation clearance areas so as to ensure that the minimum amount of vegetation is removed.  Vegetate berms as far as possible.  Remove the minimum amount of topsoil and store for use in post-construction rehabilitation.  Salvage indigenous vegetation for re-planting during post-construction rehabilitation.

Socio Economic Environment The area for the proposed mine falls within Ward 7 of the Mkhondo Local Municipality which forms part of the greater Gert Sibande District Municipality. In terms of Gross Geographical Product the two most important employment sectors are agriculture at 36% and community services at 18%. The area has a large economically active population (56%), a total of 43% of the economically active population is unemployed. This indicates that the economy is unable to accommodate these people, which will either lead to the out migration of youngsters and/or an increase in domestic poverty.

The N2 is the only national road which traverses the area. Three provincial roads traverse the area. These include:

uKhozi: KPS600/0216 Page xii of xxi Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga  R33 from the N17 in the north, through Amsterdam and Piet Retief to Vryheid in the south;  R65 between Ermelo and Swaziland via Amsterdam.  R543 between Swaziland and Volksrust via Piet Retief.

All these roads are tarred but in fairly poor condition and therefore need to be upgraded and maintained. The R543 is the road that will be used to the Kwasa Colliery.

Main Impacts Additional employment opportunities The local and regional road transport network will suffer additional pressure from the haulage trucks.

Main Mitigation Measures  Use local workers as far as possible.  The construction vehicles must remain on site as far as possible during the construction period.

Cumulative Impacts The area in which the mine is located is already substantially transformed by a range of human activities of which the most significant are mining, agriculture, timber production, and urban and rural residential developments. As a result the biodiversity of the area is already significantly reduced and several cohorts of species are either totally or largely lost.

Ecosystem service delivery is impaired and although the degree has not yet been quantified, there are costs to society. Examples of these costs include expensive water purification, and reduced public health especially in the poorer communities. The Kwasa mine will not introduce any new forms of environmental impact but its impacts will act in a cumulative fashion with the existing impacts. It is considered that the most important of these will be the following:  Loss of biodiversity. The mine is situated in an area of naturally high biodiversity. However, human activities such as agriculture, mining, timber production, and urban and rural residential development have led to serious depletion of the original biodiversity. At present there are still areas of rich floral diversity on the property but some of these will be lost as the mine develops.  Reduction of water quality. The mine is unlikely to cause water quality to deteriorate to levels which are any worse than those at other mines in the region. However, the change from uncontaminated water yield to contaminated water yield suggests that the Anysspruit will be affected by loss of dilution of existing pollution. If, however, significant wetland rehabilitation is undertaken then then this impact will be reduced.

uKhozi: KPS600/0216 Page xiii of xxi Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga  Loss of food production. The development of the mine implies that agriculture on the property will largely cease. Thus food production will be reduced and the general food shortfall of the country will be exacerbated.

Recommendation When comparing the environmental impacts that will occur if the Kwasa Colliery is recommissioned to those that is currently occurring due to the state the environment was left in, the recommissioning of the Kwasa Colliery should not have unmanageable additional impacts. Some of the impacts that are currently occurring especially those pertaining to the contamination of the surface and groundwater will be reduced when proper mitigation measures are installed.

Considering the above the option of mining out the remaining reserve and then using the funds to rehabilitate the area is the best practical option to stop the pollution that is currently occurring at the mine. Therefore it is recommended that environmental authorisation for the listed activities applied for.

uKhozi: KPS600/0216 Page xiv of xxi Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga Table of Contents

Executive Summary ...... i 1 Introduction and Background ...... 1 Project Team ...... 2 1.1.1 Contact Details of EAP ...... 2 Contact Details of Applicant ...... 3 1.2.1 Name and Contact Details of Mineral Right Holder ...... 3 Legal Requirements ...... 3 Approach to the Project ...... 6 1.4.1 Scoping Phase ...... 7 1.4.2 Scope of the EIA ...... 7 1.4.3 Authority Involvement ...... 7 1.4.4 Public Participation ...... 8 1.4.5 Decision Making...... 9 1.4.6 Authorities ...... 9 1.4.7 Application Procedure ...... 10 Assumptions and Limitations ...... 11 1.5.1 Assumptions ...... 11 1.5.2 Gaps in Knowledge ...... 12 Independence ...... 12 Report Structure ...... 13 2 Project Description ...... 15 Regional Setting ...... 15 Property Description ...... 17 2.2.1 Adjacent Land Tenure and Use ...... 18 2.2.2 Presence of Servitudes ...... 19 2.2.3 Zoning ...... 21 Objectives of the project ...... 21 Physical Project Description ...... 21 2.4.1 Completed Activities ...... 21 2.4.2 Planned Activities ...... 25 2.4.3 Water Pollution Management Facilities ...... 27 2.4.4 Domestic water use and sanitation ...... 31 2.4.5 Waste Management ...... 31 Mine Plan ...... 33 uKhozi: KPS600/0216 Page xv of xxi Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga 2.5.1 Mineral deposit ...... 33 2.5.2 Mine products ...... 33 2.5.3 Estimated Reserve ...... 36 2.5.4 Mining Methods ...... 36 Project Phases ...... 41 2.6.4 Development Procedure ...... 42 Aspects of Mine Health and Safety ...... 44 2.7.1 Background ...... 44 2.7.2 Health and Safety: General ...... 44 2.7.3 Traffic ……………………………………………………………………………………..44 3 Need and Desirability ...... 45 Socio Economic ...... 45 Biophysical ...... 46 Project Market ...... 46 Labour Force ...... 46 The Multiplier Effect ...... 46 4 Alternatives ...... 47 Development Alternatives ...... 47 Operational Alternatives ...... 49 4.2.1 Mining Method ...... 49 4.2.2 Mineral Processing Methods ...... 50 4.2.3 Transport ...... 50 4.2.4 Sources of Water ...... 50 4.2.5 Mine infrastructure sites ...... 51 4.2.7 Mine residue disposal site ...... 51 4.2.8 Domestic and Industrial Waste Disposal Sites ...... 51 4.2.9 Housing Sites ...... 51 4.2.10 Land Use Option after Rehabilitation ...... 52 5 Existing Status of the Environment ...... 53 Description of the potentially affected environment ...... 53 Description of the landscape surrounding the operation ...... 54 Assessment of the environment likely to be affected and description of current environmental state of the study area ...... 54 5.3.1 Climate ...... 54 5.3.2 Air quality ...... 55 5.3.3 Geology ...... 55 uKhozi: KPS600/0216 Page xvi of xxi Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga 5.3.4 Topography ...... 56 5.3.5 Land capability ...... 56 5.3.6 Land Use ...... 57 5.3.7 Soils ……………………………………………………………………………………..58 5.3.8 Vegetation ...... 58 5.3.9 Surface Water ...... 67 5.3.10 Groundwater (Aquifer description) ...... 86 5.3.11 Sensitive Areas ...... 87 5.3.12 Noise ……………………………………………………………………………………..90 5.3.13 Visual ……………………………………………………………………………………..90 5.3.14 Socio Economic Environment ...... 92 5.3.15 Heritage ...... 96 Specific environmental features occurring on site which may require protection, remediation, management or avoidance ...... 96 6 Environmental Impact Assessment ...... 98 Mine Risk Assessment ...... 98 The Definition of Significance in the context of this EIA ...... 99 6.2.1 Context ...... 100 6.2.2 Spatial ……………………………………………………………………………………100 6.2.3 Temporal ...... 100 6.2.4 Intensity ...... 101 6.2.5 Certainty ...... 101 6.2.6 Special knowledge...... 101 6.2.7 Perceptions ...... 101 6.2.8 Levels of Significance ...... 101 6.2.9 Implications of the Significance Rating Scale ...... 102 6.2.10 Summary of the Significance Rating Matrix ...... 102 Environmental Impact Assessment ...... 111 6.3.1 Construction Phase ...... 111 6.3.2 Operational Phase ...... 122 6.3.3 Decommissioning Phase...... 130 7 Environmental Management and Implementation Plan ...... 139 Environmental Management Plan ...... 139 Roles and Responsibilities ...... 140 Probability of Impacts Occurring Pre and Post Mitigation ...... 167 Environmental Objectives and Goals for Mine Closure ...... 170 uKhozi: KPS600/0216 Page xvii of xxi Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga 7.4.1 Geology ...... 170 7.4.2 Topography ...... 171 7.4.3 Soils ……………………………………………………………………………………171 7.4.4 Land Capability ...... 171 7.4.5 Land Use ...... 172 7.4.6 Vegetation ...... 172 7.4.7 Animal Life ...... 173 7.4.8 Surface Water ...... 173 Closure objectives ...... 173 7.4.9 Groundwater ...... 174 7.4.10 Air Quality ...... 174 7.4.11 Noise ……………………………………………………………………………………175 7.4.12 Sites of Archaeological and Cultural Interest ...... 175 7.4.13 Sensitive Landscapes ...... 175 7.4.14 Visual Aspects ...... 176 7.4.15 Regional Socio-economic Structure ...... 176 7.4.16 Interested and Affected Parties (IAP’s) ...... 176 7.4.17 Infrastructure areas ...... 177 7.4.18 Mine residue deposits ...... 177 7.4.19 Disposal facilities ...... 177 7.4.20 Ongoing seepage, control of rainwater ...... 177 7.4.21 Long-term stability ...... 178 7.4.22 Final rehabilitation in respect of erosion and dust control ...... 178 7.4.23 Sealing of underground workings and rehabilitation of dangerous excavations...... 178 7.4.24 Final rehabilitation of mine haul ramps...... 179 8 Public Participation Process ...... 180 Creating Public Awareness ...... 182 8.1.1 Site Notice ...... 182 8.1.2 Newspaper Adverts ...... 182 8.1.3 Background Information Document ...... 183 Public Meetings ...... 183 8.2.1 Public Meeting ...... 183 8.2.2 Focus Group Meetings ...... 185 Authority Meetings ...... 185 Register of IAPs ...... 187 uKhozi: KPS600/0216 Page xviii of xxi Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga Issues Raised ...... 190 Issues and Responses ...... 191 9 Methodology ...... 214 Desktop Analysis...... 214 Guiding Principles ...... 215 9.2.1 Balanced sustainable approach...... 215 9.2.2 Best Practicable Environmental Option (BPEO) ...... 215 9.2.3 Precautionary Principle ...... 216 Assumptions and limitations ...... 216 10 Environmental Impact Statement ...... 217 11 Appendices ...... 218

List of Figures Figure 1: Locality Map ...... 16 Figure 2: Title Deed ...... 17 Figure 3: Specific location of planned activities ...... 18 Figure 4: Map showing surrounding farm ...... 20 Figure 5: Graphical representation of the storm water management plan ...... 29 Figure 6: Layout plan of the mining area...... 32 Figure 7: Product Stockpile area at the access gate ...... 33 Figure 8: Mining Plan ...... 34 Figure 9: Proposed Kwasa operation adjacent to the Kiepersol Colliery ...... 35 Figure 10: Elevation profile of the proposed site (North to South) ...... 56 Figure 11: Dominant vegetation types on the mine property. Source: Mucina and Rutherford (2006) ...... 60 Figure 12: Mpumalanga Biodiversity Sector Plan (2014) for the area around the mine site...... 61 Figure 13: Areas which have been, or still are, under cultivation and timber production62 Figure 14: Usutu to Mhlatuze WMA ...... 68 Figure 15: Upper Usutu Catchment ...... 69 Figure 16: Water Management Areas...... 71 Figure 17: Layout of the mine property showing the proposed infrastructure in relation to the water courses ...... 74 Figure 18: Rivers in close proximity to Kwasa Colliery...... 75 Figure 19: The five streams with its 100m buffer zone in relation to the operational areas of the proposed colliery ...... 77 uKhozi: KPS600/0216 Page xix of xxi Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga Figure 20: Health categories used for describing the Present Ecological State (PES) of wetlands. From Macfarlane et al, 2008...... 81 Figure 21: Kwasa Colliery Proximity to Registered Wetlands ...... 82 Figure 22: Land Uses in the Usutu to Mhlathuze WM ...... 84 Figure 23: Sectorial Water Requirements (Usutu to Mhlathuze) ...... 85 Figure 24: Schematic representation of the different aquifer systems (GCS, 2009) ...... 86 Figure 25: The Wakkerstroom Wet Grasslands (WWG) proposed exclusion area (233, 393 ha) extending over 120 farms within the Pixley Ka Seme and Mkhondo Local Municipalities ...... 89 Figure 26: Population per Ward ...... 93

List of Tables Table 1: Identified Listed Activities in terms of NEMA EIA Regulations, 2010 ...... 3 Table 2: Relevant Authorities ...... 10 Table 3: Application Procedure ...... 10 Table 4: Distance to the Neighbouring Towns and Villages ...... 15 Table 5: Property Details ...... 17 Table 6: Activities during Rehabilitation ...... 42 Table 7: Summary of Development Activities ...... 43 Table 8: Pre-mining land capability of the operational adit complex ...... 57 Table 9: Vegetation types on the original Farm Goedehoop 169 HT (Conservation status ...... 59 Table 10: Vegetation types on the original Farm Goedehoop 169 HT. Conservation status from Mucina and Rutherford (2006)...... 59 Table 11: Indigenous flowers found on the site ...... 63 Table 12: Indigenous trees found on the site ...... 64 Table 13: Grass species found in the site ...... 64 Table 14: Red Data listed bird species recorded in the area around the mine...... 66 Table 15: Common Mammal Species occurring in Mkhondo ...... 67 Table 16: Threatened Mammal Species occurring in Mkhondo ...... 67 Table 19: Water chemistry readings from four streams ...... 73 Table 20: Centre points and areas of the four dams found on the property...... 78 Table 21: Primary hazard class type if mineral mined ...... 98 Table 22: Classification of Mines ...... 99 Table 23: Example of Natural Vegetation (Summarised Impact) ...... 99 Table 24: The Significance Rating Scale ...... 102 Table 25: Implications of the Significance Rating Scale ...... 103 uKhozi: KPS600/0216 Page xx of xxi Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga Table 26: Categorization of the main activities in terms of the aspects of the operation ...... 104 Table 27: Responsible role players ...... 140 Table 28: Potential impact and mitigation register for the construction phase ...... 141 Table 29: Potential impact and mitigation register for the operational phase ...... 150 Table 30: Potential Impact ad Mitigation Register for the Decommissioning Phase ...... 158 Table 31: Probability of Impact Occurring Pre and Post Mitigation ...... 168 Table 32: IAPs Register ...... 187 Table 33: Issues and Responses ...... 191

Appendices Appendix A: Public Participation A.1 Proof of Placement of Notices A.2 Proof of Notification of key Stakeholders A.3 Information Provided A.4 Authorities Involvement A.5 List of Registered I&APs A.6 Minutes from Meetings Held

Appendix B: Historical Date B.1 VBA Shelly Colliery EMPR Groundwater and Surface Water Quality Sections (Feb 1998) B.2 VBA Environmental Management Report – Goedehoop Colliery Washing Plant (June 2002)

Appendix C Motivation for the consideration of the Wakkerstroom Wet Grasslands under Section 49 of the MPRDA

Appendix D: Maps and Plans D.1 Layout Plan (A3) D.2 Silt Trap Design D.3 Water Balance Diagram

Appendix E: Site Photographs

Appendix F: Specialist Studies F.1 Integrated Water Management Report F.2 Biodiversity and Wetland Assessment Report F.3 Visual Impact Assessment Report

Appendix G: Environmental Awareness Plan uKhozi: KPS600/0216 Page xxi of xxi Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

1 Introduction and Background At the end of 2009 Kwasa Mining Services (Pty) Ltd purchased an abandoned underground mine previously operated as Protea Colliery by kwaZulu Collieries which has been liquidated. Kwasa Mining Services (Pty) Ltd abandoned the colliery and left the area in an un-rehabilitated state with old equipment, scrap metal, old coal dumps and rock heaps. Five shafts in the adit complex were left open and in an unsafe state and the area was also eroded by water erosion over the years. Although Kwasa Mining Services (Pty) Ltd. is currently the responsible party, a formal process has been initiated under Section 11 of the MPRDA for the appointed Business Rescue manager to apply to the DMR to transfer the Mining Right to Siphiwo Investments (Pty) Ltd, who is able and willing to take this over, together with the environmental liabilities.

The area that is planned to be mined by Siphiwo Investments (Pty) Ltd is larger than 5 hectares. The previous mining company Kwasa Mining Services (Pty) Ltd. has been issued with a Mining Right over the farm Goedehoop 169 HT on 2nd March 2011, Protocol Number 1092/2011, DMR Reference Number MP 30/5/1/2/2/415MR F2009/04/28/004. The list of activities in this report has been compiled to ensure that the application for environmental authorisations for the envisaged operation is aligned with what is planned in practice. This application focusses on the NEMA requirements: a Water Use license Application process has started.

In line with the policy of operating within the framework of the various, relevant laws, Siphiwo and its various partners has appointed KSE Services to manage the process of applying for the environmental authorisations, and uKhozi Environmentalists as the independent environmental assessment practitioners.

The following studies have been conducted at Kwasa Colliery in the past and were used during the compilation of this report:

 Addendum to the Environmental Management Programme Report (EMPR) for the Kwasa Colliery (old Protea Colliery) compiled by uKhozi Environmentalists in March 2010;  Water Use License application screening report compiled by uKhozi Environmentalists;  VBA Shelly Colliery EMPR Groundwater and Surface Water Quality Sections (Feb 1998);  VBA Environmental Management Report – Goedehoop Colliery Washing Plant (June 2002).

uKhozi: KPS600/0216 Page 1 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga Project Team uKhozi Environmentalists aims to provide an independent, quality, and time efficient service to proponents of environmentally responsible developments throughout Southern Africa (SADC), and to advise those proponents that do not advocate such an approach.

The identification, assessment and coordination of participative and sustainable environmental solutions have developed since 1996 as a focal mission of KSE and its sister company uKhozi–Community Upliftment Services: these two companies have now merged, to form uKhozi Environmentalists.

Operational Frameworks  Code of Practice: International Assessment for Public Participation (IAP2);  Code of Practice: International Association for Impact Assessment (IAIA);  Code of Ethics: South African Council for Natural Scientists;  Code of Ethics: SA Institute of Forestry;  Environmental Assessment Practitioner (EAP) Interim Certification Board.

Environmental Assessment Practitioner Team Consists of:

Mr Tommy Olivier Environmental Consultant completed his BSc in Ecology as well as his BSc Environmental Management and Analysis Honours degree at The University of Pretoria. His honours project focused on climate change and the effects that modern society has thereon. He has five years’ experience working as an environmental consultant at uKhozi Environmentalists where he has managed a number of different EIA’s, Basic Assessments and Water Use License Applications mainly for coal mining operations. Tommy has been a member of the International Association for Public Participation (IAP2) since 2012.

Mr Inus de Wit Environmental Consultant completed his BSc in Ecology as well as his BSc Environmental Management and Analysis Honours degree at The University of Pretoria. His honours projects focused on Soil particles size and the distribution of Juliana’s Golden Mole. He recently completed his Master’s Degree in MSc Water Resource Management. His thesis focused on the physiological effects of turbine pressure on freshwater fish species. He has 3 years’ experience working as an environmental consultant.

1.1.1 Contact Details of EAP Name: Tommy Olivier Telephone: (012) 665 2471 Fax: 086 767 8072 Cell: 082 521 8870 uKhozi: KPS600/0216 Page 2 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga E-mail: [email protected]

Contact Details of Applicant

Name: Bob Nkosi Telephone: 074 104 0662 Fax: Cell: 074 104 0662 E-mail: [email protected]

1.2.1 Name and Contact Details of Mineral Right Holder Siphiwo Investments is busy with a Section 11 Transfer to transfer the Mining Right from Kwasa Mining Services to Siphiwo Investments (Pty) Ltd.

Legal Requirements

The proposed operation requires a full scoping and environmental impact assessment (EIA) in accordance with the requirements of the National Environmental Management Act (NEMA) (2010) triggering activities nr 5, 6, 15 and 20 in GN 545 (Listing notice 2).

The following legislation is relevant to the environmental authorisation of the proposed development.

National Environmental Management Act (Act 107 of 1998): The National Environmental Management Act (NEMA) creates the fundamental legal framework that gives effect to the environment right guaranteed in Section 24 of the Constitution of the Republic of South Africa, 108 of 1996. NEMA sets out the fundamental principles that apply to environmental decision making, some of which derive from international environmental law and other from the Constitution. The core environmental principle is the promotion of ecologically sustainable development.

The following listed activities have been identified in terms of NEMA EIA Regulations 2010:

Table 1: Identified Listed Activities in terms of NEMA EIA Regulations, 2010 BAR/ No Listing Notice Description of activity Scoping . and EIA GN No. R.544 Constructions of two pipelines from the fresh water 18 June 2010 9 dam and PCD 3 to the washing plant, both pipelines BAR exceeding a 1000m in length.

uKhozi: KPS600/0216 Page 3 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga GN No. R.544 Construction of a runoff berm within 32 meters of the 18 June 2010 11 watercourse between the water course and the plant to BAR protect the wetland. GN No. R.544 Construction of a fresh water dam with a capacity of 12 BAR 18 June 2010 more than 50 000 m3. GN No. R.544 Storing diesel on site in containers that can hold more 13 BAR 18 June 2010 than 80m3 but less than 500m3. GN No. R.544 Construction of the in stream fresh water dam. 18 BAR 18 June 2010 GN No. R.544 The development of the discard dump area which will 18 June 2010 23 include an access road, fence, pollution control dams BAR and plastic lining. GN No. R.544 The expansion of five crossings to allow mine 18 June 2010 39 management to access the PCDs and other areas BAR around the colliery. GN No. R.545 The application for a water use licence for the following Scoping 18 June 5 water uses: EIA 2010 Section 21 (a), (b), (c), (g), (i) and (j). GN No. R.545 Transportation of run-off mine from the shaft to Scoping 18 June 2010 6 crushing and screening area via a conveyor belt system. EIA

GN No. R.545 The development of the operational area which will 18 June 2010 include a Co-Disposal dump site, access road, pollution Scoping 15 control dams, product and ROM stockpile areas and a EIA fresh water storage dam. GN No. R.545 Kwasa Colliery has an existing mining right. Scoping 20 18 June 2010 EIA

Mineral and Petroleum Resources Development Act (Act 48 of 2008) (MPRDA) The objective of the MPRDA is to facilitate meaningful participation of HDSAs in the mining and minerals industry. In particular, section 100(2) (a) of the MPRDA provides for the development of the Mining Charter as an instrument to effect transformation with specific targets. Embedded in the Mining Charter of 2002 is the provision to review the progress and determine what further steps, if any, need to be made to achieve its objectives.

The previous mining company Kwasa Mining Services (Pty) Ltd. has been issued with a Mining Right over the farm Goedehoop 169 HT on 2nd March 2011, Protocol Number 1092/2011, DMR Reference Number MP 30/5/1/2/2/415MR F2009/04/28/004.

uKhozi: KPS600/0216 Page 4 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga Although Kwasa Mining Services (Pty) Ltd. is currently the responsible party, a formal process has been initiated under Section 11 of the MPRDA for the appointed Business Rescue manager to apply to the DMR to transfer the Mining Right to Siphiwo Investments (Pty) Ltd, who is able and willing to take this over, together with the environmental liabilities.

National Environmental Management: Waste Amendment Act, 2014 (Act 26 of 2014) (NEM: WA): To reform the law regulating waste management in order to protect health and the environment by providing reasonable measures for the prevention of pollution and ecological degradation and for securing ecologically sustainable development; to provide for institutional arrangements and planning matters; to provide for national norms and standards for regulating the management of waste by all spheres of government; to provide for specific waste management measures; to provide for the licensing and control of waste management activities; to provide for the remediation of contaminated land; to provide for the national waste information system; to provide for compliance and enforcement; and to provide for matters connected therewith.

 GN No. 921 Category B Activity nr 7 – The disposal of any quantity of hazardous waste to land.

According to the NEM: WA, which came into effect in May 2014, residue stockpiles are seen as hazardous waste. NEM: WA defines residue stockpiles as follows:

“Any debris, discard, tailings, slimes, screening, slurry, waste, rock, foundry sand, mineral processing plant waste, ash or any other product derived from or incidental to a mining operation and which is stockpiled, stored or accumulated, within the mining area for potential re-use, or which is disposed of, by the holder of a mining right, mining permit or, production right or an old order right, including historic mines and dumps created before the implementation of this Act”.

According to GN No. 921 a person who wishes to commence, undertake or conduct a waste management activity listed in Category B of GN No. 921, must conduct a Scoping and Environmental Impact Reporting process set out in the Environmental Impact Assessment regulations made under section 24(5) of the National Environmental Management Act, 1998 (Act 107 of 1998) as part of the waste management license application.

National Environmental Management: Air Quality Act, 2004 (Act 39 of 2004) (NEM: AQA): The objective of the Air Quality Act is to protect the environment by providing the necessary legislation for the prevention of air pollution. The Act also covers potential air pollution originating from stockpiles. As with NEMA, the Act will specify listed activities that may not

uKhozi: KPS600/0216 Page 5 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga be conducted without an atmospheric emission licence. The licensing of such activities will be under the control of the metropolitan and district municipalities.

National Environmental Management: Biodiversity Act (10 of 2004): The Act provides for the management and conservation of South Africa’s biodiversity within the framework of the National Environmental Management Act, 1998. Among other things the Act deals with the protection of listed threatened or protected ecosystems and species, and requires permits to be issued to authorise restricted activities (which include conveying, moving or otherwise translocation of any specimen of a listed threatened or protected species) involving such ecosystems and species. The Act’s permit system is further regulated in the Act’s Threatened or Protected Species Regulations, which were promulgated in February 2007.

Occupational Health &Safety Act (85 of 1993): The objective of Act is to provide for the health and safety of persons at work. In addition, the Act requires that “as far as reasonably practicable, the employers must ensure that their activities do not expose non-employees to health hazards” (Glazewski, 2005: 575). The importance of the Act lies in its numerous regulations, many of which will be relevant to the proposed manganese smelter. These cover, among other issues, noise, lighting, emergency preparedness, management of dust and handling, storage and transportation of hazardous materials.

National Water Act, 1998 (Act no. 36 of 1998) A Water Use License Application has been made with the Department of Water and Sanitation in terms of Section 21 of the National Water Act, 1998 (Act 36 of 1998) for the following water uses:  S.21 (a): Taking water from a water resource;  S.21 (b): Storing water;  S.21 (c): Impeding or diverting the flow of water in a water course;  S.21 (g): Disposing of water or water containing waste in a manner that may detrimentally impact on a water resource;  S.21 (i): Altering the bed, banks or characteristics of a water course;  S.21 (J): Removing, discharging or disposing of water found underground for the continuation of an activity or for the safety of persons.

Approach to the Project

The EIA process is divided into two main phases, which are the Scoping Phase and Environmental Impact Assessment Phases. During these phases public participation is conducted to get input from key stakeholders where the potential exists for them to be affected by a proposed activity.

uKhozi: KPS600/0216 Page 6 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga 1.4.1 Scoping Phase The scoping phase objectives is to identify in broad terms the environmental issues and project alternatives that must be assessed in the subsequent EIA phase. Explicit provision is made in the scoping phase for the involvement of Interested and Affected Parties (IAPs) in the EIA process.

1.4.2 Scope of the EIA The EIA will focus on the biophysical, social and economic impacts that might be caused by the proposed operation and will also address the mitigation measures that will be implemented to avoid and/or minimise these impacts. The public will form part of the process in identifying these impacts during the public participation process that will be conducted throughout the EIA process.

1.4.3 Authority Involvement The Department of Economic Development, Environment and Tourism (DEDET) Ermelo conducted a site visit in September 2014 after the final scoping report was submitted. On the 16th of September 2014 the final scoping report was accepted by DEDET (refer to the acceptance letter in Appendix A.4.1.1).

The Department of Water Affairs (DWA) conducted a site visit on the 21st of May 2013. After the site visit DWA issued a warning letter on the 24th of June 2013 to Kwasa Mining Services (Pty) Ltd indicating that the mine has water use activities that are unlawful and that activities at the mine imposes a risk of polluting the surrounding water resources. DWA afforded the mine an opportunity to make written representations to the Department within 30 days, if according to the responsible party, compelling reasons can be submitted to the Department (refer to Appendix A.4.2 for the full letter).

KSE Services representing Siphiwo replied to DWA’s warning letter on the 19th of July 2013 stating that:  There are several non-compliances at the mine, as noted during the visit by Officials of the Department in June 2013.  Although Kwasa Mining Services (Pty) Ltd. is currently the responsible party, a formal process has been initiated under Section 11 of the MPRDA for the appointed Business Rescue manager to apply to the DMR to transfer the Mining Right to Siphiwo Investments, who is able and willing to take this over, together with the environmental liabilities.  Siphiwo recognises the urgency of the pollution control measures needed on the site.  uKhozi Environmentalists prepared an application for a Water Use Licence which was submitted to Kwasa Collieries in March 2010. Siphiwo is currently following up to

uKhozi: KPS600/0216 Page 7 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga determine the date and office to which this application was submitted. The Department is requested indicate if a copy of this application can be made available.  Siphiwo recognises the need for a coal washing plant to beneficiate the Run-of-Mine coal to an acceptable product specification, and this implies the need for a discard dump.  Siphiwo has received a proposal from uKhozi Environmentalists to address:  Water Use Licence in terms of the National Water Act, 1998 – revision and amendment as per the requirement for a washing plant and discard dump;  Environmental Authorisation in terms of the National Environmental Management Act, 1998– as may be relevant.  In the email accompanying the letter KSE Services indicated that uKhozi Environmentalists have been appointed to conduct the Water Use Licence Application and EIA.  A period of some eight months (plus?) will thus be required for the mine to become environmentally compliant, and STA needs to confirm the feasibility thereof in terms of accepting the responsibility liabilities for the mine (refer to Appendix A.4.2 for full letter).

The Inkomati-Usuthu Catchment Management (IUCMA) Agency conducted a site visit on the 17th of November 2014 in order to advise on the way forward with regards to the Water Use License application.

On the 25th of February 2015 a meeting was held with the Inkomati-Usuthu Catchment Management (IUCMA) Agency and the DMR to find a collective way forward as to who is liable to rehabilitate or to contain the pollution at Kwasa Colliery. uKhozi requested an extension for the submission of the draft EIA/EMP Report in order to finish the necessary specialist studies. The landowner did not allow access for all the specialists in time therefor the report has to be submitted in order to stick to the deadline of February 2016 set by the department.

1.4.4 Public Participation During the Scoping/EIA process a public participation process was undertaken to allow IAPs to voice their concerns and issues regarding the project. The key elements of the process included:  Development and distribution of a background information document (BID);  Informing IAPs of the proposed mining operation through a newspaper advertisement and notification letters.  A key stakeholder meeting held in Piet Retief on the 5th of September 2013 (refer to Appendix A.6.1 for the NfR).

uKhozi: KPS600/0216 Page 8 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga  A meeting was held with the landowner Ms Reinette Boshoff’s representatives, Foster Attorneys in Ottosdal on the 24th of February 2014 (refer to Appendix A.6.3 for the NfR).  A public meeting held in Piet Retief on the 25th of February 2014 (refer to Appendix A.6.2 for the NfR).  A 2nd public meeting held in Piet Retief on the 5th of December 2014 (refer to Appendix A.6.5 for the NfR).

During this process a register of IAPs was compiled, together with a record of their comments and responses from the project proponent and the EAP (refer to Issues and Response Report in section 8.6 of this report).

The Draft Environmental Impact Assessment Report will be emailed or posted to the registered IAPs for their comment. A copy will also be made available at the public library in Piet Retief.

A final public meeting will be held after the IAPs have had time to work through the draft EIA/EMPr. The comments received during the review period and public meeting will be taken into account in finalising the EIA/EMPr for submission to the DEDET. The outstanding specialist studies also need to be completed before the EIA/EMPr can be finalised. This depends on whether the landowner and Applicant can come to an agreement.

1.4.5 Decision Making The decision-making framework comprises of the following:  Department of Economic Development, Environment and Tourism (DEDET), Ermelo;  Inkomati-Usuthu Catchment Management Agency (IUCMA (Nelspruit);  Department of Water and Sanitation (DWS Nelspruit)  Department of Mineral Resources (Witbank) (DMR);  Mkhondo Local Municipality;  Gert Sibande District Municipality;  The Applicant Siphiwo Investments (Pty) Ltd.

1.4.6 Authorities The relevant authorities are described in Table 2.

uKhozi: KPS600/0216 Page 9 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga Table 2: Relevant Authorities Department Description of applicable Contact person department DEDET Department of Agriculture Thabile Mahlakudt and Environmental Affairs [email protected] (Ermelo) which regulates activities as listed under Cell: 072 571 8851 NEMA. DMR Department of Minerals Matshilele Ramovha Resources (Witbank) which [email protected] regulates mining related activities. Tel: 013 653 0500 IUMCA Responsible for water use Thabo Rasiuba applications in the Usutu [email protected] Catchment. Golden Mthembi [email protected]

Tel: 013 753 9000 Cell: 083 825 8894 Fax: 086 668 8681

DWS The Department of Water and Sanitation (DWS), Adolph Mbetse – 078 893 8924 which regulates water and / [email protected] environmental related issues. Responsible for Mdu Nkuna – 083 634 8769 / water use applications [email protected] The Usutu Catchment is the relevant catchment Tel: 013 932 2206 management area.

1.4.7 Application Procedure Table 3: Application Procedure Application for Environmental Authorisation in terms of the National Environmental Management Act (107), 1998 (“NEMA”) Date Activity 27 November 2013  Application was accepted by DEDET on or before  Submit a Draft Scoping Report R.29. 30 May 2014 uKhozi: KPS600/0216 Page 10 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga Application for Environmental Authorisation in terms of the National Environmental Management Act (107), 1998 (“NEMA”) Date Activity 10 July 2014  40 day comment period ends for Draft Scoping Report. 30 July 2014  Submit Final Scoping report. 16 September 2014  Final Scoping Report Accepted by DEDET; October 2014  Appoint Specialists as per the plan of study in the Scoping Report. February 2016  Submit Draft EIAR.

March 2016  30 day comment period ends for Draft EIAR.

30 April 2016  Submit final EIAR.

June 2016  Finalization of the application by the Department.

30 June 2016  If approved –project goes ahead onwards  If not approved, applicant to review options.

Assumptions and Limitations

The report is based on currently available information and, as a result, the following assumptions and limitations are implicit in it:

1.5.1 Assumptions  The report is based on project descriptions from the EMPR that was done for Kwasa Mining Services in March 2010 and these are likely to undergo a number of iterations and refinements before it can be regarded as definite.  The information provided by the applicant is correct and accurate;  A project description based on the final design would be provided if changes occur.  Descriptions of the natural and social environments are based on available studies and field work. More information will be provided in the Final EIA/EMPr based on the outcomes of the specialist studies. The following specialist studies are being conducted:  Hydrogeological and Geochemical Study (Groundwater Consulting Services GCS);  Hydrology Study (GFK Consulting Engineers);  Biodiversity study and Wetland Delineation (Terratest);  Soil Specialist Study (uKhozi Environmentalists);  Visual Impact Assessment (uKhozi Environmentalists);  Heritage Impact Assessment (eThembeni Cultural Heritage); uKhozi: KPS600/0216 Page 11 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga  Integration of the Social and Labour Plan with the Socio Economic Assessment (KSE Services).  The groundwater model will be updated as information becomes available during the operational phase of the colliery.

1.5.2 Gaps in Knowledge The specialist studies were conducted to certain levels of confidence, and in all instances known methodologies have been used and confidence levels are generally high. This means that in most cases the situation described in the pre-mining environment is accurate at high certainty levels, but there exists a low probability that some issues have not been identified during the studies. Such situations cannot be avoided simply due to the nature of field work and have therefore not been further discussed below.

Furthermore, statistical analyses and mathematical models are merely tools which assist the researcher in assessing field observations and have innate assumptions which can reduce objectivity of the results obtained. This is not seen as a major flaw but should always be considered when assessing results.

This report aims to identify potential environmental impacts associated with the proposed activities, however seeing as it is an on-going process the scope of the impacts identified could change through new information coming to light. Should this happen, the new information and changes to the scope will be added to the report. The following specialist studies have not been completed because the landowner refused access to the site and will form part of the final EIA/EMPr:  Hydrogeological Assessment;  Hydrology Assessment;  Heritage Impact Assessment;  Soils and Land Capability.

Independence uKhozi Environmentalists (Pty) Ltd are:  the independent environmental practitioners in this application;  do not have and will not have any vested interest (either business, financial, personal or other) in the undertaking of the proposed activity, other than remuneration for work performed in terms of the Environmental Impact Assessment Regulations, 2010;  will perform the work relating to the application in an objective manner, even if this results in views and findings that are not favourable to the applicant;  declare that there are no circumstances that may compromise our objectivity in performing such work;

uKhozi: KPS600/0216 Page 12 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga  have expertise in conducting environmental impact assessments, including knowledge of the National Environmental Management Act, 1998 (Act107 of 1998), regulations and any guidelines that have relevance to the proposed activity;  will comply with the National Environmental Management Act, 1998 (Act107 of 1998), regulations and all other applicable legislation;  will take the provisions of regulation 7(2) of the EIA Regulations, 2010 into account when preparing any report relating to this application;  undertake to disclose to the applicant and the KZN Department of Agriculture, Environmental Affairs and Rural Development all material information in our possession that reasonably has or may have the potential of influencing its decision with respect to this application;  will ensure that information contained in all reports in respect of this application is distributed or made available to interested and affected parties and that their participation is facilitated in such a manner that they will be provided with a reasonable opportunity to participate and provide comments on the reports;  will provide the competent authority with access to all information at our disposal regarding this application, whether such information is favourable to the applicant or not;  declare that all the particulars furnished by uKhozi in this report are true and correct;  realise that a false declaration is an offence in terms of regulation 71 of the EIA Regulations, 2010 and is punishable in terms of section 24F of the National Environmental Management Act, 1998 (Act 107 of 1998); and  will comply with all the requirements as indicated in the National Environmental Management Act, 1998 (Act 107 of 1998) and Environmental Impact Assessment Regulations, 2010.

Report Structure

This report, which complies with the minimum requirements of National Environmental Management Act (Act 107 of 1998), Environmental Impact Assessment Regulations, has been structured as follows:

 Chapter 1: Introduction and background. This chapter includes the background to the project, EAP and project teams details, the applicant’s contact details, legislative requirements, the approach to the project, assumptions, limitations and gaps in knowledge;

 Chapter 2: Project Description. This chapter includes the property description, objectives of the project, physical project description, mine plan, project phases as well as aspects of mine health and safety.

 Chapter 3: Need and Desirability. This chapter describe the socio economic and biophysical need and desirability of the proposed project. uKhozi: KPS600/0216 Page 13 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga  Chapter 4: Alternatives. This chapter describes the development alternatives and operational alternatives that have been considered for the proposed project.

 Chapter 5: Environmental Status Quo. This chapter describes the baseline environmental conditions on and around the site.

 Chapter 6: Environmental Impact Assessment. This chapter describes the criteria and rating system applied to assess the significance of the impacts along with the impact assessment of each identified impact before mitigation.

 Chapter 7: Environmental Management Plan. This chapter describes the roles and responsibilities, mitigation measures for each identified impact, implementation schedule, and significance rating after mitigation, the probability of the impact occurring pre and post mitigation as well as the closure plan.

 Chapter 8: Public Participation Process. This chapter describes the steps taken by uKhozi to consult with stakeholders and relevant authorities, the results of the consultation process thus far, IAP register as well as an Issues and Response Report;

 Chapter 9: Methodology. This chapter describes the methodology used during the EIA process, guiding principles, as well as the assumptions and limitations;

 Chapter 10: Environmental Impact Statement.

 Chapter 11: References. All documents consulted during the formulation of this report are cited in this chapter.

uKhozi: KPS600/0216 Page 14 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga 2 Project Description Kwasa is a small, underground coal mine. It is planned to establish a wash plant on site. The mining methods will be bord and pillar, using a coal cutter with minimal drill and blast. There will be no secondary mining of the pillars that would compromise the long term integrity of the roof.

Regional Setting

Kwasa Colliery is situated in the Gert Sibande Magisterial District which falls within the Mkhondo Local Municipality in Mpumalanga.

The coal reserve is located approximately 37 km south-west of the town of Piet Retief, 22 km due East of the town of Dirkiesdorp and 58 km East of the town of Wakkerstroom (please refer to Figure 1 and Table 4).

The locality of the area under application is illustrated in the Regional Setting Map. Reference is made to Figure 1 which shows the main features of the land and mining area to which the application relates.

Table 4: Distance to the Neighbouring Towns and Villages Town Distance Dirkiesdorp 22km Piet Retief 31km Wakkerstroom 58km

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Figure 1: Locality Map

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Property Description

The abandoned Kwasa Colliery is located on the farm Goedehoop 169 HT. Please refer to the property details and title dead below.

Table 5: Property Details Property No. Area (ha) Land owner Capacity Description

Goedehoop 169 HT 1 (remaining extent) 801.1229 I.J.C Boshoff Surface owner

Figure 2: Title Deed

The previously disturbed area was abandoned in an un-rehabilitated state with old equipment, scrap metal, old coal dumps and rock heaps. Five shafts in the adit complex

uKhozi: KPS600/0216 Page 17 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga were left open in an unsafe state and the area was also eroded by water erosion over the years.

Figure 3 indicates the specific locations of all the activities planned on portion 0 (RE) of the farm Goedehoop 169 HT for the refurbishment of the Kwasa Colliery.

Figure 3: Specific location of planned activities

2.2.1 Adjacent Land Tenure and Use The adjacent land use consists mainly of agriculture and (to a lesser extent) also coal mining. Agricultural use is in the form of scattered forestry plantations, crops (maize), domestic livestock (cattle and sheep) and artificial pastures. Coal mining activities include:  Protea Colliery (defunct and abandoned), some 12km to the north-east;  Kiepersol Colliery (operational since 2004) adjacent, to the west, and  Savmore Colliery to the North West (defunct).

Parts of the area are inhabited by communities that were relocated from an area south of the mountain (Mhlangamvula). Other areas are still scarcely inhabited as they are commercial farming areas. The current land use thus includes:  Residential – subsistence farming; uKhozi: KPS600/0216 Page 18 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

 Commercial agriculture – grazing;  Commercial agriculture – arable;  Commercial plantations (“Blue gum Trees”).

Bulk sampling has been done in the surrounding area as well.

2.2.2 Presence of Servitudes The following servitudes have been identified on site: Power lines: overhead, supplied and owned by Eskom. Access road: Through the portion of the RE of Goedehoop 169 HT (runs from North to South).

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Figure 4: Map showing surrounding farm

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2.2.3 Zoning The site is currently zoned for agriculture.

Objectives of the project

The purpose of the project is to reclaim the remaining reserve at the old Kwasa Colliery. Mining methods will include underground mining. During the mining operation, the current pollution footprint will be decreased by the establishment of a pollution control system to contain the current source of pollution. The un-rehabilitated areas outside the mining footprint will be rehabilitated as part of the first phase of the project.

Physical Project Description

Kwasa Colliery is a small underground coal mine that was left in an unrehabilitated state. There are construction activities that have been completed as well as infrastructure left on site but these would need to be refurbished during the construction phase. There are also a number of additional construction activities required before sustainable mining can continue. These are described in detail below.

2.4.1 Completed Activities The development of the mine up to this point in time have all been done and funded by Kwasa Mining Services (Pty) Ltd. The following activities had been completed approximately three years ago but would probably need to be refurbished:  Refurbishment of access road to the mine and shafts;  Installation of Eskom power lines and transformers;  Refurbishment of the underground workings, with a) roof stabilisation, b) conveyor system, c) ventilation infrastructure, d) water management.  Fencing of the shafts;  Development of access control;  Setting out of a stockpile and loading area;

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Photo Plate 1: Open adits

Photo Plate 2: Existing access road

Infrastructure on site The following infrastructure is currently on site:  Access roads as well as internal roads;  Security berms and palisades;  Old mining equipment;  Abandoned buildings;  Power Lines.

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Photo Plate 3: Old Mining Equipment

Photo Plate 4: Abandoned Buildings

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Photo Plate 5: Old mining equipment and abandoned buildings

Photo Plate 6: Existing security berm

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Photo Plate 7: Palisades on the mining area

Power is available

Photo Plate 8: Power lines

2.4.2 Planned Activities Construction Phase The following activities will be carried out during the construction phase:  Refurbishment and reconstruction of the water pollution control system;  Construction of one fresh water storage dam;  Construction of four pollution control dams (PCDs);  Construction of silt traps at each PCD;  Transport to site and erection of a modular washing plant; uKhozi: KPS600/0216 Page 25 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

 Preparation of the discard management facility (Co-Disposal Dump site);  Construction of offices and a change house;  Installation of a septic tank system;  Commissioning of an existing weighbridge;  New security house at main gate;  Final trenching and berms;  New runoff water catchment areas;  Three freshwater towers and tanks;  Installation of a new conveyor belt in the Alfred seam adit;  Road signs;  Water pumps and piping for PCDs and clean water storage dam;  Security lights at gates.  Five year contractual commitments for the supply and operation of crushing and screening equipment;  Five year contractual commitments for underground mining services.

The facilities inside the operational area will be fenced such as the PCDs, fresh water dam, washing plant area, co disposal dump site and stockpile areas.

Operational Phase Activities to be conducted during the operational phase of the mine are:

 Underground board and pillar mining with continuous miner which will not involve blasting;  Transportation of run-off mine from the shaft to crushing and screening area via a conveyor belt system;  ROM Stockpiling;  Crushing and screening of run-off mine;  Stockpiling of the coal product;  Spraying of water on access roads to suppress dust;  Transportation of coal product to client via trucks;  Cleaning of silt traps;  Disposal of discard and silt at the Co-Disposal dump site;  Soil stockpiling (hard and softs);  Sewage management;  Solid waste management;  Water management and dirty water handling including recycling water from PCD 3 to the coal washing plant for process water.

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Closure and Post Closure Phase Activities to be conducted during the closure and post-closure phase of the mine are:

 Plugging/sealing of the adits (ventilation, access and exit);  Removal of storage equipment;  Cleaning and re-vegetation of the Co-disposal dump site and product stockpile area at the plant;  Removal of coal wastes;  Demolition of unwanted (by the post-mining land users) infrastructure such as offices, change house, pollution control dams, access roads, high wall etc.;  The pollution control dams will be cleaned before it is filled and re- vegetated.  Landscaping and re-vegetation of disturbed areas.  Ground and surface water monitoring.  The fresh water dam will be left on site for the community and landowner. However if the landowner wants it to be rehabilitated it will also be filled and re-vegetated.

2.4.3 Water Pollution Management Facilities

Storm water will be separated. Clean, unaffected water will be excluded from the area by diversion berms, and storm water falling directly onto the operational areas and has the risk of becoming contaminated, will be contained by berms and directed by cut off trenches through silt traps to one of four pollution control dams. This water is then recycled and used in the washing plant and for dust suppression. This is done to minimise the amount of water extracted for the process from underground sources.

Sources of Contaminated Water

The Co-disposal dump site and coal stockpile areas are the biggest sources of contaminated water during the operational phase of the mine. Incidental water from precipitation that enters the site is another source of contaminated water, which should be contained and prevented from entering the clean water system associated with the mining activities. During the decommissioning phase of the mining operation, seepage from the backfilled adits will be a source of contaminated water. Due to the nature of the backfilled material, there is a possibility of acid mine drainage into the adjacent soils and aquifers.

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A graphical representation of the storm water management plan is shown below in Figure 5. Please refer to Appendix F.1 for the Water Balance Report by GFK Consulting Engineers.

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Figure 5: Graphical representation of the storm water management plan

uKhozi: KPS600/0216 Page 29 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga West Alfrid Adit Clean water will be separated from the operational area by cut of trenches at the top of the West Alfrid Adit. Pollution control berms/channels will be constructed around the operational area to divert the potentially contaminated water falling onto the polluted area into the adit complex from where it will be pumped to PCD 1 with the underground water. The water in PCD 1 will be utilised for dust control to maintain PCD 1 at maximum 5% capacity.

Central Alfrid Adit Clean water will be separated from the operational area by cut of trenches at the top of the Central Alfrid Adit. Pollution control berms/channels will be constructed around the central alfrid adit, Plant, Product and ROM Stockpile area (10ha) to divert the potentially contaminated water falling onto the polluted area into PCD 2. The water falling onto the Central Alfrid Adit complex will be diverted into the complex and pumped to PCD 2 with the underground water. The water in PCD 2 will be utilised for dust control to maintain PCD 2 at maximum 5% capacity.

East Dundas Adit Clean water will be separated from the operational area by cut of trenches at the top of the East Dundas Adit. Pollution control berms/channels will be constructed around the East Dundas Adit and soil stockpiles to divert the potentially contaminated water falling onto the adit area into the complex. The water will then be pumped with the underground water into PCD 3. The water in PCD 3 will be recycled and used as process water in the washing plant.

Co-Disposal Site Clean water will be separated from the Co-Disposal dump site by cut of trenches at the top of the Co-disposal site. Pollution control channels will be constructed around the Co- Disposal site to divert the potentially contaminated water from the site into PCD 3.

Product Stockpiles at Entrance Clean water will be separated from the product stockpile area by the construction of cut of trenches at the top of the stockpile area. Pollution control berms/channels will be constructed around the product stockpile area to divert the potentially contaminated water from the area into PCD 4. The water in PCD 4 will be utilised for dust control to maintain PCD 4 at maximum 5% capacity. Road Network Measures that will be implemented for storm water regarding the roads are the construction of five low level bridges on the internal road from the west adit to the east uKhozi: KPS600/0216 Page 30 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga adit. This will ensure safe passage over the streams with minimal damage to the water resource as well as the riparian habitat. Contaminated storm water falling on the mine area will be diverted to a pollution control dam, depending on the area on the mine.

2.4.4 Domestic water use and sanitation The sewerage plant will be designed for 15 500 litre per day (15% safety margin on design capacity). The water treatment plant will be located at the proposed new dam and will be a small “package plant” consisting of two sedimentation tanks with flocculent dosing, pump, two pressurized sand filters and chorine dosing. Liquid chlorine and flocculent will need be replenished on a monthly basis. No other maintenance other than testing for clarity and chlorine on a daily basis would be required as the system would be automatic. A clear water tank of 30 000m³ would be required.

2.4.5 Waste Management Solid waste management facilities There will be no industrial waste disposal on the site; such waste will be removed by specialist contractors.

Domestic Waste disposal sites All domestic waste which may be generated on site will be collected daily and disposed of at registered landfill site as required.

Hazardous Industrial Waste Most of the hazardous waste originates from the operating, maintenance and servicing of vehicles and equipment. All the hazardous waste will be disposed of in hazardous waste bins and removed by the waste service provider to a hazardous waste site.

Mine Residue disposal sites Waste rock generated from the mining activities will be disposed of at the Co-Disposal dump site on the eastern part of the site. A portion of the discard generated during mining will be sold. The facility will be lined and surrounded by berms. These measures are set in place in order to minimise the chances of contamination due to storm water runoff. Other Waste Other waste includes waste tyres and scrap iron. All scrap iron and waste tyres is sold off to a scrap dealer and paper is disposed with the general waste.

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Figure 6: Layout plan of the mining area

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Figure 7: Product Stockpile area at the access gate

Mine Plan

In short the purpose of the project is to reclaim the remaining reserve at the old Kwasa Colliery.

2.5.1 Mineral deposit The mining layout plan, as depicted in Figure 8 describes the proven reserve as it is planned to be mined, and Figure 9 below shows the location of the adjacent Kiepersol Colliery (operational).

2.5.2 Mine products The mine will produce crushed and screened anthracite and bituminous coal which will be provided to the local and export metaliferous markets.

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Figure 8: Mining Plan

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Operational Kiepersol Proposed Kwasa Colliery Colliery

Figure 9: Proposed Kwasa operation adjacent to the Kiepersol Colliery uKhozi: KPS600/0216 Page 35 of 218

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2.5.3 Estimated Reserve In estimating the Coal Reserves, the following parameters have been applied:

Proven Reserves are tonnages computed from outcrop, mine workings and boreholes, with the ability to establish average calculated quality of the coal within the given geological environment. Normally the estimates would be considered accurate within 10% of the tonnage-and grade, however, as there is some disturbance and the drilling pattern is relatively incomplete, a geological loss of 20% is considered appropriate.

Note: The development of the Kiepersol Colliery on the adjacent farm to the west (where applying various ‘standards’ of reporting demanded by a variety of disciplines, estimates as - disparate as 4,2-million tones ‘sales’ and 3,0-million tones in situ were published) serves as an example when accessibility for drilling, and therefore additional sampling points, is precluded by inaccessible terrain. Drilling will always add to the level of confidence, no matter how complicated the geology, but with limited access only practical mining will solve the problem.

Probable Reserves are tonnages established on more widely spaced information and samples, projected from known conditions, but where additional drilling is required to confidently assess reserves and quality. A 30% geological loss is considered appropriate here.

Alfred Seam The probable Average Coal reserve in Block A (proven) and Block C (probable) totals 2 811 221 tonnes in situ. The Alfred Seam: Average thickness is 1,87m (range 1, 72m-2,74m).

Dundas Seam. Block A Proven Block – 304 404 tonnes in situ and Probable Block C – 3 056 659 tonnes in situ. The probable Average Coal reserve in Block A (proven) and Block C (probable) totals 37l 664 tonnes in situ. The Dundas Seam: Average thickness 1,90m.

2.5.4 Mining Methods The planned mining methods of this proposed mining operation is underground and the following methods will be used:

 Bord-and-pillar method using a coal cutter with minimal drill and blast.

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Production Rate The estimated production rate at this stage is 10 000 – 15 000 tons per months.

Project Life Description The life of the mine is estimated to be between 3-5 years.

Access to workings The underground section will be accessed through the old shafts. The old shafts were stabilised by Kwasa Mining Services for safety reasons. A high wall was created around the mining areas to contain all the dirty water that might be generated within the mining boundary. The storm water accumulating in the old adits will be pumped out and used during the mining process.

Surface subsidence – Mining areas During operations, surface subsidence may occur at the underground adits in the form of landslides and or land slumps of soil or rock from the stockpiles and windrows into the pits. Appropriate management such as geotechnical stability measures and maintaining buffer zones will prevent or limit these negative effects of the movement of earth material.

Structures and drainage paths that may be affected by surface subsidence There are no structures that will be affected by the proposed mining. Rain falling within the construction site will be reused during the construction phase. This water will be prohibited from entering the drainage lines and stream and will therefore affect the quantity of surface water. No subsidence after sealing is expected, however, the mining area will revert back to grassland and no structures or drainage will be affected if limited subsidence at the backfilled adit platform does occur.

Mineral processing There are no processes that will affect the mineralogy of the run-of-mine coal from this project that are applicable to either the extraction and/or preparation of the coal to comply with the market requirements, as the coal will be crushed, screened and washed to meet the metallurgical market requirements.

The beneficiation processes applied to the of the run-of-mine coal (in order to meet the market requirements) are all proven technology.

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Washing and the re-fuelling of the haulage trucks will be undertaken within the bunded area designated and designed for these purposes.

Mine residue disposal Mine residue produced from the production of coal can generally be divided into two distinct types, namely:

Discard: resulting from the separation of a coal product from stone, shale and other “contaminants”, and the discard generated is typically returned to the open pit or placed in a discard dump. Generically, the residue is (ideally) placed right at the bottom of the pit below the groundwater level, in order to minimize the amount of oxygen exposure. Where there is a market for it the discard will be sold.

Overburden: this is removed from above the coal seam(s) during open cast mining to access the coal. This is not applicable for this project as only underground mining is planned.

A runoff control drainage system for storm water will be constructed to collect run-off storm rain water down slope – and to divert clean water upslope of the washing plant and coal stockpiles. This water would feed into a containment / pollution control dam from which water for dust suppression will be drawn. The run-of-mine coal stockpiles will be limited to the washing plant area. This area will be rehabilitated once mining has ceased. The extent of the stockpiles will be limited as coal will be produced to satisfy the off-take agreement. The processed water from the crushing and screening plant will be pumped into PCD 2.

An effective surface water management system would be constructed to protect the wetlands ecosystems, to ensure that the risk of significant impacts will be acceptable.

These systems may also be used for post closure water treatment until a closure certificate is issued. This will be designed in detail during the detailed mine planning phase.

In a similar manner to that proposed for the surface water management, the underground water/decant will be intersected at predetermined point that will be engineered so that all possible contaminated water from the underground sections will be drained from the stoops and contained in the pollution control facility that is designed to contain the 1:50 year flood event.

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Product Transport The transportation of the coal will be by road haulage (trucks) via district and provincial roads. The haul roads within the mining area will facilitate the movement of mine machinery. The existing internal roads will be used. A road linking the plant area and mining area will be constructed to facilitate transportation of the raw material. Existing service roads will be used to access the adits and discard dumps.

The roads will be upgraded with adequate storm water management measures to prevent erosion and to contain potentially contaminated surface run-off. Regular dust suppression by water spray onto the dirt road surfaces will take place to minimize dust generation.

The existing Kiepersol Colliery access road will be used to transport the product from the mining area to the district road R543.

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Kiepersol Access Road

Figure 9: Map reflecting the locality of the study area in relation to the access routes and neighbouring town uKhozi: KPS600/0216 Page 40 of 218

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Project Phases

The three broad components of the project have been listed as follows, and described below:  Compliance (including application, planning and environmental authorisation);  Operation (including construction and operational phase and includes the management of waste material); and  Decommissioning (including implementation and monitoring of rehabilitation).

The applicant, Siphiwo Investments plans to operate the Kwasa Colliery over a period of 10 years. Depending on the results for further prospecting, rehabilitation for the underground sections will commence once the entire proven reserve has been mined. Rehabilitation is expected to continue for three years thereafter.

The compliance phase would take another 6-9 months before the necessary environmental authorisation is granted. Pollution control structures and roads will be established within the first quarter of the construction phase. However Siphiwo Investments and uKhozi are currently in discussions with DWS and IUMCA to start the construction of the pollution control system before the granting of the WUL in order to contain the current source of pollution (unrehabilitated area).

The actual target date for the commencing of the construction phase is September 2015. The first year of operation will focus on the underground board and pillar mining.

2.6.1 Construction Phase The construction phase would take three months before the necessary pollution control measures are functional.

The main activities that will be undertaken during the construction phase will include the following:  Construction of on-site haulage road between the proposed plant area, adit complexes and stockpile area.  Construction /upgrading of service road.  Construction of berms and cut-off trenches.  Construction of pollution control dams and silt traps;  Construction of an off-stream storage dam;  Transport to site and erection of a modular washing plant;  Preparation of the discard management facility;  Preparation of ROM and product stockpile areas;  Construction of offices and a change house;  Installation of a septic tank system; uKhozi: KPS600/0216 Page 41 of 218

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 Commissioning of an existing weighbridge;  Installation of a new conveyor belt in the Alfred seam belt adit;  Water pumps and piping for PCDs and storage dam;  Erection of offices and other mining related infrastructure (weighbridge etc.).

2.6.2 Operational Phase The mining operation is planned to run at a constant production rate for the proposed life of the mine.

Once the Environmental Authorisation and Water Use Licence is issued, operations will commence immediately. The mining will be undertaken by contractors, which will use proven technology in terms of:  Underground mining: Bord-and-pillar method using a coal cutter with minimal drill and blast.

The following additional activities will take place:  Crushing, Screening and washing of coal;  Dust suppression;  Dirty water management; and

2.6.3 Rehabilitation/Decommissioning The following activities will take place during the rehabilitation phase:

Table 6: Activities during Rehabilitation Activity Description Removal of surface infrastructure Removal of temporary container offices and (buildings, etc). chemical toilets. Sealing of underground workings. Sealing of the underground workings and adit. Implementation and management of Rehabilitation of land for the target post-mining rehabilitation programme. land use of grazing.

2.6.4 Development Procedure The public participation process has started and will be ongoing throughout the environmental authorisation process. All the comments and concerns raised by the IAPs need to be addressed in the Final EIA/EMP report and Siphiwo need to commit to adhere to the mitigation measures and commitments made in this report. The IAPs need to be kept in the loop throughout the proposed mining operation and especially afterwards with the rehabilitation of the disturbed land.

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A legal process has been initiated for the S.11 transfer of ownership of the Mineral Rights from Kwasa Mining Services to Siphiwo Investments. A legal process is also underway to buy the farm from the landowner Reinette Boshoff (Please refer to correspondence with her attorneys in Appendix A.2.1 and Appendix A.6.3).

Once the environmental authorisation is granted for all the listed activities applied for and a Water Use Licence issued by DWS for all the water uses applied for, Siphiwo will start with the refurbishment and reconstruction of the water pollution control system. This will take approximately 3 months. Please note that Siphiwo Investments and uKhozi are currently in discussions with DWS and IUMCA to start the construction of the pollution control system before the granting of the WUL in order to contain the current source of pollution from the unrehabilitated area. If this is agreed to the departments and IAPs will be informed of this decision.

The other construction activities will occur after the WUL and Environmental authorisation is granted and will include:  Refurbishment of the underground working workings, with (a) roof stabilisation, (b) conveyor system, (c) ventilation infrastructure, (d) water management.  Refurbishment of the access roads;  Transport to site and erection of a modular washing plant;  Installation of a septic tank system;  Preparation of the discard management facility (Co-Disposal Dump site).

Please refer to Table 7 below for a summary of the development activities.

Table 7: Summary of Development Activities Duration Responsible No. Development Activities (months) party 1 Ongoing public participation process ongoing uKhozi 2 Ongoing legal processes: Matswani 2.a S.11 transfer of ownership of the Mineral 3 to 9 months Matswani Rights 2.b Surface Rights. 3-6 months Matswani 2.c Mining Right completed Siphiwo 2.d EIA authorisations 4 months uKhozi 2.e Water Use Licence 4 months uKhozi

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Duration Responsible No. Development Activities (months) party 3 Refurbishment and reconstruction of the ASAP. 3 months. Siphiwo water pollution control system 4 Refurbishment of the underground 3 months Siphiwo working workings, with a) roof stabilisation, b) conveyor system, c) ventilation infrastructure, d) water management. 5 Refurbishment of the access roads. 3 months Siphiwo 6 Transport to site and erection of a 3 months after WULA Siphiwo modular washing plant has been approved 7 Preparation of the discard management 3 months Siphiwo facility and stockpile areas

Aspects of Mine Health and Safety

2.7.1 Background As a requirement of the Department of Mineral Resources towards compiling an integrated EMP report, a provisional description of Mine Health and Safety aspects has been made to assist the Department in its holistic approach to mining. This will be finalised in conjunction with the final mine plan.

2.7.2 Health and Safety: General Employees will be trained in safety and health and be issued with the necessary protective clothing and equipment, including:  Hard-hats,  Safety shoes,  Safety goggles,  Gloves, and  Hearing protection.

2.7.3 Traffic The speed limit on the internal roads will be 40km/h for heavy vehicles and 60km/h for light vehicles. This will also assist in reducing the generation of the dust.

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3 Need and Desirability Socio Economic

The anthracitic coal produced by the colliery will be used for the local and export metallurgical market thereby benefiting the whole of the country. The benefits of the mining to the community largely centre on the Social and Labour Plan. Exporting of the coal will contribute positively to the South African Economy.

The local socio-economically depressed and geographically marginalised communities would benefit directly from the refurbishment and recommissioning of the mine. The impact here would be long term, passed the life of the mine itself. The proposed operation will be creating 60 new jobs which where possible will be sourced locally. All the staff will be trained and this will also uplift the community. The activities will provide employment for locals and support services, as well as empowerment and skills transfer opportunities. Seen in the light of the current economic environment, having an income has a high effect on the quality of life of families, creating a positive effect. This can therefore be considered a significant benefit. The proposed operation will be creating 11 indirect jobs by employing contractors for security (8), operating of the weighbridge and doing admin (3). The employment opportunities on the mine will indirectly provide further opportunities for small scale entrepreneurs to sell and produce other forms of consumables. The local communities might be able to provide housing for the employees of the mine and make a profit from the rent.

The proposed area is an abandoned mine, which poses a great safety risk. Should the mining operations be approved, the area will be fenced off and rehabilitated. This will increase the safety of the area, as well as provide possibilities for future land use. The employees of the proposed activities, will be sufficiently trained in order to promote a safe environment.

To summarize the impact that the mining would have in the local and sending communities and the surrounding areas in line with the duration of the mining right, include but not limited to the following:

 A number of jobs created;  Small, Medium and Micro-sized Enterprises (SMMEs) development;  Infrastructure development;  Community Development;  Poverty Eradication and;  Rehabilitation of the area.

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Biophysical

The local situation will also be directly and positively affected in that the defunct and abandoned colliery will be rehabilitated after mining seizes. Currently the colliery is polluting the surrounding environment especially the surface and groundwater resources. During rainfall events the coal discard lying around on site ends up in the surrounding streams which flow into the Annysspruit. Farmers have reported loss of livestock after they drank the water of the streams flowing down gradient of the colliery. If mining goes ahead proper storm water management measures will be implemented to contain the polluted storm water runoff. After the source is contained the applicant can start a process to clean up the streams. This will have a positive impact biophysically and socioeconomically by reducing the pollution of the surrounding surface water resources and minimizing the risk that livestock will be lost in the future. The site will be managed and kept in a better condition and rehabilitated after mining seizes.

Project Market

The coal produced by this mine will mostly be sent to the export market (80% of in situ tonnage). The remainder (20% of the in situ tonnage) would be used by the local iron and steel production industries. Labour Force

The proposed operation will be creating 60 direct jobs which where possible will be sourced locally. The proposed operation will be creating 11 indirect jobs by employing contractors for security (8), operating of the weighbridge and doing admin (3).

All the staff will be trained and this will also uplift the community.

The Multiplier Effect

According to multiplier affect there is an average of five persons per household in the Piet Retief district. Thus, taking into account that the total labour force to be employed at the mine is 60 persons, the multiplier effect comes to a calculated total of 300 persons influenced. This means that the lives of a total of 300 people in the region will be directly influenced by the refurbishment and recommissioning of the Kwasa Colliery.

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4 Alternatives Development Alternatives

There are four main sets of alternatives associated with the recommissioning of this underground coal mining operation, namely:

a) The underground operation with no additional washing plant and discard dump, where the Run-of-Mine coal is beneficiated (washed) off site at a remote plant (this proved to be not feasible over the past three years of operation).

In order to produce a product that is marketable on an economically profitable and sustainable basis the product must be washed. Dry screening and crushing would be an alternative but would fail to produce the required product. Thus this alternative will not be implemented because it is not economically profitable or sustainable for Siphiwo Investments.

b) The underground operation together with a wash plant and associated discard dump, in the vicinity of the current operation (preferred).

This is the preferred alternative. The area was left in an un-rehabilitated state with coal waste lying around on site. During rainfall events this coal waste ends up in the surrounding surface water resources. If the mining operation continues, storm water management measures will be implemented in order to contain the polluted storm water falling onto the mining area. This will mean that the source currently contaminating the surrounding water resources will be contained. As mentioned above in order for the mining operation to be sustainable a washing plant needs to be constructed on site. If this does not happen the chances are good that the planned mining operation will be cancelled which will mean that the pollution currently occurring on site, will continue.

The main negative impact of this alternative would be the potential contamination of the surrounding water resources if the storm water measures are not implemented correctly as well as a cumulative effect on dust pollution caused by the haulage trucks.

Summary of negative impact for alternative (b) Magnitude Timing Duration Probability Level of Significance

Large Future L/T Temporary L/T Possible Moderate

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The positive impact will be that the product can be mined on an economically profitable and sustainable basis which would mean that the mining operation will continue thus cleaning up the area and containing the source of pollution.

Summary of positive impact for alternative (b) Magnitude Timing Duration Probability Level of Significance

Moderate Future S/T Permanent Probable High

**Refer to all the identified positive and negative impacts of this alternative in section 6 of this report.

c) The underground operation together with a wash plant and associated discard dump, located at the abandoned Protea colliery, some seven kilometres north of Kwasa.

This alternative would be considered if for some reason the wash plant and associated discard dump could not be established at the underground operation.

This is not the preferred alternative because it would mean that a 7km road would need to be upgraded from the underground operation to the abandoned old Protea Colliery. The negative impacts would be that the ROM would need to be transported approximately 7km from the underground operation to the washing plant which will increase the cumulative impact of dust, noise and visual pollution. This will also increase the size of the mine footprint and risks of contamination while transporting the ROM.

Summary of negative impact for alternative (c) Magnitude Timing Duration Probability Level of Significance

Large Future L/T Temporary L/T Probable High

The main positive impact will be that storm water management measures would be implemented at the abandoned old Protea Colliery thus containing the pollution of the surrounding area that is currently occurring.

Summary of positive impact for alternative (c) Magnitude Timing Duration Probability Level of Significance

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Large Future L/T Permanent Probable High

d) No go Option.

Should the mine not proceed:

 A source of 5 million tonnes of saleable coal will be lost.  Employment opportunities for 60-75 individuals will not be forthcoming.  The multiplier effect will not be realised; and  The area will remain un-rehabilitated and continue to pollute the surrounding environment.

The positive impacts would be:  The community will not be disrupted by the mining activities;  No additional traffic on the district roads as well as the access road to Jindal;  There will not be a cumulative impact of dust pollution in the area;  There will be no risk for the landowners and IAPs that the area could be contaminated further and left in a worse state;

Operational Alternatives

4.2.1 Mining Method As this is purely an underground mine, the major impact on land use alternatives is from the adit and infrastructure on site as well as from the impact on the water resources. The adit site itself is not suitable for any agricultural activity. Mitigation measures can be implemented in such a way, that the loss of the grazing areas due to the mining activities is reduced.

The major alternative land use has been compromised due to the mine being left in an un- rehabilitated state. The area would need to be rehabilitated before it can be used for agricultural activities such as grazing. This will not be significantly compromised by the proposed activity.

Underground mining is the most feasible method of mining and the bord-and-pillar method will be used along with a coal cutter with minimal drill and blast. This technology will be used to ensure stability of the surface. There will be no secondary mining of the pillars to ensure that the roof will remain competent. uKhozi: KPS600/0216 Page 49 of 218

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4.2.2 Mineral Processing Methods In order to produce a product that is marketable on an economically profitable and sustainable basis the product must be washed.

Dry screening and crushing would be an alternative but would fail to produce the required product.

4.2.3 Transport Existing Kiepersol Access Road A 10km tarred access road from the district road to Kiepersol exists. If an agreement can be reached with Jindal and the IAPs using the road this would be the best option for Siphiwo. Internal roads would need to be upgraded between the plant area and the various adit openings. All culverts along the internal roads would need to be upgraded to accommodate a greater volume of storm water.

An alternative option would be to construct a new road from the district road directly towards the Kwasa Colliery. This option will not make biophysical or economic sense. Biophysically it will have significant impacts on the environment especially the wetlands and streams found north of the Kwasa Colliery. Economically it would be extremely expensive to construct a new 10km access road. Especially considering that there is an existing road that can be used.

4.2.4 Sources of Water Water supply from the old workings as well as contaminated water from the pollution control dams will be used for dust suppression and make up water for the plant. It is proposed that a fresh water dam is constructed to use for potable water and possible make-up water for the plant during the dry winter months. As the water will be stored, clean runoff will be captured in this dam and prevented from entering the natural watercourses in the area. This will influence the quantity of runoff entering the streams located downstream of the site. A pipeline of approximately 2.5 km have to be constructed from this dam to the washing plant which will disturb the soils and vegetation.

The dam will have a positive impact on the community because it is planned that the water stored in the dam will also be used by the community for irrigation and stock watering. The fresh water dam must be constructed with an outlet in order to let water back into the downstream water resources.

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Alternative options are to source water from the Savmore dam or to drill boreholes for make-up water.

4.2.5 Mine infrastructure sites The disturbed areas on the RE of Goedehoop 169 HT have been selected as infrastructure because of the existing de facto change in land use. Minimal infrastructure will be erected at the adit sites to minimise the impact. Temporary offices will be constructed below the plant area on an undisturbed surface. All old buildings as used during previous mining activities (as located at the old central adit) will be removed.

Diesel will be stored in a bunded facility at the plant area.

4.2.6 Mine residue disposal site The preferred site for the Co-Disposal Dump is shown on the surface layout plan in Figure 6, three candidate sites were considered and the final site as per the plan was selected based on its suitability:

The other two mine residue deposit sites were found to be less suitable based on:  Distance from the plant area;  The locations were undisturbed land;  Uneven topography.

A detailed Discard management design and operation report has been prepared by GFK Consulting Engineers during the Integrated Water Management report (refer to Appendix F.1)

4.2.7 Domestic and Industrial Waste Disposal Sites As there will be no housing on the premises only the office complex will generate a small quantity of domestic waste which will be stored in containers. These containers will be cleaned and the waste removed to a registered waste site of the premises. The details of this waste site will be forwarded to the DEDET and the DMR once finalised.

Industrial waste such as used oils will be removed from the mining area by registered contractors. The details of these contractors will be forwarded to the DEDET and the DMR on appointment.

4.2.8 Housing Sites

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No housing sites are being provided. The philosophy is that people can develop their own homes in Piet Retief or the nearby villages around Dirkiesdorp. This provides more security for the individuals and enables them to invest in their homes rather than live in mine houses.

4.2.9 Land Use Option after Rehabilitation The considered alternative land uses could include:  Extension of the agricultural/residential use over the entire area;  Grazing.

The RE of Goedehoop 169 HT is best suited to artificial grazing which could be sold to a local entity post closure.

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5 Existing Status of the Environment The baseline information presented below concerns the environment which may be affected by the mining activities in order to determine protection, remedial measures and environmental management objectives.

Description of the potentially affected environment

A description is given below of the environment likely to be affected by proposed mining operations:

Kwasa Colliery is situated on the remaining extent of the farm Goedehoop 169 HT on the edge of the mountain. The area around the mine is severely transformed from the natural state in some places, although the natural environment was pristine in others. The important drivers of the transformation have been agriculture, livestock grazing, and coal mining. In addition, it is probable that some impacts are associated with the existing mine (Kiepersol Colliery) to the immediate west of the present site. These impacts will include pollution and the existence of a sterile block, inhospitable to many species and which will be a barrier to movements of key fauna including pollinators. There is a non-perennial stream that flows on the western side of the mining area. In the immediate surroundings of Kwasa Colliery, there are no public roads, railway lines, residential areas or cemetery or any other land for public use that may prohibit this mining operation. Access to the colliery is obtained via existing roads.

The area has a high conservation status, mainly because of high species diversity found in the grassland biomes. In 1999, seven Natural Heritage Sites and a private nature reserve had been registered. The two that are of importance to this proposed mine are the following areas:

 Site No. 83: uMhlangamvula (1,600 ha) registered as a result of the presence of Aloe hlanganpise, Samango monkey, Oribi, Serval, martial eagle Ground hornbill and Bald ibis.  Site No. 119: Rooikraal (1,170 ha) registered as a result of the presence of Oribi, Aardwolf and Serval, as well as many species of Podocarpus, Alsophila and Cussonia plants.

The mountain stream is a sensitive environment, as are the areas of indigenous vegetation and the wetlands.

The identified land-use objectives after closure include:

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 Stabilise the affected areas by landscaping and vegetating the areas to afford the land capability of grazing;

 Manage the surface water and groundwater to ensure that the mining activities do not cause an unacceptable, negative impact on the receiving environment nor on the affected groundwater aquifer;

 Recreate a land capability that will sustain an applied and controlled grazing programme. The land should be suitably rehabilitated to sustain the planned post closure use with a stocking rate of one large stock unit per eight hectares per annum.

 Establish an area that can be used for the sustainable grazing of domestic animals.

Description of the landscape surrounding the operation

The general region within which the mine site is located is recognised for its wetland richness and for the extensive biodiversity associated with the wetlands. This diversity, together with that of the original grasslands and some forest patches has been the basis for conservation measures such as an inter-provincial grasslands programme and the establishment of the Important Birding Area. Therefore, the presence of extensive wetland areas on parts of the mine property is in keeping with its surrounds. However, as is also typical of the region, a large part of the wetlands have been lost as a result of past human activities. According to Low and Rebelo (Low & Rebelo 1996) the wider study area forms part of the North-eastern Mountain Grassland (Piet Retief Sourveld) Biome. This vegetation type comprises the grasslands of the northern parts of the great escarpment mountains in Mpumalanga which stretch northwards into the Northern Province, and southwards through KwaZulu-Natal, reaching the northern parts of Eastern Cape. Altitude ranges from 1,400 to 1,900m above mean sea level (amsl). The abandoned Kwasa Colliery falls inside the Nkangala Grassland project. A large part of the area surrounding and including Goedehoop 169 HT is also under application to become part of the Wakkerstroom Wetland Grasslands protection area.

Adjacent to the defunct Kwasa Colliery is the Kiepersol Colliery that has been active since 2004 as well as the abandoned Protea Colliery.

Assessment of the environment likely to be affected and description of current environmental state of the study area

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Regional climate The regional climate can be described as falling within the Highveld climatic zone (sub- humid), with a summer (October to February) to winter (April to August) range of around 19º C with average temperatures in the contrasting seasons, of 26º C and 8º C.

Rainfall Mkhondo Local Municipality falls within a summer rainfall area, with approximately 85% of the annual rainfall occurring in the summer months from October till February in the form of showers and thunderstorms. The average MAP of the Usutu (including Swaziland) is approximately 850 mm/annum and ranges from 500 mm/annum in the eastern areas to 1 200 mm/annum in higher lying areas within Swaziland, then declining as one moves further west to between 750 and 850 mm/annum on the eastern escarpment of the Drakensberg.

5.3.2 Air quality In the pre-mining environment, there are no major local sources of air pollution. Adjacent to the site on the south-west of the study area there is an existing coal mining operation (Kiepersol Colliery Operations) which contributes to air pollution through dust as well as diesel fumes from the operational trucks and vehicles. In the immediate vicinity, there is some potential for dust pollution due to traffic on the gravel roads and general agricultural activity. In the dry season there is the possibility of air pollution during the burning of fire breaks and uncontrolled veld fires. Smoke from cooking and heating fires from the nearby settlements also have an impact on the air quality in the area.

5.3.3 Geology Regional Geology This coal reserve falls within the Karoo Super Group and is part of the Vryheid Formation of the Ecca Group. The formation consists of sediments of varying grain sizes from shales to course sandstones. Intrusive rocks would consist of Karoo dolerite with a series of dykes and sills. The succession of the four coal seams from top to bottom (with average seam thickness) is as follows:

 Eland seam (0,7 – 0,9 m),  Alfred seam (1,1 to 2,1 m),  Gus seam (0,5 to 1 m ) and the  Dundas seam (1,5 to 2,5 m).

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Although there has been much transgressed activity, there are a number of smaller faults within the mining area; no major faults traverse the area. A range of anthracitic and lean to bituminous type coal is found within the reserve.

The uMhlangamvula Mountain is capped by the No 10 dolerite sill which overlies the B5 and B6 dolerite sills. The Zuinguin dolerite body intrudes the area as a dyke. The Ingogo dolerite dyke also intrudes the area. The B3 intersects the coal seam in the west which has caused a large section of coal to be burnt.

5.3.4 Topography The pre-mining, natural topography of the area is a combination of steep slopes and relatively flat (natural) terraces. The operational area has a modified topography consisting of a terrace (cut and fill) sloping gradually back into the mountain.

Access to the colliery will be made via the existing properly constructed access road, which follows the gradient of the mountain.

Figure 10: Elevation profile of the proposed site (North to South)

5.3.5 Land capability Generic definitions of land capability The land capability of the areas associated with mining can be classified into five classes, namely:  Wetland;  Arable;  Grazing;  Wilderness; and  rehabilitated areas.

according to the Chamber of Mines of South Africa Guidelines for Environmental Protection, Volume 3/1982.

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The proportions calculated previously for the area have been used as a point of departure for the current situation. An area of 5ha has been disturbed for the operational area, which was used by the previous mining activities. Even taking into account, the more recent guidelines having been made available by the Department of Water Affairs for the delineation of wetlands, it is not expected that the percentage of area classified as wetland would increase, as the water course is outside the operational area. This will not directly affect the assessment of the impact of mining as the area developed does not include pristine wetlands.

Description Based on the description of the soils and topography in the area under application, the land capability can be described as largely grazing and wilderness, with the area under the operational, adit complex, potentially (post-mining) falling into the category of rehabilitated mining land.

Table 8: Pre-mining land capability of the operational adit complex Class Description (Ha) (%) Class I Wetland 0 Class II Arable 0 Class III Grazing (prev. 1.5) (prev. 30%) Class IV Wilderness 0 (prev. 3.5) (prev. 70%) Class V Rehabilitated 5 (potentially) after closure: 100 Areas Total 5 100

5.3.6 Land Use The most significant land uses in the upper Usutu catchment are afforestation and irrigation. The total area under afforestation in the South African portion of the Usutu catchment is estimated at 1 930 km2, while the irrigated area is limited to 27km2.

The surface area under application can be divided into the following two categories:  Wilderness used for grazing;  Unrehabilitated mining area.

Coal waste is lying around on the unrehabilitated mining area and has the potential to pollute the surrounding water resources during rainfall events.

Adjacent to the Kwasa Colliery to the west lies the operational Kiepersol Colliery. The other adjacent land uses are afforestation and agriculture. uKhozi: KPS600/0216 Page 57 of 218

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5.3.7 Soils Description of the type of soil found on the surface of the site Regionally, a number of soil forms can be found in the area. Predominantly, the soils are loamy and clayey, and of red and yellow colour. Most of the soils are of a dystrophic and/or mesotrophic nature.

The dominant soil form in the disturbed area is the Hutton Form which is associated with the dolerite boulder based scree slope as the pedology of the soil. The soil texture has high clay content and is rich in iron oxide. The soil is dystrophic as a result of the high rainfall.

Please note that a specialist soil study is currently underway and the information from this study will be included in the final EIA/EMPr.

Topsoil depth The soil within the mining area is generally deep, interspersed with dolerite boulders of varying sizes.

5.3.8 Vegetation Plants, trees and grasses growing naturally in the area around the site A biodiversity study was done by Terratest (Pty) Ltd in January 2016. It was recognised at the outset that the study could potentially be hampered because, despite being undertaken in the rainy season, the site surveys had to be done under drought conditions. The implication of this were as follows:  Plant growth would have been reduced and so the observable diversity would be less than could be expected.

According to Mucina and Rutherford (2006) the indigenous vegetation types in the area in which the mine is located are as shown in Table 9 and in Figure 11.

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Table 9: Vegetation types on the original Farm Goedehoop 169 HT (Conservation status from Mucina and Rutherford (2006)

The Mpumalanga Conservation Plan was interrogated to search for conservation priorities. It was found that the key features listed for the area around the site are the natural vegetation types and the status accorded to the three types found at the site is indicated in Table 10. The property in which the mine site is listed as being of “Least Concern” at the northern end and ranges through “Highly Significant” to “Irreplaceable” in the high-lying areas at the southern end. This spectrum appears to be in contradiction to the status of the vegetation types present but is most probably based on the condition of the vegetation in the various areas.

Table 10: Vegetation types on the original Farm Goedehoop 169 HT. Conservation status from Mucina and Rutherford (2006).

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Figure 11: Dominant vegetation types on the mine property. Source: Mucina and Rutherford (2006)

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The Mpumalanga Biodiversity Sector Plan (2014) shows the ecosystems in the area around the mine site to be “Endangered”.

Figure 12: Mpumalanga Biodiversity Sector Plan (2014) for the area around the mine site.

In 2011 the status of the site was “Vulnerable” but it has been downgraded as a result of continued development in the area. The factors listed as responsible for the change include urban development, agricultural expansion and increase in mining activities.

During the field assessment the transitions between the three vegetation types which are present on the property are clearly apparent although there are clear differences in the condition of the veld. On the lower, flatter areas much of the natural vegetation has been displaced by agriculture. In a few places crops are still being cultivated with maize being predominant. However, over considerable areas the lands have been abandoned and are now lying fallow and are slowly being grown over by a variety of weeds and pioneer indigenous species (See Figure 13).

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Figure 13: Areas which have been, or still are, under cultivation and timber production

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Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga The figure shows clearly that the crop lands and the timber plantation are concentrated in the central and northern portions of the property since the lowest gradients are in those areas. It is also apparent that in some places the agriculture has taken place in wetland areas. The largest such area is at the far northern end of the property where the area involved is considerable. It is not known when the cultivation was first undertaken but it is likely to have been at least 40 or 50 years ago. On those parts of the property where the topography is steeper the indigenous vegetation remains in good condition. Within this area are portions of the Paulpietersburg Moist Grassland and all of the Wakkerstroom Montane Grassland. The tables below show some of the indigenous species found on site.

Table 11: Indigenous flowers found on the site Acalypha spp, Adenathellum osmitoides Aloe minima Agapanthus spp Ammocharis coranica Anthericum spp Anthospermum spp Aristia woodii Astripomoea spp Berkheya spp Buddleia salviifolia Commelina spp Conyza podocephala Cyperus spp Dianthus spp Eriospermum spp Gerbera spp Haemanthus spp Helichrysum spp Hypoxis spp (3 different species) Indigofera spp Ipomoea spp Kohautia spp Kyllinga alba Ledebouria spp Leonotis Leonura Lobelia spp Maytenus sp Monopsis spp Moraea spp Nesaea grandis Pachycarpus spp Oxalis spp Pelagonium luridum Pentanisia spp Pseudognphalium luteo album Rhoicissus spp Satyrium sp Sebaea sp Scabiosa spp Sphenostylis angustifolia Waltheria densiflora Watsonia spp Zantedeschia aethiopica

uKhozi: KPS600/0216 Page 63 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga Table 12: Indigenous trees found on the site Scientific Name Common Name Leucosidea sericea Ouhout Cussonia paniculata Cabbage tree or Kiepersol Rapanea melanophloeos Cape Beach Myrica pilulifera Broadleaf waxberry Psychotria capensis Bastard lemonwood Vaccinium exul Blueberry

Table 13: Grass species found in the site Scientific Name Common Name Themeda triandra Rooigras Tristachya leucothrix Drieblomgras Hyparrhenia hirta Thatch grass Setaria nigrirostis Bristle grass Eragrostis curvula Oulandsgras/weeping love grass Rhynchelytrum nerviglume Bergblinkgras Heteropogon contortus Assegaaigras Melinis repens Natal red top Aristida junctiformis Ngongoni Pennisetum clandestinum Kikuyu Cynodon dactylon Couch grass/ kweekgras

(Please refer to the Terratest Report: Assessment of the Biodiversity and Wetlands in Appendix F.2 for the list of indigenous species found in the study area). The lower lying areas do show some signs of being grazed by cattle but the extent of the grazing has been low and so it is not an issue of concern. Plant species diversity is high and basal cover is generally good. While there are some Wattle Trees (Acacia mearnsii) present in places, alien plants are generally not abundant. Soil erosion is largely restricted to the drainage lines and is not extensive at any site seen other than in the actual footprint of the mining area. In the higher lying areas, located generally at or above the level of the mine adits, the vegetation is in pristine or near pristine condition.

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Photo Plate 1: Paulpietersburg Moist Grassland and Wakkerstroom Montane Grassland near the western and central mine adits

Photo Plate 2: Woody vegetation along a stream channel (Note the absence of water)

Animals naturally occurring in the area No detailed faunal survey was undertaken at the time of the site visit but note was made of any animals seen. The list of species is presented in Appendix II of the Biodiversity and Wetland Assessment conducted by Terratest. Please refer to Appendix F.2.

None of the species actually seen is red data listed although the Aaardvark (Orycteropus afer) is listed under the TOPS Regulations as a “Protected Species” as defined in Section 56(1) (d) under the National Environmental Management: Biodiversity Act (Act 10 of 2004. In addition, it is also probable that other listed species are still present, or at least occasionally present, on the site. Examples of such species are the Grey Crowned Crane (Balearica regulorum) and the Secretary

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In addition to the terrestrial fauna noted, it had also been intended to survey the aquatic fauna using the SASS5 procedure for the invertebrates and electrofishing for fishes. However, because of the dry conditions, with some streams having no flowing water at all, these surveys could not be undertaken.

Avifauna In broader terms, a Highveld Grassland habitat once occurred over much of southern Mpumalanga, but this has now largely been transformed into monocultures by agriculture and forestry. Where pristine grassland remains, the biodiversity needs to be retained. The mine site lies within Important Bird Area number SA 020 but is close to the eastern border. The site is important for its grassland and wetland bird species and extends through parts of KwaZulu-Natal, Mpumalanga, and the Free State Provinces. The area around the mine will be of more relevance in relation to grassland birds although the northern is within a wetland which, although highly degraded, could still hold a number of red data listed species as listed in Table 14.

Table 14: Red Data listed bird species recorded in the area around the mine.

Mammals The following species of mammals are common to the broader area.

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The MTPA has also confirmed the following mammal species as being threatened species in the broader area:

Table 16: Threatened Mammal Species occurring in Mkhondo 3.2.3. Common name Scientific name Oribi Ourebia ourebi (Zimmerman 1783) Aardvark Orycteropus afer (Pallas 1766)

Conservation Areas The closest formal conservation area is the Paardeplaats Nature Reserve which is approximately 10 km south west of the mine adits.

5.3.9 Surface Water The mining area falls in the Usutu Catchment. The mine is in a portion of the headwaters of the Anysspruit which in turn flows into the Assegaairivier downstream of Heyeshope Dam.

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Figure 14: Usutu to Mhlatuze WMA

uKhozi: KPS600/0216 Page 68 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga The Usutu catchment is of strategic importance because water for the cooling of coal-fired power generation plants, situated in the Vaal and Olifants systems, is sourced from this catchment, with the Heyshope, Morgenstond, Westoe and Jericho dams providing the transferable yield for these power stations. These dams are all situated upstream of Swaziland and the catchment forms part of the Maputo River Basin which is an international river basin.

Quaternary Catchment information The study area falls within the farm Goedehoop 169 HT which is in turn is situated in quaternary sub-catchment W51C; the catchment of the Vegkop River is 161km2.

The Vegkop River is a tributary of the Annysspruit which flows into the Assegaai (Mkhondo) River, which flows from this drainage region north-eastwards, joining the Great Usutu River in Swaziland, and flowing into the sea in Mozambique.

Reference is made to the Usutu Mhlatuze Water Management Area: Overview of Water Resources Report No. P WMA 06/000/00/02/03. Refer to Figure 15 below.

Kwasa Colliery

Figure 15: Upper Usutu Catchment

uKhozi: KPS600/0216 Page 69 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga The central area of this catchment is quite dissected and has a high erosion potential due to the intense rainfall events, but in general is utilised reasonably well by commercial livestock farming and game reserves. Close to the Swaziland border there are some population concentrations including Piet Retief town, but pollution remains to be limited, localised and faecal in nature.

The Usutu River drains into Mozambique and thus international quality and quantity requirements must be met. The catchment of the Vegkop River is 161 km2, and yields a mean annual runoff of 21, 2 million m3 of water. The quaternary sub-catchment W51C yields a MAR of 89.4 X 106 m3 p.a. (Conversely: 678km2 x 903mm p.a. x 14.6% runoff factor).

The site Mean Annual Runoff (MAR) was (conservatively) calculated using estimated areas. The runoff percentages for the sub-catchment above the adit sites were described to be MAR = 0,876 m3 p.a. (That is: 6 ha x 903mm p.a. x 14.6% runoff factor). How big is the surface operational area and the Mean Annual Precipitation (MAP) i.e., the rainfall. The storm water is diverted around the operational area and the contaminated run-off water is contained within the operational area in pollution control dams.

Data has been used from various sources, including:

 Usutu Mhlatuze Water Management Area: Internal Strategic Perspective Report No. P WMA 06/000/00/03/04;  Surface Water Resources of South Africa : WRC Report No 298/6.1/94, 1990,  Shelly Colliery EMPR: Groundwater and Surface Water Quality Sections - Report compiled by I du Toit and L Marot of Groundwater Consulting Services cc, dated February 1998;  Water balance report by GFK Consulting Engineers for Kwasa Colliery, 2014;  Field work for geological and groundwater investigations at Goedehoop section.

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Water Management Areas

Kwasa Colliery

Figure 16: Water Management Areas

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Water Courses Drainage on the mine property is from south to north. The ridge crest behind the mine adits lies at an elevation of 2100 masl while the lowest areas in the north are at 1330masl. Because of the altitudinal range, the site is in a catchment area and a number of small perennial and seasonal first order streams flow off the high lying ground and then converge into two third order watercourses which flow from the mine property at its northern end. A short distance from the property they both merge into a large wetland and then continue as the Anysspruit. Typically, the watercourses appear to be in pristine or near-pristine condition at their higher elevations. The channels have a bedrock or boulder substrate and the sides are often vertically incised as a consequence of natural storm flow erosion. However, the systems then degrade as they flow downwards. At first the degradation originates from trampling of the channel banks by livestock which results in erosion of the banks and deposition of sediment in the stream bed. Thus the channel changes from a square or rectangular section to a “V” shaped section. The indigenous woody vegetation which was dominated by species such as Diospiros lyciodes, Dias cotonifolia, Buddleja salvifolia, Buddlija auriculata, Leucosidea sericea, and Rhus montana is lost and, in places, alien species such as Acacia mearnsii come to predominate. This process becomes progressively worse as the lower areas are approached. The channels widen and in many places the fringing vegetation loses almost all of the fringing vegetation of sedges and grasses. In a few places where cattle are excluded the channel recovers its natural shape and the vegetation persists. These areas are usually alongside old crop fields. The eastern stream has in its lowest sections had an earth berm built along the crest of the left bank. It is assumed that this is a measure to confine storm flows to the channel and so to keep the drained wetland there in a dry condition. Once the watercourses have left the property, they are soon diverted into drainage canals through wetlands which have presumably be drained for agricultural purposes.

Water quality was measures at four sites in the vicinity of the mine adits and the results of the analyses are shown in Table 19 below. NOTE: The stream below the central adit was dry and so no readings could be taken there.

uKhozi: KPS600/0216 Page 72 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga Table 17: Water chemistry readings from four streams

The water quality in the upper Usutu catchment is excellent, which is why Eskom source their water for the cooling of coal-powered power stations from this catchment. However, there is a huge risk of coal mining activities polluting the resource and this risk must be carefully managed through the formulation of pro- active catchment management plans.

During the public participation process some farmers indicated that they have lost livestock that drank the water of the stream flowing down gradient of the Kwasa Colliery into the Annysspruit. Currently no water monitoring is taking place at Kwasa Colliery. It is recommended that a water monitoring program is set in place as soon as possible in order to establish the baseline water quality of the downstream water resources.

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Figure 17: Layout of the mine property showing the proposed infrastructure in relation to the water courses

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Impacts on the surface water resources

Figure 18: Rivers in close proximity to Kwasa Colliery

Annysspruit The point of origin of a tributary of the Annysspruit is situated on the southern side of the mining right area. The origin of the stream is situated at approximately 1828m amsl which is approximately 360mamsl higher in relation to the centre of the operational area (Please refer to the elevation profile below). The risk of contamination is possible as the stream flows in close proximity of the proposed mining operation. Monitoring of this stream will be done in order to determine if contamination occurs, which will lead to better and more efficient pollution control measures.

Vegkop River

uKhozi: KPS600/0216 Page 75 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga The point of origin of a tributary of the Vegkop River is situated approximately 2.8 km southwest of the mining right area. The origin of the stream is situated at approximately 1684mamsl which is approximately 200mamsl higher in relation to the centre of the operational area (Please refer to the elevation profile below). The risk of contamination is possible but not likely, as the drainage line of the said river flows parallel to the proposed area approximately 1.8km west of the proposed mining right area. Monitoring of this stream will be done in order to determine if contamination occurs, which will lead to better and more efficient pollution control measures.

Boesmansspruit The point of origin of a tributary of the Boesmansspruit is situated approximately 4.8 km south east of the mining right area. The origin of the stream is situated at approximately 1519mamsl which is approximately 35mamsl higher in relation to the centre of the operational area (Please refer to the elevation profile below). The risk of contamination is possible but not likely, as the drainage line of the said river flows parallel to the proposed area approximately 3km east of the proposed mining right area. Monitoring of this stream will be done in order to determine if contamination occurs, which will lead to better and more efficient pollution control measures.

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Figure 19: The five streams with its 100m buffer zone in relation to the operational areas of the proposed colliery  The blue indicates the extent of the 100m buffer zones from the five streams that could be affected by the proposed operation.  It must be noted that according to the farmers only the stream on the eastern side of the mining right area is still flowing. During the site visits to the area this was confirmed.  The red line shows the mining right area.  The circle in the middle shows the extent of the operational area including the washing plant, ROM and product stockpile, Co-Disposal dump site and PCD 3.  The two smaller circles to the left and right of the operational area shows the extent of the west and east adit respectively along with the PCDs.  The small black circle at the entrance of the colliery shows the extent of the product stockpile along with its PCD.

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Dams Four dams were located on the property. Three are situated on wetland areas on the ridge above the mining areas while the fourth is an off-channel storage facility that is not on a natural drainage line. The centre points and approximate areas of the three are shown in Table 20.

Table 18: Centre points and areas of the four dams found on the property

From the table it is apparent that the storage capacity of the dams is small. Two, at least will not be affected by the mining operations since they are situated high above the mine adits.

Wetlands The NFEPA database shows no natural wetlands within 500m of the study area. The features that are shown in the general area are all dams or ponds and are classified as “Artificial” (refer to Figure 21). However the landowners have pointed out wetlands found to the north of the site. These were also noted during a site visit conducted on the 8th of December 2014 (refer to the photographs below).

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Photo Plate 9: Wetland area at the north end of the property

A wetland delineation study was done by Terratest (Pty) Ltd in January 2016. The below section is an abstract of the study done by Terratest (refer to Appendix F.2 for the full report).

It was recognised at the outset that the study could potentially be hampered because, despite being undertaken in the rainy season, the site surveys had to be done under drought conditions. The implication of this were as follows:  Wetlands and wetland-related features would be at their most inconspicuous. To deal with this issue use was made of Google Earth imagery taken at wet times of the year.

However, once in the field, it was possible to find traces of the wetland vegetation even if it could not be identified to species level. Soils, although dry and hard in some places, could be augered at others, and so could be used as a marker. Thus, although comprehensive biodiversity surveys were not possible, the presence of some wetlands could be detected. Figure 21 shows the wetlands on the property but it must be noted that not all were delineated in accordance with the DWAF (2005) Guidelines. Those indicated as “Extant” were delineated correctly in as far as the very dry survey conditions would allow. Use was made of a soil auger in places where the ground was soft (damp) enough and the presence of hygrophilous vegetation could be detected even if the plants were dry and brown. A wetland delineation will be done uKhozi: KPS600/0216 Page 79 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga by Terratest and if it is confirmed that the wetland is within 500m of the planned product stockpile area at the entrance of the colliery then this stockpile can be moved further south towards the operational area.

Photo Plate 10: Drainage ditch in Wetland

Photo Plate 11: Extinct wetland. The drainage ditch and a soil berm are visible. The area to the right has lost its wetland vegetation and was cultivated in the past

The exceptions to this procedure were those wetlands located in the high lying areas at the south of the property. They were seen and their presence can be confirmed, but they were delineated from Google imagery. The omission was deliberate as they uKhozi: KPS600/0216 Page 80 of 218

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Those wetlands that are indicated as “Extinct” are those that are so severely damaged that they now offer virtually no wetland ecosystem services to the landscape. They were delineated on the basis of terrain conditions and on historic Google imagery. However, because very little or no trace of these systems remains, it is probable that the areas indicated are not indicative of all systems lost and that there were others that have not been detected. The losses are primarily as a result of deliberate drainage and conversion to crop lands. In places the drains and/or soil berms are still clearly visible and their dendritic pattern leading toward streams is apparent. Elsewhere, at higher elevations and on steeper terrain, the wetlands have been damaged by erosion. Because of the characteristics of the sites, the causative agent is thought to be excessive trampling by cattle or other livestock. The animals would have been drawn to the wetlands for the greener vegetation available in dry seasons and also for the water there. The damage done to the vegetation led to establishment of preferential drainage runnels and, in time, these eroded and expanded to the point where they became, in effect, drainage ditches which removed the water from the wetland. This form of wetland loss is probably the most widespread incidental cause of wetland loss in the grassland areas of South Africa.

It had been intended to model the Present Ecological State (PES) of the wetlands by means of the WET-Health Model (Macfarlane et al, 2008) but since there is so much uncertainty about the original extent of the wetlands, the outputs would be grossly inaccurate and possibly misleading. Therefore, on the basis of expert opinion the large wetland system at the north end of the property is subjectively considered to be a PES Category E site in accordance with the criteria defined in Figure 20.

Figure 20: Health categories used for describing the Present Ecological State (PES) of wetlands. From Macfarlane et al, 2008.

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Figure 21: Kwasa Colliery Proximity to Registered Wetlands

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Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga Water Authority The Department of Water and Sanitation, (Usuthu Catchment) is the commenting authority for this area.

Resource class and river health The reserve determination for the W51C quaternary catchment was not available. The Department of Water Affairs did not respond to uKhozi’s telephone or email requests for the reserve determination.

Water Uses and Requirements Water Uses The use of water for the various listed purposes is one of the water uses regulated in terms of the NWA. Water uses can take many forms and – especially in the case of coal-mining and associated activities, there can be a direct impact on the water resource if the impacts are not effectively mitigated. These uses need to be aligned with the needs of the ecological Reserve and other downstream users. A central philosophy is that current and future opportunities should not be unreasonably and unnecessarily denied to users, and that the implementation of policy should ensure that disadvantaged and poor people should also be able to avail themselves of opportunities. The following uses of surface water have been identified:  Domestic - potable,  Aquatic ecosystems,  Mine process water make-up (possible), and  Agricultural - stock-watering.

As per Figure 22 below only a portion of the Usutu to Mhlathuze WMA’s resources are undeveloped. This area further is one of the higher quantities of water being used by alien species. The surface water associated with the mining area is mainly used for stock watering, aquatic eco-systems, and also for human (potable) requirements.

Water Requirements As indicated in Figure 22 the most dominant land uses within the Usutu to Mhlathuze WMA (As per DWA’s Situation Assessment of 2003), is Agriculture and Afforestation. As indicated in Figure 23 the industry using the greatest amount of water (As per DWA’s Situation Assessment of 2003), is Transfers out, with Agriculture with the second most water requirements allocated to irrigation within the Usutu to Mhlathuze WMA. Very little water is allocated to the mining industry.

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Figure 22: Land Uses in the Usutu to Mhlathuze WM

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Figure 23: Sectorial Water Requirements (Usutu to Mhlathuze)

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5.3.10 Groundwater (Aquifer description) The mining area is mainly located across the mountain area; however the adit complex is located on a terrace in a lower down the hill-slope. Although these two different areas are interlinked, they are very different in terms of the aquifer description. The groundwater will be assessed in detail by GCS during the Hydrogeological and Geochemical study which is currently underway.

Lower hill-slopes topographical areas According to a hydrogeological study done by GCS in 2009 for the area directly west of Kwasa Colliery, the lower hill-slopes topographical areas have two principle aquifers . These are the following:

 A weathered aquifer occurring at a depth from 2 to 15 metres.  A fractured Karoo aquifer occurring at depths below 15 metres.

Mountain topographical areas As per the above referenced report it is assessed that a perched aquifer system occurs above the dolerite sills and that more than one unconfined / semi-confined aquifer system occurs above the regional aquifer system that is associated with the lower topographical system. Figure 24 below depicts a schematic representation of the aquifer systems.

Figure 24: Schematic representation of the different aquifer systems (GCS, 2009) Depth to water table The water table at the proposed site is estimated to be 15 m beneath the surface. It should however be noted that is based on the experience of groundwater specialists in the area and not based on any specific findings.

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Hydro census (Presence of water boreholes and springs) The mountain area has various fountains and springs. During a field investigation conducted by GCS it was found that water (which recharges the mountain aquifer systems) eventually daylights as fountains along exposed contact zones and depressions within the overburden material.

Groundwater quality The groundwater quality at Kwasa Colliery is not currently being monitored. It is recommended that a monitoring program is put in place as soon as possible in order to establish a groundwater quality database.

Reserve Determination The following groundwater specific preliminary resource quality objectives are proposed based on the level of understanding aquifer systems and land-use activities in the Usutu to Mhlathuze WMA:

 Maintain groundwater levels and the groundwater gradients with specific reference to maintaining the groundwater contribution to base flow. Implement a groundwater level monitoring programme and specifically monitor the quantity and quality of groundwater.  Continuously assess the potential impacts of the development activities, and associated land-use activities, on the quality of the groundwater resources. Implement a periodic groundwater quality sampling programme prior to and during development operations.

Groundwater use The groundwater is mainly used for livestock watering (from fountains and springs) with a limited use for domestic supply.

Both the shallow groundwater base-flow in the region of the lower topographical hill- slopes, together with spring water seeping from the higher topographical areas feed the streams with water. This is considered to be a critical water supply to the local farms and communities, especially in the dry, winter months.

The mine will recycle and re-use groundwater from the underground workings for make-up process water, and water from the fresh water dam for potable water, and possibly also for makeup water during the dry, winter months. 5.3.11 Sensitive Areas uKhozi: KPS600/0216 Page 87 of 218

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The abandoned Kwasa Colliery falls inside the Wakkerstroom Wetlands Grassland proposed exclusion area in terms of Section 49 of the MPRDA (refer to Figure 25 below). A motivation was submitted to the Minister to include 120 farms, of which Goedehoop 169 HT is one, inside the exclusion area to prevent further prospecting or mining activities on these farms.

The following primary reason was given to include these farms in the Wakkerstroom Wet Grassland area: “The primary basis for the consideration of the WWG under Section 49 of the MPRDA is the exceptionally high biodiversity value of the area that provide valuable ecosystem services to the people of South Africa.

The map (found in the document mentioned above) below shows the extent of the Wakkerstroom Wet Grassland proposed exclusion area as well as the area that is still under application to become part of exclusion area. From this map it is clear that the abandoned Kwasa Colliery falls inside the area that is still under application.

The Annysspruit along with other small tributaries flowing in close proximity of the Kwasa Colliery is also considered sensitive areas and the current pollution that is occurring, especially during the rainy season, must be stopped through the establishment of a pollution control system at the mine. These pollution control structures must be established as soon as possible, preferably before the rainy season start to avoid further contamination of the water resources downstream.

The wetland north of Kwasa Colliery’s entrance is considered a sensitive area (refer to Photos 9 and 10 above). According to the landowners there are various different species of waterfowl (spur winged geese, Egyptian geese, crowned cranes, blue cranes) relying on this wetland. The product stockpile area at the entrance of the colliery can be moved further south to decrease the chance of contaminated water ending up in this wetland during storm events. The construction of the in stream fresh water storage dam will lead to the reduction of storm water runoff into this wetland. The fresh water dam must be constructed with an outlet in order to let water back into the downstream water resources.

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Goedehoop 169 HT

Figure 25: The Wakkerstroom Wet Grasslands (WWG) proposed exclusion area (233, 393 ha) extending over 120 farms within the Pixley Ka Seme and Mkhondo Local Municipalities

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5.3.12 Noise Noise in the area is restricted to routine traffic to and from the surrounding farms and adjacent mining operations conducted by Kiepersol Colliery. Agricultural activities such as the cultivation of lands and harvesting of crops along with forestry activities also contribute a low scale source of noise to the ambient level.

Potential receptors which might be affected by the mining operation are the local residents of the neighbouring farms and farm workers. The residential areas are not located in vicinity of the mining activities and they are thus too far removed to be regarded as a receptor.

5.3.13 Visual The site is visible from the R543 (Piet Retief – Wakkerstroom) district road, lying some twelve kilometres to the north of the site. The area already has a mining character due to the state the environment was left in. The un-rehabilitated Kwasa Colliery and the Kiepersol Colliery have already altered the visual character of the Mhlangamvula and Mhlanganpisi Mountains, especially when looking at the mountains from the north and west. However the size of the disturbed area at the Kwasa Colliery is very small compared to the disturbed area at Kiepersol Colliery directly to the west. The access road to the defunct operational area is visible from the Kiepersol road. The visual aspect of the areas that have not been disturbed by mining can be described as wilderness with pockets of forestry.

The visual receptors that will mostly be affected are these within a 5 km distance from the site and include two farmhouses (Mr Trebble and Mr Prigge) as well as various rural dwellings north of the colliery.

Tourism Context The broader area (50 km radius from the site) includes two small nature reserves and the small tourism hub of Wakkerstroom. The Paardeplaats Nature Reserve, situated approximately 13 km south of the proposed site, is 2000 ha in extent. The Pongola Bush Nature Reserve (18 km south) is characterised by mixed Yellowwood forest with high altitude grassland. Both Reserves attract birding and nature enthusiasts and remain important protected areas for biodiversity. A number of river systems and dams in the area attract tourism in the form of fishing and birding.

Wakkerstroom, a small town situated 48 km southwest of the proposed site, is a focus of tourism in the area, and due to the significance of the Wakkerstroom river uKhozi: KPS600/0216 Page 90 of 218

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Tourism in and around Piet Retief is dominated by guesthouse facilities and conservancies, including private reserve developments in the Ngwempisi and Assegai River Valley and catchments (Mkhondo IDP, 2015). The Kwamandlangampisi Mountains and the high grassland escarpment hold high biodiversity and scenic value, although their true tourism potential has not yet been realised (Mkhondo IDP, 2015).

Existing Piet Retief Context Piet Retief (eMkhondo) is located on the N2 at the intersection of the R543 (Volksrust- Swaziland) and R33 (Vryheid-Amsterdam) roads. The surrounding area is dominated by forestry plantations, from which much of its economy originated. At present it boasts a well-diversified economy, including components from all sectors, from manufacturing to personal services, real estate and tourism. It is strategically situated in respect of rail and road freight transport (Mkhondo IDP, 2015), and is the main link of both industrial and commercial transport from Gauteng to the import/export harbour at Richards Bay.

Situated on the outskirts of Piet Retief (eMkhondo) is the town of eThandakukhanya, which remains largely a dormitory town and is economically dependent on Piet Retief and the surrounding forestry and rural areas (Mkhondo IDP, 2015).

Existing Surrounding Area Context Local Area (<5 km from proposed site) The immediate area surrounding the proposed site (5 km radius) is characterised by farming and mining activities. The operational Kiepersol Colliery is situated 1.5 km to the west and the proposed Goedehoop Colliery is situated 1.8km to the east, along the lower slopes of the Kwamandlangampisi Mountain. Further north (5.3km), the defunct Protea Colliery is located. The nearest households are situated 2.19km north east from the proposed site. Further north, east, and northeast scattered clusters of rural community households can be found located both on community and private farm land.

Natural springs are located to the north and east of the proposed site, with the resulting streams servicing the farmhouse to the north east as well as the surrounding rural community. uKhozi: KPS600/0216 Page 91 of 218

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Broader Area (>5 km but <50 km from the proposed site) The nearest formal urban centres are Dirkiesdorp (18 km west), Piet Retief (eMkhondo) (27 km northeast), Paulpietersburg (38 km southeast), and Wakkerstroom (48 km southwest), and the formal rural centre of Driefontein situated 21.2 km northwest of the proposed site. The surrounding 50 km area is predominantly characterised by agricultural activities, with some mining, conservation, and industrial activities occurring.

The nearest large dams are Savmore Dam (7.2 km northwest) and Heyshope Dam (14 km northwest), with the Assegai River running 17 km north of the proposed site at its closest point. The general area is characterised by informal roads, many of which are not tarred, with the closest main roads being the R543 and R33. The main R543 road is located 10 km to the north of the proposed site, and the R33 road is situated 28 km to the east. The small German community and school of Wittenberg is located 22 km east of the proposed site, and remains the closest large education facility to the site. Outside of the main formal urban and rural centres, housing is limited to established farm households and infrastructure, and rural community households scattered on a combination of private and community lands.

5.3.14 Socio Economic Environment The area for the proposed mine falls within Ward 7 of the Mkhondo Local Municipality which forms part of the greater Gert Sibande District Municipality. Figure 26 below shows the population per ward for the Mkhondo Local Municipality.

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Figure 26: Population per Ward

Demographic and Socio Economic Profile Based on the figure above the Mkhondo Municipality has an estimated population of 106 452 people. It is estimated that about 54% of this population reside in the rural parts of the Mkhondo municipality, and about 46% in the urban parts.

Based on the Mkhondo Local Municipality Draft IDP (2011-2016) the 106 457 people residing in the Mkhondo Municipality represent about 29 927 households at an average household size of 3, 6. An estimated 36% of the population is in the age bracket 25-65. The percentage male residents in the municipality decreased slightly from 2001, while the number of residents with tertiary qualifications (diplomas and degrees) increased significantly which is positive. The percentage of the population with no schooling background also reduced drastically since 2001.

Unemployment figures are relatively high at 43%, but it did show a 3% reduction from 2001. The average annual income per individual increased by almost 150% to R1281, 54, but is still very low in national context. The number of households residing in formal houses increased to about 67% (from 33% in 2001).

Households having access to electricity more than doubled during this period, with an estimated 69% of all households having access to electricity. Households with sanitation services below RDP level decreased from 61% to 41% (pit latrines, bucket latrines and no systems). The number of households with access to piped water inside the dwelling/yard also increased drastically from 10 795 in 2001 to 20 169 in 2007 which represents about 67% of all households in the area. uKhozi: KPS600/0216 Page 93 of 218

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In terms of Gross Geographical Product the two most important employment sectors are agriculture at 36% and community services at 18%. These sectors are followed by trade at 13% and manufacturing at 12%. It evidences that the economy is not very diversified still being highly reliant on the agricultural sector.

The above reinforces the fact that forestry is and will remain an important asset in the region. There is little down-stream economic activity and much of the raw timber is exported from the region, which is negative as value-adding opportunities and increased income for the region are lost. Reliance on the community services sector is also high, and thus indicative of the social needs provision in the region.

Although the area has a large economically active population (56%), a total of 43% of the economically active population is unemployed. This indicates that the economy is unable to accommodate these people, which will either lead to the out migration of youngsters and/or an increase in domestic poverty.

Transport Network The N2 is the only national road which traverses the area. It is an important tourist and freight transport route connecting Gauteng with the KwaZulu Natal north coast and Richards Bay. Though a national road, the road needs to be upgraded and maintained, given its important connecting role. Three provincial roads traverse the area. These include:

 R33 from the N17 in the north, through Amsterdam and Piet Retief to Vryheid in the south;  R65 between Ermelo and Swaziland via Amsterdam.  R543 between Swaziland and Volksrust via Piet Retief.

All these roads are tarred but in fairly poor condition and therefore need to be upgraded and maintained. The local roads in the area are tarred, gravelled or graded. All need maintenance, especially in the rainy season. The R543 is the road that will be used to the Kwasa Colliery.

A freight railway service exists leading from Ermelo in the north to the north coast in the south via Vryheid.

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Social Infrastructure There are several primary schools distributed widely throughout the area. These are not only centred in the urban areas, but generally also cover the rural areas, which is appropriate given the high percentage of rural based people residing in the Mkhondo area. There are 15 secondary schools in the municipal area which are located and scattered across the wards, however as the population grows the need for more arises. There is also a Mondi Science and Career Guidance centre which assists in career guidance and youth development for the community of Mkhondo at large.

There is only one hospital in the municipal area which is located in Piet Retief. In addition, there are 10 other health facilities which are mainly clinics. Of these, three of the facilities are located in Piet Retief and the other seven are distributed in the area. There are two Alcohol and Drugs Rehabilitation centres, two old age homes, two disabled centres and two orphanages. There is a need for more health facilities in the area to achieve easier access to basic health and family planning services – especially in the rural areas.

There are also four police stations and three post offices in the Mkhondo municipal area.

Water Provision Sixty nine percent of households within the Mkhondo municipal area have direct access to clean reticulated water either in-house or on site. The remaining 31% of the population obtains water from streams, rivers or boreholes. According to the IDP the municipality is in a process of addressing the water provision backlog, together with the lack in sanitation services, to avoid serious environmental and health risks.

Sanitation Services Sanitation services differ substantially throughout the area. Most of the newer urban areas have access to full sanitation reticulation e.g. Piet Retief, eThandakukhanya and Amsterdam ext 2 and 3, while the older urban areas still rely on septic tanks. A large percentage of the population (49%) (urban and rural) in the municipal area still rely on pit latrines, or chemical toilets, while 21% have no access to sanitation in their households. The latter figures indicate possible environmental pollution problems and increased health risks. Sanitation services need to be upgraded in 13 wards excluding ward 7 and ward 12.

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Electricity Slightly over 50% of households in urban areas obtain electricity from the MLM; the remainder of the urban areas rely on candles for lighting and paraffin, gas and other sources for energy. ESKOM supplies electricity to the rural areas.

The municipal areas with the largest concentrations of service backlogs are recorded around Piet Retief / eThandakukhanya, Amsterdam / kwaThandeka, and Driefontein / kwaNgema.

5.3.15 Heritage Since the area under application was found disturbed by previous mining activities and left un-rehabilitated, there are no historical features, structures or artefacts of significant historical importance that could remain within the surface operational area. It should however be noted that no heritage or social assessment had been conducted and therefore no definite description regarding the historical elements can be described. A first phase heritage assessment is currently being conducted by eThembeni Cultural Heritage and the information from this study will be included in the final EIA/EMPr.

No social assessment had been completed for the area and the current state of the cultural resources cannot be described.

Specific environmental features occurring on site which may require protection, remediation, management or avoidance

The proposed operational area has no sensitive environmental features remaining, that could require protection or avoidance since the area had previously been disturbed by mining activities. However during heavy rainfall events the coal waste lying around on site flows into the downstream water resources. A detailed Storm Water Management Plan needs to be designed in order to contain the source of pollution. Once this source is contained programs can be set in place to rehabilitate the contaminated water resources downstream of the mine.

The following specific areas in close proximity to the colliery requires protection, remediation, management and/or avoidance:

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The Wakkerstroom Wet Grassland proposed exclusion area. This area must be avoided at all cost.

The Annysspruit along with other small tributaries flowing in close proximity of the Kwasa Colliery. These areas must be managed but separating the clean water from the dirty water through the construction of berms and trenches. The dirty water must be contained in Pollution Control Dams and the clean water allowed to enter the downstream streams/rivers. These pollution control structures must be established as soon as possible, preferably before the rainy season start to avoid further contamination of the water resources downstream.

The wetland north of Kwasa Colliery’s entrance. In order to protect this area the proposed product stockpile area at the entrance of the colliery can be moved further south to decrease the chance of contaminated water ending up in this wetland during storm events. The following management measures will also apply:

 Maintain the 0.8 m freeboard at the pollution control dam;  Regular inspection of the PCDs and silt traps;  Line the PCD with appropriate lining (HDPA (2mm) and clay on top).

The construction of the in stream fresh water storage dam will lead to the reduction of storm water runoff into this wetland. This could cause the wetland to become dry. This must be managed by constructing the fresh water dam with an outlet in order to let water back into the downstream water resources once it is filled to capacity.

A description is given below of the environment likely to be affected by proposed mining operations:

The mountain stream is a sensitive environment, as are the areas of indigenous vegetation and the wetlands.

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6 Environmental Impact Assessment In order to conduct this assessment, the activities need to be described. Please refer to Section 2.4 of this report for the physical project description.

Mine Risk Assessment

Table 19: Primary hazard class type if mineral mined Primary Hazard Class Large Mine Small Mine Size: Mine, Mine, Large if Mine Mine Mine Mineral Ore Mine & > than and Waste, Waste, Mine (tpm) Mine Plant & Plant & Waste Waste plant plant Waste Waste Prospecting (All C C C C Minerals) Antimony 1000 A A C C Asbestos 0 A A A A

Sulphide 10 000 A A C A Base metals (Copper, Cadmium, Cobalt, Iron ore, Molybdenum, Nickel, Tin, Vanadium) Oxide 10 000 C A C A

Coal 0 A A A A Chrome 10 000 C A C C Diamonds & Precious 10 000 C B C C stones Gold, Silver, Uranium 10 000 A A A A Phosphate 10 000 C B C C Platinum 10 000 C B C B Magnesium 10 000 C B C C Manganese 10 000 C B C C Mineral sands (Ilmenite, Titanium, 10 000 C B C C Rutile, Zircon & Lead) Zinc & Lead 10 000 C A C A

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Industrial Minerals (Andalusite, Barite, 10 000 C C C C Bauxite, Cryolite, Fluorspar)

Kwasa Colliery is classified as a Category A mine. Please refer to Table 22 for classification of mines.

Table 20: Classification of Mines CATEGORY A CATEGORY B CATEGORY C  Any gold or coal mine;  Any mine where  All other mines not  Any mine with an significant impacts may covered by A or B. extraction metallurgical occur on water quality process, including heap or quantity of affected leaching; or water;  Any mine where sulphate producing or acid generating material occurs in the mineral deposit

The Definition of Significance in the context of this EIA

Judgement on the significance of an impact has been influenced by both the context and intensity of the impact. The nature, cause and effect are also described.

The level of significance has been determined for the EIA below (section 6.3), as the combined result of a number of several factors, four of which are summarised in a table describing each criterion on an individual basis. A fifth criterion namely “risk” has been included in the description of groundwater impact assessment. An example of such a summary table is given below:

Table 21: Example of Natural Vegetation (Summarised Impact) Context Intensity Implication Level of Magnitude/Extent Timing Duration Probability Risk Significance Small Present Temporary Definite Low Low

The first three, namely magnitude, timing and duration describe the context of the uKhozi: KPS600/0216 Page 99 of 218

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6.2.1 Context Context comprises both spatial and temporal dimensions.

6.2.2 Spatial Implies magnitude, extent and/or size. How big is the impact?

Impacts on the environment have been described according to their relative magnitude (or size or extent). For example, topsoil may be totally affected but in a localised, contained area by a construction or excavation, which is a relatively small fraction of the greater area. In contrast, sheet and/or donga erosion over a more general area may not have totally removed all the topsoil (yet), but the scale of significance of the effect is relatively more severe.

6.2.3 Temporal Implies timing and duration. When will it happen, and how long will it last?

Timing Timing indicates when the effect will happen (manifest itself) namely:

 Past (already happened)  Present and/or  Future (on-going).

Duration Duration describes how long an impact will last on a project specific basis and includes five levels namely:

 Permanent: > 5 years after closure of the operation  Temporary, Long term: 5-10 years (duration of the project)  Temporary, Medium term: 2 - 5 years  Temporary, Short term: < 2 years  Reversible: If an impact is reversible, the predicted time frame becomes uKhozi: KPS600/0216 Page 100 of 218

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important.

6.2.4 Intensity Intensity indicates the severity of an impact. It is assessed on the basis of certainty (probability), special knowledge and/or perceptions of the Stakeholders.

6.2.5 Certainty Certainty (probability) of occurrence or fact has been assigned five levels or categories, namely:  Already happened: 100%  Definite: >90% of occurrence or fact  Probable: >70% of occurrence or fact  Possible: >40% of occurrence or fact, and  Unlikely: used also for the groundwater assessment to indicate that it is not anticipated (through scientific methods) to occur,  Unsure: <=40% of occurrence or fact.

6.2.6 Special knowledge Special knowledge recognises local, traditional knowledge of the environment being assessed, and/or experience of local people and/or interested parties.

6.2.7 Perceptions The perceptions, priorities, concerns and/or needs framework of the interested and affected parties (IAP’s) and the relevant Authorities.

6.2.8 Levels of Significance Five resultant levels of significance have been described on the basis of the magnitude, timing, duration and probability of an aspect, namely:

 “very low”,  “low”,  “moderate”,  “high”, and  “very high”.

This has been summarised below in Table 25: The Significance Rating Scale.

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6.2.9 Implications of the Significance Rating Scale Various implications of the significance scale have been summarised below in Table 25: Implications of the significance rating scale. The scale is described as five levels along a continuum. The order is described relative to within the bounds of impacts which could occur. The significance rating scale could be replaced by one of the following categories where relevant, namely:

 “No effect” implies that there is not even the lowest order (very low / negligible) impact on either the key issue or a component thereof.  “Can’t know” indicates that the impact assessor believes that, even with additional information, an assessment is not possible, and finally  “Don’t know” accommodates the situation where the assessor cannot, or is unwilling to make an assessment.

6.2.10 Summary of the Significance Rating Matrix The various criteria that need to be considered when assessing the significance of the aspect and its impact have been summarised below in Table 24. Please note: In Table 25 (Implications of the Significance Rating Scale) the rating scale is relative to within the bounds of impacts which would occur.

Table 22: The Significance Rating Scale Intensity Level of Magnitude Timing Duration Probability Risk significance How serious is Severity, certainty of it? How big is it? When will it How long will it happening or fact / +’ve / –‘ve (Relative to what?) happen? last? perception Actual/Potenti al Unlikely: < = 40% Negligible (to the Past Reversible (? Yr.) not Very low Very low project area) predicted to occur Small (limited to Temporary: S/T Possible: part of the project Present Low Low <2 years. >40% area) Future: S/T Moderate (limited to Temporary: M/T Probable: (<6 Moderate Moderate the project area) 2 – 5 years >70% months)

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Intensity Level of Magnitude Timing Duration Probability Risk significance Definite: High Large (extends Future: M/T Temporary: L/T >90% beyond the project 6 months – 5-10 years. Already High area: contained) 5 years Project duration happened High 100%

Extensive (extends Permanent: >5 Future: L/T beyond the project yr. after mine Unsure High Very high (>5 years) area: un-contained) closure

Table 23: Implications of the Significance Rating Scale Impact Level Order Negative (Alternatives) Positive (Alternatives)

Virtually unnecessary; easy, Generally better than means of Very low Negligible cheap, simple achieving the benefit.

Easily achieved and / or little Easier, cheaper, more effective Low Little real effect required and / or less timeous.

Not substantial, Feasible and fairly easily Moderate Equal in time, cost and effort. but real possible

Feasible, difficult, expensive, Feasible, difficult, expensive High Substantial or time consuming and / or time consuming.

Very high Highest Not possible Nothing practicable

The main aspects that will have an impact on the environment have been categorised below in Table 26. A description of each aspect is given along with the specific activities, phase of the operation in which it will occur, and the duration. The specific listed activities in terms of NEMA (GG No. R544 or GG No.R543) that are triggered by each aspect is also indicated below. The impacts of these activities on the environment were assessed in section 6.3 for the construction, operation and decommissioning phases of the proposed mine.

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Table 24: Categorization of the main activities in terms of the aspects of the operation Aspect Listed Activity in terms Activities Phases of Timeframe

of NEMA operation

Underground  GG No. R543 Activity nr 5  Board and pillar mining with Construction, 5 years  GG No. R543 Activity nr continuous miner (no blasting will mining Operational, 20. be done);  Dewatering of the aquifer and groundwater recharge in mine workings;

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Transport  GG No. R543 Activity nr 6;  Upgrading and construction of the Construction, Daily for 5 years  GG No. R543 Activity nr 5; internal road network; Operational  GG No. R544 Activity nr  Expansion of five low level 39. crossings;  Transportation of coal will be done via a conveyor belt from the shaft to the washing plant;  After crushing and screening, product will be transported to the stockpile area;  Product will be loaded onto trucks with front-end loaders and transported via road to the market(s).  No workers or contractors will be staying on the mine; these labourers will be transported daily to and from the site.  All equipment will be brought onto and again taken off the mine via the existing access road network.  It is not expected that roads will be constructed to access the operations. The existing road and track network will be utilised as far as possible.

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Aspect Listed Activity in terms Activities Phases of Timeframe

of NEMA operation

Washing of  GG No. R543 Activity nr 5;  Establishment of the coal washing Construction, 5 years  GG No. R544 Activity nr plant along with associated coal Operational. 23; infrastructure;  GG No. R544 Activity nr  Coal washing; 11.  Recycling of process water from PCD 3;  Disposal of waste water in the PCDs;  Disposal of discard at the Co- Disposal Dump site.

Stockpiling and  GG No. R543 Activity nr 5.  Product stockpiling in two areas – Operational 5 years.  GG No. R543 Activity nr at the plant and at the entrance; Loading 15.  ROM stockpiling at the washing plant.

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Water  GG No. R544 Activity nr 9;  Construction of four pollution Construction, 5 years  GG No. R544 Activity nr control dams; Management Operational 12;  Construction of one fresh water  GG No. R544 Activity nr dam; 18;  Construction of final trenching  GG No. R543 Activity nr 5. and berms;  Establish new runoff water catchment areas;  Installation of water pumps and piping for PCD 3 and the fresh water dam;  Storing of waste water in PCD 1, 2, and 4.  Recycling transformed water from PCD 3 to use as process water in the washing plant.  Taking water from the freshwater dam to use as process water in the washing plant and for dust suppression during dry winter months.  Spraying of water on access roads, stockpiles and the Co-Disposal Dump Site to suppress dust.  Underground water will be abstracted from the adits and pumped into the pollution control dams. uKhozi: KPS600/0216 Page 107 of 218

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Aspect Listed Activity in terms Activities Phases of Timeframe

of NEMA operation

Fuel Storage  GG No. R544 Activity nr  Storing diesel on site in containers Operational. 5 years 12. that can hold more than 80m3 combined but less than 500m3. Dust  GG No. R543 Activity nr 5.  Water will be obtained from PCD Construction, 6 years 1, PCD 2, PCD 4 and the fresh suppression Operational, water dam via water carts and sprayed on the roads and Decommissioning operational areas for dust suppression;

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Aspect Listed Activity in terms Activities Phases of Timeframe

of NEMA operation

Waste  GG No. R543 Activity nr  Preparation of the Co-Disposal Construction, 6-7 years. Dump Site; management 15; Operational,  Discard will be disposed in the  GG No. R543 Activity nr 5. Co-Disposal Dump site from Decommissioning where it will be sold or disposed and Closure of at a registered site.  Waste water will be disposed of in PCD 1, PCD 2 and PCD 4.  A septic tank system will be installed on site;  Sewage from mine workers will be contained in the septic tank system.  There will be no industrial waste disposal on the site; such waste will be removed by specialist contractors.

Plugging and N/A  Plugging and sealing of three Decommissioning 3 months shaft i.e. ventilation, access and sealing of exit shaft). shafts.

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Aspect Listed Activity in terms Activities Phases of Timeframe

of NEMA operation

Removal of N/A  All infrastructure such as the Decommissioning 3 months washing plant, offices, change infrastructure houses, pollution control dams, access roads etc. will be demolished and removed from the site.

Re-vegetation N/A  Once all infrastructures have been Closure 2 months removed from the site, disturbed areas will be re-vegetated in an attempt to re-instate the land use and land capability to its pre- mining state.

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Environmental Impact Assessment

6.3.1 Construction Phase Geology Impact The geology will be disturbed by drilling and blasting and the excavation of the new adits. The material excavated will either be used in the construction of the terraces or (the remainder) stockpiled for later use during decommissioning to refill the adit. The disturbance will be limited to a small part of the project area, it will be a permanent disturbance that will definitely happen.

The refurbishment and operation of Kwasa Colliery as well as the multiple mining operations in the area will have a cumulative impact on the geology of the area. Underground mining will have a definite long term impact, as the geology cannot be restored, on the local and regional geology of the area.

Summary of impacts on the geology Magnitude Timing Duration Probability Level of Significance

Small Future S/T Permanent Definite Moderate

Topography The topography will be altered by the excavation and terracing of the adits, the topsoil and rock stockpiles and the construction of the plant complex, discard facility and associated pollution control facilities. The disturbance will be limited to a relatively small part of the project area, it is reversible in the long term (>7 years) as the post mining topography will be landscaped to emulate the pre-mining topography and it will definitely happen.

The topography of the site will be affected by the planned activities which will require the possible opening of an additional adit(s). The Alfred and Dundas seams are planned to be mined using conventional underground board and pillar mining methods and it is therefore not expected to have an impact on the topography during the construction phase. The opening of any adit will however have an impact on the topography which is a steep sloped to gentle sloped landscape. Construction activities will involve the levelling of an area to accommodate the adit.

Various clean water diversion berms and a high wall will be created around the mining area to contain all dirty water that might be generated within the mining boundary. These berms as well as trenches will divert clean water away from the mining area into the surrounding streams. Channels will also be created to divert the dirty water into the pollution control uKhozi: KPS600/0216 Page 111 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga dams. These berms and dams will be constructed of in-situ material and will be limited to the immediate vicinity of the infrastructure areas, and will have a small but significant effect on the topography during the construction phase. The impacts will be limited to the site, with a definite impact for the short term. The intensity and significance will both be low.

Multiple mining operations in the area exists thus there will be a cumulative impact on the topography of the area in the long term as the tailings facilities are permanent features affecting the relief of the area.

Summary of impact on the topography Magnitude Timing Duration Probability Level of Significance

Small Future S/T Temporary L/T Definite Low

Soils Impact The planned additional mining activities as mentioned above will affect soil in the area as an additional adit and related structures will have to be constructed. The construction of the four PCDs, the fresh water storage dam, new roads and the Co-Disposal Dump site will have a significant impact on the soils because these structures will be constructed on undisturbed surfaces.

The soil in the areas to be disturbed that is suitable for use as a growth medium will be excavated (pre-stripped) and stockpiled for use during rehabilitation (decommissioning phase). The pre-stripping and stockpiling of the soil will result in both physical and chemical changes in the soil due to the disturbance, increased aeration and absence of vegetative cover. This action on the soil will result in a breakdown of the macro- and micro-soil structure, especially when excessively wet and with duplicate handling. As only the topsoil and subsoil will be stockpiled, the mixing of the soil from the lower horizons with the bed rock would alter the characteristics of the conglomerate as far as chemistry and water retention capacity is concerned. The stockpiled topsoil and subsoil will be exposed to contamination (such as coal dust, oils lubricants etc.) and erosion agents such as water and wind during the construction phase.

It must be taken into account that the area was left in an unrehabilitated state and currently erosion around the access road as well as in the mining area is a big concern for the local farmers.

During construction there is the probability of sheet erosion occurring on the areas cleared of vegetation. The extent of the cleared area is however relatively small and will only involve portions of the mining area. As these sites will be actively managed (or be covered by uKhozi: KPS600/0216 Page 112 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga temporary structures) the duration will be long term. The probability of gully erosion will be limited to the concentrated flow of collected water points or concentrated flow points (such as culverts) around the planned activities. However proper berm construction and erosion control measures will ensure that the intensity will be greatly reduced.

Summary of impact on the soils Magnitude Timing Duration Probability Level of Significance

Small Future S/T Temporary L/T Definite Moderate

Land Capability Land capability will be compromised in the vicinity of the operational areas that are planned to be pre-stripped of topsoil and growth medium material (for later re-use). The disturbance will be limited to a relatively small part of the project area.

Where the land capability is grazing or wilderness, the post mining capability will not be compromised and the impact is reversible in the long term (> 7 years) and will definitely happen. The land capability of the mining area will be compromised during the construction phase of the planned activities. This is mainly due to the intense impact that the construction activities will have on the soil and vegetation of the site.

It has however a low level of significance mainly due to damage caused by previous mining activities and the un-rehabilitated state that the land was found in.

Mining activities in the area will definitely have a cumulative impact as mining activities will reduce the original land capability in the area to a homogenous area defined by mining.

Summary of impact of on the land capability Magnitude Timing Duration Probability Level of Significance

Small Future S/T Temporary L/T Definite Low

Land Use The current land use of the defunct operational area will remain mining, while the area of the new adit complex, pollution control dams, co-disposal dump site, fresh water dam etc. would change from agriculture (grazing) to mining. The disturbance will be limited to a very small portion of the mining right area (less than fifty hectares), it is reversible in the long term (>7years) and will definitely happen.

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Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga The underground mining activities in the area will have a low cumulative impact in the medium term as the surface infrastructure is limited in extent.

Summary of impact on the land use Magnitude Timing Duration Probability Level of Significance

Small Future S/T Temporary L/T Definite Low

Vegetation Impact The terrestrial vegetation at the site consists of three types which are as follows:

 Eastern Highveld Grassland;  Paulpietersburg Moist Grassland;  Wakkerstroom Montane Grassland.

The first two of these are considered to be either “Endangered” or “Vulnerable” and so are of conservation concern. In addition, because of regional landscape transformation, the vegetation in the mine area is considered to be “Irreplaceable”. At present the vegetation in the intermediate (> 1370 masl) and higher lying areas is in good to pristine condition and alien weeds are not common. However, the vegetation in the lower-lying and flatter areas has been substantially transformed by past agricultural activities.

The construction activities will lead to considerable loss of indigenous vegetation on the property. The losses will come about through development of infrastructure, and also through general contamination of the area. Natural ecological processes will be disrupted and there is a strong probability that alien weed species such as Wattle (Acacia mearnsii) will become more prolific. These impacts will be most apparent at elevations below that of the mine adits while the higher lying areas will be relatively unaffected.

Summary of impact on the vegetation Magnitude Timing Duration Probability Level of Significance

Large Future S/T Permanent L/T Definite High

Animal Life The terrestrial fauna at the site is already very severely depleted with many of the original species, especially the larger mammals, now being locally extinct. However, with the further degradation of the area as a result of the mine development, further losses will take place. uKhozi: KPS600/0216 Page 114 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga Affected groups will include the mammals, birds, reptiles, amphibians, and a wide variety of invertebrate groups with the insects being the most obvious. Several species of conservation have already been lost from the area as a result of human activities. None were seen at the time of the site visit.

The disturbance and consequent habitat destruction will be limited to a relatively small part of the project area: it is estimated that the zone of influence would be temporary in the long term and will happen. The associated loss of habitat, disturbance in the area in terms of noise, dust and water pollution associated with mining activities will possibly have a negative cumulative impact on the fauna in the area in the long term.

Summary of impact on the animal life Magnitude Timing Duration Probability Level of Significance

Moderate Future S/T Permanent L/T Definite Moderate

Surface Water

 Potential Impact: Contamination of surface water through storm water runoff Rain falling onto the disturbed area is currently polluting the surrounding surface water resources.

Once construction starts and storm water measures are implemented this will help contain the source of pollution which will have a positive impact on the surrounding surface water resources. Spillage from chemical toilets, oil spills and construction dumping may be picked up by runoff and will contaminate the downstream watercourses.

Increased sediment movement off the construction sites will add to the cumulative impact of increased sediment loads in the valley bottom wetlands and streams down gradient of the site.

Summary of impact on the surface water quality Magnitude Timing Duration Probability Level of Significance

Large Future S/T Temporary S/T Possible Moderate

 Potential Impact: There will be temporary decrease in surface water runoff as the uKhozi: KPS600/0216 Page 115 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga catchments will be closed off by construction activities. The proposed mining activities will require the construction of a new adit complex, pollution control dams, co-disposal dump site, stockpile area and a fresh water dam. Surface water will be directed around these areas through various storm water measures. However rain falling within the construction site will be contained in the PCDs during the construction phase. This water will be prohibited from entering the drainage lines and stream and will therefore affect the quantity of surface water runoff. Should storm water measures not be implemented, surface water will be polluted by construction activities and the impact on the surface water would have a greater significance.

Multiple mining operations in the area will probably have a moderate cumulative impact on the catchment yield.

Summary of impact on the surface water runoff Magnitude Timing Duration Probability Level of Significance

Large Future S/T Temporary L/T Probable Moderate

 Potential Impact: Disturbance of the bed and banks of the water courses running through the mining site.

The expansion/upgrade of five low level crossings will have a potential impact on the riparian habitat of the stream. Although the area will be rehabilitated, the riparian habitat (vegetation and microenvironment) will definitely be disturbed. The bed/bank of these streams will be altered which might lead to a potential decline in the quality of the water. The clearance of vegetation around the site can pose as a potential risk for erosion, however it will be of low significance as the disturbance would only be around the expansion site.

Summary of impact on the riparian habitat Magnitude Timing Duration Probability Level of Significance

Small Future S/T Temporary S/T Definite Moderate

Groundwater  Potential Impact: Contamination of groundwater through infiltration The groundwater of the surrounding area is currently being polluted by the seepage of rain water from the disturbed site into the underlying aquifer.

Spillage from chemical toilets, oil spills and construction dumping may infiltrate the uKhozi: KPS600/0216 Page 116 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga groundwater system and contaminate the groundwater resources. Dirty storm water collecting in the Pollution Control Dams (PCD) during the construction phase has the potential to leach into the groundwater.

Multiple mining operations in the area will probably have a moderate cumulative impact on the groundwater quality.

Summary of the impact on the groundwater quality Magnitude Timing Duration Probability Risk Level of Significance

Large Present Temporary L/T Probable High Moderate

 Potential Impact: Decrease in groundwater level through the opening of additional adits The opening of additional adits may have an impact on the groundwater as these adits, depending on their location and in relations to the groundwater table and impermeable rock layers. Once the precise location of the adits has been determined, one will be able to assess whether the construction phase will have a significant impact on the groundwater level. The existing adits would already have affected the groundwater.

Multiple mining operations in the area will probably have a moderate cumulative impact on the groundwater availability.

Summary of the impact on groundwater level Magnitude Timing Duration Probability Risk Level of Significance

Large Future S/T Temporary L/T Possible Moderate Moderate

Air Quality During the construction phase of the planned activities (the construction of the new adit complex, washing plant area, stockpile areas, Co-Disposal Dump site, PCDs, fresh water dam and associated roads), dust will mainly be produced by site establishment operations, including stripping of topsoil and grading of access roads. The carbon-dioxide emissions associated with the diesel machines are of such a small quantity that the impact thereof on the air quality is considered to be of a low significance. Dust suppression by water tanker will be employed to mitigate the release of dust which will lower the significance rating of the impact.

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Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga Construction activities in the area associated with development and mining activities will probably have a cumulative impact on the air quality of the area if mitigation measures are not implemented. Summary of the impact on air quality Magnitude Timing Duration Probability Level of Significance

Large Future S/T Temporary S/T Probable Low

Sensitive Landscapes The area is a brownfields sites thus no sensitive landscapes will directly be affected by construction activities. However, should the groundwater be affected, there is a significant probability that springs and fountains which feed various wetlands, may be negatively affected. It is therefore recommended that an assessment of possible impact on sensitive landscapes be conducted prior to any such activities be conducted.

The wetlands on the mining property are already largely degraded or lost and none are NFEPA listed. However, some of the mining activities will have the potential to impact further on the systems

The construction of the pollution control system will have a positive impact on the surface water resources quality down gradient of the site by containing the current source of pollution but it will have a negative impact on the quantity of surface water runoff into the downstream wetland.

During the establishment of the fresh water storage dam the bed and banks of a tributary flowing into the Annysspruit will be altered.

Summary of the impact on sensitive landscapes Magnitude Timing Duration Probability Level of Significance

Large Future S/T Permanent L/T Definite High

Noise The main cause of an increase in the ambient noise level is the haulage trucks and other plant equipment associated with the construction of additional adits, stockpile areas and water management structures such as the pollution control dams and the fresh water dam required for the planned activities. The reverse sirens of the construction vehicles and general diesel engine running noise will add to the industrial noise of the site, which will be in stark contrast to the natural noise character of the site. The noise will however be mitigated by the natural topography of the site and high wall created on the site. The uKhozi: KPS600/0216 Page 118 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga mountain will act as a noise buffer to the adjacent landowners on the southern and south- eastern side of the mountain. The construction noise will extend from the site boundaries and will definitely contribute to the existing noise levels.

Construction activities in the area associated with development and mining activities will definitely have a cumulative impact on the noise level of the area.

Summary of the impact on noise Magnitude Timing Duration Probability Level of Significance

Large Future S/T Temporary S/T Definite Low

Visual Aspects Of the planned activities, the mining of additional seams through additional adits and the establishment of the washing plant and its associated infrastructure will have an impact on the visual character of the area. The site is visible from the R543 (Piet Retief – Wakkerstroom) district road, lying some twelve kilometres to the north of the site. There are some four family communities who would have a direct line of vision of the mine.

The new presence of mining equipment and the erection of infrastructure will change the aesthetics and “sense-of-place” of the area. The stockpiles and berms around the terraces will also act as screens to mitigate sound and visual disturbance from the mining site.

Dust from the construction activities will also cause a visual disturbance that is temporary. Coal dust fall-out along the sides of the roads and around the mining area will also impact on the aesthetics of the area. Lighting from vehicles at night during construction activities, lighting masts and security lights will also contribute to the visual impact.

However, as the area already has a mining character, the impact will only contribute to the existing impact and the planned activities will have a moderate significance before mitigation. Such mining activities are further screened from surrounding receptors (on the southern and south-eastern side) by the local mountain range.

Summary of the impact on visual characteristics

Magnitude Timing Duration Probability Level of Significance

Large Future S/T Temporary S/T Definite Moderate

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Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga Socio-economic Conditions (Construction Phase)  Potential Impact: The local economy will benefit from the new employment opportunities and the knock-on effect of employment.

This project will ensure employment of personnel associated with the construction of the mine, albeit on a temporary basis. There will be an opportunity for a permanent employment framework, but this is covered under the section below, operational phase.

The families living on and around the property will have a major change in quality of life and lifestyle due to the close proximity of the mining operation, and wealth that it will create and distribute among the communities via salaries and services. The mine could negatively impact upon the value of surrounding land.

As there is no evidence of the land value depreciating as a direct result of the adjacent Kiepersol Colliery, it is not likely that the refurbishment and recommissioning of the Kwasa Colliery would have a high impact on the land value in the area. This is a subjective issue, (in that it would largely be determined by market forces), and has not been quantified.

The overall, residual impacts as determined by this qualitative impact assessment are such that it is unlikely that a significant, long-term depreciation in land value would result. Furthermore, should other local adjacent coal reserves be exploited, the regional community will holistically, be sufficiently empowered to limit negative impacts to an acceptable level. (This includes members of the community with skills and experience in legal and technical issues).

The effect of the construction phase on the regional and socio-economic structure will extend beyond the project area and will be temporary (short term - <6 months). It will have a low to moderate level of significance, both negative and positive.

Summary of the impact on the local economy Magnitude Timing Duration Probability Level of Significance

Large Future S/T Temporary S/T Definite Moderate

 Potential Impact: The local and regional road transport network will suffer additional pressure from the haulage trucks.

The local and regional road transport network will suffer additional pressure from the haulage trucks travelling on the surrounding district roads.

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Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga Additional heavy motor vehicle traffic will increase the road degradation of the road infrastructure. However, it is not foreseen that the construction phase will contribute significantly to the road infrastructure degradation as the construction vehicles will remain on site during the construction period and will not travel on the surrounding district roads frequently.

Summary of the impact on the regional road network Magnitude Timing Duration Probability Level of Significance

Large Future S/T Temporary S/T Definite Moderate

 Impact on Interested and Affected Parties (IAPs) The existing status quo of the local economy will be affected by the introduction of relatively higher paying (assumed) but short term employment opportunities. Various IAP have indicated concerns regarding the rehabilitation of the proposed mine and questioned whether the applicant will have enough resources to rehabilitate the area when mining seizes. Further concerns were related to the possible environmental degradation especially the impact on the water resources.

It is therefore assessed that the proposed mine will have an impact during the construction phase on the community cohesion and community perception which is linked to their aspirations for the future.

Ongoing communication with IAPs will be conducted where monitoring information will be made available through the annual audit reports.

A complaints register will be made available at the mine and an environmental monitoring committee will be established.

Summary of the impact on the IAPs perceptions Magnitude Timing Duration Probability Level of Significance

Large Future S/T Temporary S/T Definite Moderate

Heritage/Archaeological Aspects Due to the state that the environment was found in, it is not envisaged that there are any graves or other structures of historical importance on the disturbed site and therefore most of the planned activities will have no impact on any heritage aspects. However the construction of the Co-Disposal dump site and the fresh water storage dam has the potential uKhozi: KPS600/0216 Page 121 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga to impact heritage resources. A heritage impact assessment is currently being conducted by eThembeni Cultural Heritage to determine if there are any heritage resources on the undisturbed areas.

If such aspects are discovered the appropriate mitigation measures as described by a heritage specialist will have to be adhered to.

Cultural Aspects No cultural or spiritual importance has been found to be associated with the mining area; therefore the mining operation will have no impact on any cultural aspects of the site.

6.3.2 Operational Phase Geology The geology will be disturbed on a localised and limited basis by the primary mining methods. The methods planned to be used are proven for this specific reserve, having been employed by the contractor STA at the adjacent Kiepersol Colliery.

The disturbance will be limited to parts of the project area, will be permanent and will happen. It has a high level of significance.

Multiple underground mining operations in the area will have a definite cumulative impact on the geology of the area.

Summary of impact on geology Magnitude Timing Duration Probability Level of Significance

Moderate Future M/T Permanent Definite High

Topography The topography of the area will be affected by the planned activities in terms of the various stockpiles which will be moved, grown and reduced continually during the life of the operations. It is however not foreseen that the planned activities will have an additional impact which is significantly different to that of the impacts identified for the construction phase.

Multiple mining operations in the area exists thus there will be a cumulative impact on the topography of the area in the long term as the tailings facilities are permanent features affecting the relief of the area.

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Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Summary of impact on topography Magnitude Timing Duration Probability Level of Significance

Moderate Future M/T Temporary L/T Probable Low

Soils As per the construction phase, the soils excavated will be separately pre-stripped as topsoil or subsoil and stockpiled separately in a designated area for use during rehabilitation. During the stripping operation of the soil, soil layers will be mixed when removed, transported and stockpiled by the bulldozers. Seeds and roots within these layers will be uprooted and may be exposed to the open air elements which could damage and kill them. This will render the topsoil less fertile. Further stockpiling of the soil will expose the soil to elements of erosion such as wind and water as well as risking the occurrence of compaction.

Due to the fact that the soils have already been compromised, possible further disturbance will have a cumulative effect.

There is a probability of sheet erosion occurring on the areas cleared of vegetation. The extent of the cleared area is however relatively small and will only involve portions of the new adit area, stockpile areas and roads. As these sites will be actively managed (or be covered by temporary structures) the duration will be long term. The probability of gully erosion will be limited to the concentrated flow of collected water points or concentrated flow points (such as culverts) around the mining area. However, proper berm construction and erosion control measures will ensure that the intensity will be greatly reduced. The impact on the soils of the area, due to erosion will therefore have a low level of significance.

Summary of impact on the soils Magnitude Timing Duration Probability Level of Significance

Small Future M/T Temporary L/T Possible Moderate

Land Capability The land capability will not continue to be impacted on by the activities associated with mining.

Mining activities in the area will definitely have a cumulative impact as mining activities will reduce the original land capability in the area to a homogenous area defined by mining.

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Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga Summary of impact on the land capability Magnitude Timing Duration Probability Level of Significance

N/A N/A N/A N/A No further impact

Land use The land use will remain as mining. There would be no further impact during the operational phase as the land use was already changed to mining in the new area during the construction phase.

The fresh water dam will be made available to the community to use for livestock watering and/or irrigation purposes. If managed this way the fresh water dam will have a moderate positive impact on the local community.

The underground mining activities in the area will have a low cumulative impact in the medium term as the surface infrastructure is limited in extent.

Summary of impact on the land use Magnitude Timing Duration Probability Level of Significance

Moderate Future M/T Permanent Definite Moderate (Positive)

Vegetation Impacts on the vegetation will be on-going; however operational activities will produce dust which may impact vegetation surrounding the operational areas. Alien invader species may further establish on the disturbed areas if a weed eradication plan is not set in place. The magnitude of such impacts during the operational phase is however limited to the disturbed areas and does not have a high intensity.

The removal of vegetation over the mining area may lead to a decrease in the carbon sink potential of the area which may have a cumulative impact in the long term due to the increased carbon emissions from mining related activities. In addition, the disturbance in the area will lead to an influx of invasive species and hence a potential loss in biodiversity.

Summary of impact on the vegetation Magnitude Timing Duration Probability Level of Significance

Moderate Future M/T Permanent L/T Possible Moderate

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Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Animal Life Several species of conservation have already been lost from the area as a result of human activities. None were seen at the time of the site visit. If any of the species of concern are still present, even if only for limited periods of time then the impact may be regarded as “High”. However, because the affected area is already so depleted, the additional impacts may be of lower significance.

The associated loss of habitat, disturbance in the area in terms of noise, dust and water pollution associated with mining activities will possibly have a negative cumulative impact on the fauna in the area in the long term.

Summary of impact on the animal life Magnitude Timing Duration Probability Level of Significance

Moderate Future L/T Permanent L/T Possible Moderate

Surface water The property on which the mine is situated is part of a water catchment area and is traversed by numerous drainage lines. Some of these are seasonal while others have perennial flow in normal years. The water yield is regionally important.

The mining activities have the potential to impact on the watercourses in a number of ways which include:  Deterioration of water quality through coal-related substances entering the system. These substances will include both suspended solids such as coal dust and dissolved solids including sulphates and metal ions which can lower the pH of the water and can reach toxic levels.  Erosion of the veld as well as runoff from roads and other infrastructure can clog the stream substrate with silt. This results in loss of habitat for aquatic fauna and so biodiversity is reduced.  Reduction of flows. If excessive water is abstracted for use in the mine and the associated operations, then stream flows are reduced and smaller systems may be dried out completely. Aquatic biodiversity is then lost.

Groundwater  Potential Impact: Decrease in groundwater quantity Mining of additional seams will have a definite impact on the groundwater. Since no secondary mining (and possible total extraction) will be conducted, the roof (dolerite cap) uKhozi: KPS600/0216 Page 125 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga stability will not be compromised. However, should the impermeable layers be cracked water will be allowed to flow through the mountain to the mine workings. Therefore no water would daylight along the side and on top of the mountain. Springs and fountains being fed by the groundwater will dry up.

Multiple mining operations in the area will possibly have a high cumulative impact on the groundwater availability.

Summary of impact on the groundwater quantity Magnitude Timing Duration Probability Risk Level of Significance

Large Future M/T Temporary L/T Possible High High

 Potential Impact: Groundwater contamination Water infiltrating into the mine workings will generate acid mine drainage.

Dirty water contained in the pollution control dams could contaminate the underlying aquifer through seepage. Seepage could also occur on the operational areas (stockpile and discard facility) if storm water is allowed to pool. The management measures should focus on separating the aquifer from the facility by lining the pollution control dams with HDPA (2mm) and clay on top, compacting the operational area and sloping the surface of the stockpile areas to avoid pooling.

The potential exists that leakages from the septic tank system can seep through and contaminate the underlying aquifer. If no management measures are conducted, the groundwater quality will significantly be impacted.

Multiple mining operations in the area will possibly have a high cumulative impact on the groundwater quality.

Summary of impact on groundwater quality Magnitude Timing Duration Probability Risk Level of Significance

Large Future M/T Temporary L/T Possible High High

Sensitive Landscapes Potential Impact: Potential degradation/damage to the wetlands and streams due to mining operations. The following sensitive areas could be affected during the operational phase:

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Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga The Wakkerstroom Wet Grassland proposed exclusion area. This area must be avoided at all cost.

The Annysspruit along with other small tributaries flowing in close proximity of the Kwasa Colliery as well as the wetland north of Kwasa Colliery’s entrance. The potential exist that these streams/rivers could become polluted if the pollution control system does not contain all the contaminated water.

The wetlands on the mining property are already largely degraded or lost and none are NFEPA listed. However, some of the mining activities will have the potential to impact further on the systems.

The construction of the pollution control dams and the in-stream fresh water storage dam will lead to the reduction of storm water runoff into the surrounding streams and wetland.

Large parts of the proposed mining area is a brownfields site with no sensitive landscapes. However, should the groundwater be affected, there is a significant probability that springs and fountains which feed various wetlands, may be negatively affected.

The pollution control system will have a positive impact on the surface water resources quality down gradient of the site by containing the current source of pollution but it will affect the runoff negatively.

Summary of impact on the sensitive landscapes Magnitude Timing Duration Probability Level of Significance

Large Future M/T Permanent L/T Possible High

Air Quality Dust will be created from the localised operational area and the untarred access and district roads during the operational phase from the primary beneficiation and screening operations and the haulage trucks. The air outtake ventilation may transport intermittent increases in (coal) dust levels. Coal dust particles may be transported by the medium of air and deposited beyond the project area. A build-up of coal dust on grazing (especially during the dry winter months) would make the grass less palatable, and would affect the yield of annual crops such as maize. The effect will be temporary and will have a moderate significance rating. Dust suppression by water tanker will be employed to mitigate the release of dust which will lower the significance rating of the impact.

uKhozi: KPS600/0216 Page 127 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga Operational activities in the area associated with development and mining activities will probably have a cumulative impact on the air quality of the area if mitigation measures are not implemented.

Summary of impact on the air quality Magnitude Timing Duration Probability Level of Significance

Large Future M/T Temporary L/T Probable Moderate

Noise During the operational phase noise will be caused by the mining of the adits, operational vehicles, machines and washing plant. In addition construction activities will continue through the operational phase. The main cause of an increase in the ambient noise level is the haulage trucks and other plant equipment associated with construction of the additional adits required for the planned activities. The reverse sirens of the construction and operational vehicles and general diesel engine running noise will add to the industrial noise of the site, which will be in stark contrast to the natural noise character of the site. The disturbance would extend beyond the project area due to the haulage trucks and sirens; it would be a temporary (long-term) disturbance and it will happen. It has a moderate level of significance.

The noise will however be mitigated by the natural topography of the site and highwall constructed on the site. The mountain will act as a noise buffer to the adjacent landowners on the southern side of the mountain. The operational noise will extend from the site boundaries and will definitely contribute to the existing noise levels.

Summary of impact on the noise Magnitude Timing Duration Probability Level of Significance

Large Future M/T Temporary L/T Definite Moderate

Visual Aspects Of the planned activities, the mining of additional seams through additional adits and coal washing along with the related operational requirements will have an impact on the visual character of the area. The establishment of the discard dump along with dust pollution caused by haulage trucks will have the biggest impact on the visual aspects during operation. Lighting from vehicles at night during operational activities, lighting masts and security lights will also contribute to the visual impact. However, as the area already has a mining uKhozi: KPS600/0216 Page 128 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga character, the impact will only contribute to the existing impact and can be describe as having a moderate significance before mitigation.

Summary of impact on the visual aspects Magnitude Timing Duration Probability Level of Significance

Large Future M/T Temporary L/T Definite Moderate

Socio-economic Impacts (Operational Phase)  Potential Impact: The local economy will benefit from the on-going employment opportunities and the knock-on effect of employment.

The proposed mine will create additional employment in the formal sector during the operational phase. The mine will further ensure that the continuation of the mining operations will contribute to increased sustainable income in the area. Furthermore, the employment opportunities in the informal sector – such as street vendor providing food to mine workers – may increase and stabilise. The associated sustainable employment opportunities will have a moderate positive impact on the economic structures of the area. The effect of the mine on the socio-economic structure would extend beyond the project area, have a temporary effect in over the life of the mine and would happen.

On-going communication with the authorities will be maintained to make information available for IAP’s. There are no management measures that can be implemented.

Summary of impact on the local employment Magnitude Timing Duration Probability Level of Significance

Large Future M/T Temporary L/T Definite Moderate

 Potential Impact: The local and regional road transport network will suffer additional pressure from the haulage trucks.

The impact of haulage trucks on the regional road infrastructure will be very high. Currently the haulage industry is causing excessive damage to the road network and the transport by road of coal from Kwasa Colliery to Piet Retief would result in an actual increase in traffic over the long term (life of the mine). The effect of the mine on the road infrastructure would extend beyond the project area, have a temporary effect in over the life of the mine and would happen. uKhozi: KPS600/0216 Page 129 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Summary of impact on road infrastructure Magnitude Timing Duration Probability Level of Significance

Large Future M/T Temporary L/T Definite High

 Potential Impact: The local community will have a reliable water resource to use for irrigation and stock watering The water contained in the fresh water dam will also be available for the local community to use for irrigation or stock watering. This will have a positive impact on them because there will be a more reliable source of water available throughout the year for their farming activities.

Summary of impact on water resource Magnitude Timing Duration Probability Level of Significance

Moderate Future M/T Permanent Probable Moderate

Heritage/Archaeological Aspects No graves or other structures of historical importance were identified therefore the planned activities should have no impact on any heritage aspects. If such aspects are discovered during operational activities, the appropriate mitigation measures, as described by a heritage specialist will have to be adhered to.

A heritage impact assessment is currently being conducted by eThembeni Cultural Heritage. The results from this study will be included in the Final EIA/EMPr.

Cultural Aspects No cultural or spiritual importance has been found to be associated with the proposed site; therefore the mining operation will have no impact on any cultural aspects of the site.

6.3.3 Decommissioning Phase Geology The rock and other substrates that were stockpiled from excavation of the adits, will be used to backfill and landscape (terrace) the adit void on top of the plug. There will be no further impact.

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Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga Summary of impact on the geology Magnitude Timing Duration Probability Level of Significance

Small Future L/T Permanent Definite Low

Topography The topography will be re-shaped by the rehabilitation of the adit complex and the plant area. The remaining impact on the topography will be limited to a small part of the project area, as the landscaped and vegetated Co-Disposal Dump site. It will be a permanent disturbance and it will still need to happen. It has a moderate (positive) level of significance as the post mining topography will be landscaped to emulate (except for the dump) the pre- mining topography.

Summary of impact on the topography Magnitude Timing Duration Probability Level of Significance

Small Future L/T Permanent Definite Moderate (Positive)

Soils The pre-stripped, top soil will be replaced over the remaining landscaped area. The disturbance will be limited to part of the project area, it will have a permanent effect and it will still happen. It has a positive, and moderate level of significance.

The impact on the soils during the decommissioning phase will focus on the amelioration thereof through building up the nutrient status, organic carbon levels and bio-components to self-maintaining levels. Activities associated with the decommissioning phase will aim at rehabilitation of the site and associated soil to the extent that the site can revert back to grazing use. The impact is therefore considered to have a positive impact on not only the site after mining, but also when considering the current state soils.

Summary of impact on the soils Magnitude Timing Duration Probability Level of Significance

Small Future L/T Permanent Definite Moderate (Positive)

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Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga Land Capability The mining area will be rehabilitated to an applied grazing land capability (actually a rehabilitated mining area).

The disturbance will be limited to within the project area, it will be permanent and there is a definite probability that it will happen. It has a moderate (positive) level of significance.

Summary of impact on the land capability Magnitude Timing Duration Probability Level of Significance

Moderate Future L/T Permanent Definite Moderate (Positive)

Land Use The land use will be changed from mining back to agriculture. The disturbance will be limited to the operational area, it will be a permanent disturbance and there is a good chance that it will happen. It has a moderate (positive) level of significance.

The use of land will gradually revert to a combination of agriculture (grazing of domestic livestock) during the decommissioning phase.

The underground workings will be sealed and dangerous excavations rehabilitated. Further rehabilitation activities will include the final rehabilitation of stockpile and discard areas, roads and pollution control structures.

Summary of impact on the land use Magnitude Timing Duration Probability Level of Significance

Moderate Future L/T Permanent Probable Moderate (Positive)

Vegetation The indigenous grasses will be encouraged to re-establish in the rehabilitation programme under the initial protection of a nurse crop of pasture grasses such as Eragrostis tef. The activity will be limited to the project area. It should provide a permanent solution and there is a 90% chance that it will still happen. It has a moderate level of significance. As the site is currently in a degraded state, the rehabilitation of the mining areas as proposed by this application will have a positive cumulative impact on the environment.

uKhozi: KPS600/0216 Page 132 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga Summary of impact on the vegetation Magnitude Timing Duration Probability Level of Significance

Moderate Future L/T Permanent Probable Moderate (Positive)

Animal Life As the habitats become re-established, the pre-mining animal species diversity will gradually return to the vicinity of the previously disturbed areas. This will not be limited to the project area. There is a 70% chance that it will happen. It has a low level of significance and the effect would be positive.

Summary of impact on the animal life Magnitude Timing Duration Probability Level of Significance

Large Future L/T Permanent Probable Low (Positive)

Surface Water The runoff will be diverted away from the rehabilitated sites by run-off control structures until these are stable. The topography will be free-flowing, with no ponding of rainwater. After this occurs, the catchment water make would be affected even less by the mining area.

The pollution control dams would have a certain retention and release capacity and would contain the contaminated water, while the clean water would be released directly into the river system.

The disturbance will be limited to the project area, it will be a permanent and positive effect and will still happen. It has a moderate (positive) level of significance.

Summary of impact on the surface water Magnitude Timing Duration Probability Level of Significance

Large Future L/T Permanent Definite Moderate (Positive)

Groundwater During the decommissioning phase, the dewatering will cease and the groundwater levels in the zone of influence will start to recover. The decommissioning phase is considered to be too short (approximately 6 months) for a significant impact on the groundwater levels or qualities to become manifest. uKhozi: KPS600/0216 Page 133 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Under conditions of no disturbance (such as abstraction), the suspended solids would settle over time, and consequently a salt gradient (salinocline) would develop. This provisional and conceptual impact assessment will be both quantified and qualified during the groundwater modelling exercise currently being conducted by GCS, in terms of the expected volume, quality and phreatic zones where seepage is expected to occur.

Summary of impact on the groundwater levels Magnitude Timing Duration Probability Level of Significance

Large Future L/T Permanent Probable Moderate (Positive)

 Potential Impact: The potential for acid mine drainage During the assessment of the potential for acid mine drainage, it is important to evaluate the volume of leachate that could potentially be generated as well as the quality of leachate emanating from the mining area. Both of these factors will affect potential acid mine drainage from the mining area. In order to obtain site-specific information on the quality of the leachate that will emanate from the mining area, rock samples need to be taken from the mining area. The potential for acid-mine drainage or poor quality leachate forming in the mining area is caused by the exposure of sulphide minerals to atmospheric oxygen. Sulphur assay results are used to calculate the maximum amount of acid that could be generated and the sulphide content is determined by subtracting sulphate sulphur from the total sulphur percentage.

Acid Base Accounting (ABA) is a screening test that does not provide information on the speed (or kinetic rate) at which acid generation or neutralization will proceed. For this reason, it is often recommended that additional test work be undertaken on samples which have acid potential especially, to determine the rate of acid generation (kinetic tests). ABA is however a sound starting point for determining the risk of acid mine drainage from selected rock samples.

The potential for any given rock to generate and/or neutralize acid is determined by its mineralogical composition. This includes the quantitative mineralogical composition, mineral grain size, shape and texture. The term “potential” is used because even the most detailed mineralogical analysis, when combined with ABA, provides a worst-case value for potential acid production.

During underground coal mining there is a very good chance that acid mine drainage will occur. The risk of this happening as well as mitigation measures will be determined by GCS during the Hydrogeological and Geochemical study which is currently underway. The uKhozi: KPS600/0216 Page 134 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga results of this study will be included and assessed in the Final EIA/EMPr.

Summary of impact on the groundwater quality Magnitude Timing Duration Probability Risk Level of Significance

Large Future L/T Temporary L/T Probable High High

 Potential Impact: Risk of decant The rate of recharge to the underground workings after rehabilitation has been completed will determine the risk of decant.

Two aspects have been considered in this section, namely, the volume of leachate that could be generated, and the potential quality of the decant. The possible exposure pathway is also of importance, since poor quality leachate becomes an issue at the point where aquatic systems or other users become exposed to it.

The volume of decant will depend on the rate of recharge as well as groundwater seepage to the underground workings.

The volume of decant should be confirmed by the aid of a groundwater model which is currently being done by GCS. Note: The rate of rise of groundwater levels around the mining area is provisional, and must be confirmed through on-going monitoring. It is not possible to accurately predict the long-term quality of water in the underground workings with the available information.

Summary of impact in terms of decant Magnitude Timing Duration Probability Risk Level of Significance

Small Future L/T Permanent Possible High High

Sensitive Landscapes There will be no impact on sensitive landscapes by mining-related activities during the decommissioning phase.

Summary of impact on the groundwater Magnitude Timing Duration Probability Level of Significance

N/A N/A N/A N/A No effect

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Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Air Quality Dust will be created during the decommissioning phase by the earth moving activities during closing of the adits, terracing the adit areas, rehabilitation and grassing of the dump. The dust created by the haulage trucks will cease and the area affected will be considerably smaller than during the operational phase. The disturbance will be limited to the project area, it will be temporary (short term <6 months after closure). It has a low level of significance.

Summary of impact on the air quality Magnitude Timing Duration Probability Level of Significance

Moderate Future L/T Temporary S/T Probable Low

Noise The earth-moving equipment that is involved with doing the rehabilitation activities will create noise. The activity will be limited to the project area, it will be a temporary disturbance and it will still happen. It has a low level of significance.

Summary of impact on the noise Magnitude Timing Duration Probability Level of Significance

Large Future L/T Temporary S/T Definite Low

Visual Aspects Impact The decommissioning programme itself will influence the aesthetics of the area negatively as there will be much activity on the surface during the rehabilitation of discard dump, removal of coal waste and ripping of hard surface areas, re-shaping of surfaces, and re- vegetation of the footprint area. Once finished, the aesthetics will have been improved.

The impact after the decommissioning phase (post closure) is permanent and of moderate significance (positive) due to the state the environment was found in.

Summary of impact on visual aspects Magnitude Timing Duration Probability Level of Significance

Moderate Future L/T Temporary S/T Probable Moderate (Positive) uKhozi: KPS600/0216 Page 136 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Socio-economic Conditions  Impact: Unemployment

Upon decommissioning of the mine, there is a possibility that various labourers will be left without employment. A decrease in employment levels will have a knock on effect of all spheres of the social environment. It could result in lower household income, health and social well-being as well as participation in deviant social behaviour. The effect on the IAP’s associated with this specific project would extend beyond the project area, and it would have a permanent effect and it will still happen. It has a moderate level of significance.

A complaints register will be made available at the mine reception and a toll- free complaints number made available for the first year of the operation. An environmental monitoring committee will be established.

Summary of impact on the employment Magnitude Timing Duration Probability Level of Significance

Large Future L/T Permanent Definite Moderate

 Potential Impact: The local community will have a reliable water resource to use for irrigation and stock watering The dam will remain on site if this is agreed to by the local community and landowner. The water contained in the dam will be used by the local community and farmers for irrigation or stock watering. This will have a positive impact on them because a more reliable water source will be available on a constant basis throughout the year for their farming activities.

Summary of impact on the water resource Magnitude Timing Duration Probability Level of Significance

Small Future L/T Permanent Definite Moderate (Positive)

 Potential Impact: Expectations of the Interested and Affected Parties Impact on the communities perceptions of the mining activity. If the decommissioning activities exceed or fall short of the expectations of the IAPs regarding the decommissioning of the mine it will have a significant impact on their farming activities as well as aspirations for the future. It is anticipated that the IAP’s will be involved in a consultative closure application process through the environmental monitoring committee. The closure uKhozi: KPS600/0216 Page 137 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga certificate would be communicated to the IAP’s. The effect would extend to beyond the project area. It has a high level of significance.

Summary of impact on the IAPs Magnitude Timing Duration Probability Level of Significance

Large Future L/T Permanent Possible High

Heritage/Archaeological Aspects Decommissioning activities will not have an impact on the heritage/archaeological aspects of the site because these aspects would have been identified and avoided during the construction of operational phase. If such aspects are discovered during decommissioning activities, the appropriate mitigation measures, as described by a heritage specialist will have to be adhered to.

Cultural Aspects No cultural or spiritual importance has been found to be associated with the mining area; therefore the mining operation will have no impact on any cultural aspects of the site.

uKhozi: KPS600/0216 Page 138 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga 7 Environmental Management and Implementation Plan A description has been made of the environmental objectives and specific goals for the proposed coal mining operation in terms of:

 Management of construction, operation and decommissioning bio-physical as well as socio economic issues  Mine closure

The Environmental Management Programme (EMP) will be implemented by means of an operational procedure. It is the objective of the EIA process to determine whether or not this will be sustainable (with acceptable risk and impact). A description of all mitigation measures for the potentially significant impacts that could be introduced by the project has been described.

The principal objectives for impact mitigation would be to:  Prevent or avoid;  Reduce or minimise the impacts; and/or  Contain (and treat where possible).

Only the impacts that could potentially be significant before mitigation will be addressed in the EMP. The post-mitigation impacts will all be considered / assessed to establish whether or not they have been adequately mitigated based on the EMP. The operation would be subject to an EMP that is fully integrated with all outcomes of the EIA.

Mining would only proceed under the authorisation and control of an approved Environmental Management Plan (EMP) Report (plus the other parallel legally required environmental authorisations, such as a water use license, integrated water and waste management plan, change in land use, amongst possible other requirements).

Environmental Management Plan

The following goals and objectives have been set as targets for the effective mitigation of impacts caused by the coal-mining activities during the construction, operation and decommissioning phases. These goals and objectives will be measured through the monitoring programme. The significance of the identified impacts have been assessed pre and post mitigation in Table 28, 29 and 30 below.

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Various parties will be involved during the construction, operation and decommissioning of the proposed mine. As such, the responsibility of various mitigation measures, as identified in the tables below, has been allocated to the various stakeholders involved.

It is proposed that the surrounding community be assisted by the local municipality to establish a committee, which will represent their interests. Representatives of such a committee should be tasked with liaising with Siphiwo Investments.

It is further proposed that an Environmental Control Officer (ECO) be appointed by Siphiwo Investments to assist with the environmental monitoring of the construction and operational phase. It is proposed that the ECO do weekly inspections and provide a monthly progress report during the construction phase and a quarterly performance report during the operational phase.

The key role players for this particular project have been tabled below:

Table 25: Responsible role players Role-player Siphiwo Investments (Pty) Ltd SI The appointed contractors AC The Environmental Control ECO Officer The Community Liaison officer CLO

Each of the parties will have certain responsibilities, as indicated in the tables below, to ensure that the EMP is being adhered to.

The table below have been designed as an easy reference for the impact which may occur due to the construction, operation and decommissioning of the proposed mine. Linked to each of the impacts is the correlating mitigation/management measure as well as the party responsible for the implementation thereof. These tables have been designed for the construction, operation and decommissioning phases.

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Table 26: Potential impact and mitigation register for the construction phase Potential Environmental Activity Environmental Recommended Mitigation Measures Responsible Schedule Environmental Management Impact Significance Party Significance after Indicators Before Mitigation Mitigation Geological and Geomorphological Altering the Mining of all seams will have a definite long Moderate The impact on the geology will be permanent AC Construction phase Moderate Stable High Wall. geotechnical term impact on the local and regional Significance and cannot be mitigated due to the nature of Significance characteristics of the geology of the area. the activity. geological strata. Stability of the high wall will be ensured by the use of split blasting techniques. Topography Change in existing The excavation of the adit, terracing and Low Significance The disturbed area must be kept to the AC Ongoing: Quarterly Low Significance Erosion; topography. stockpiling of overburden and topsoil, along minimum needed for the mining operation. Pooling of surface with the construction of pollution control water. measures will alter the topography. The various stockpiles must be managed to prevent erosion and shaped where required.

Decrease of surface Levelling the topography of the site and Moderate During the levelling of the site ensure that the AC Construction phase Low Significance Pooling of surface water runoff. establishment of diversion berms and the Significance surface water flow is directed away from the water. high wall. construction area towards the surrounding surface water resources.

Soils Erosion and The soils will be pre-stripped as topsoil or Moderate The topsoil must be stockpiled separately and SI/ECO Quarterly Low Significance Erosion; sedimentation. subsoil and stockpiled in a designated area Significance used for the construction of berms: the gradient Vegetative growth for use during rehabilitation. of the sidewalls must be such as to prevent on soil stockpiles. excessive wash during storms. These must be grassed and managed to prevent soil loss through erosion and excessive dust.

The soils should be stockpiled in the form of a berm not exceeding 1.5 m in height in a position down slope of the adit to contain the contaminated rain water run-off around the area.

Contamination of soils. Oil and/or diesel spills from construction Moderate Defining routes for the circulation of heavy SI Ongoing: Life of mine Low Significance Visible oil spills; vehicles. Significance machinery and vehicles; Pooling of water on the operational Restricting machines’ movement to the strictly area. necessary areas;

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Potential Environmental Activity Environmental Recommended Mitigation Measures Responsible Schedule Environmental Management Impact Significance Party Significance after Indicators Before Mitigation Mitigation Ensuring the impermeability of all storage areas for fuel, lubricants and other chemicals.

Land Capability Change in existing land The land capability will be compromised Low Significance The disturbed area must be kept to the SI Ongoing: Monthly Low Significance Vegetative cover; capability. through the construction of the adit site. minimum required for construction of the adit. This is mainly due to the intense impact that Limited area of the construction activities will have on the The topsoil and subsoil must be managed to disturbance. soil and vegetation of the site. ensure effective rehabilitation back to the pre mining land capability during the decommissioning phase.

Land Use Changes in land use The land use will be compromised through Low Significance Control of the area disturbed during the SI Construction/Operational Low Significance Limited area of from a defunct colliery the construction of the adit sites, washing construction phase to ensure no unplanned phase disturbance. to an operational plant and its associated infrastructure. (and/or unauthorised) expansion, with a direct colliery. effect on land use.

Vegetation Loss of vegetation. The vegetation will be removed during the High Significance A detailed mine plan which shows, as far as is SI/ECO Construction phase Moderate Limited area of excavation of the box cut, the roads, possible, all mine infrastructure must be Significance disturbance. pollution control facility, fresh water dam prepared. This plan should be reviewed by an and other infrastructure. Some of these ecologist and, if areas of particularly valuable areas have previously been disturbed and vegetation are likely to be affected then the vegetation that has subsequently alternative layouts should be considered. established is not pristine. Plant salvage operations should be considered. These operations should be undertaken on the advice of the provincial conservation agency who must provide the following information:

If needs be a permit must be obtained from the conservation agency so that the translocations may be done legally. Dust outfall on flora Construction activities which create fugitive Low Significance Clearly demarcate the area for clearance of SI Construction and Insignificance Limited area of outside the dust, such as clearing vegetation, movement vegetation and within which construction Decommissioning phase: disturbance. development of construction vehicles on unpaved activities may take place; Monthly footprint area. surfaces. Prohibit activity outside of the demarcated area;

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Potential Environmental Activity Environmental Recommended Mitigation Measures Responsible Schedule Environmental Management Impact Significance Party Significance after Indicators Before Mitigation Mitigation Implement dust suppression spraying where necessary;

Rehabilitate disturbed areas after construction using indigenous vegetation.

Proliferation of alien Disturbance of natural vegetation and soil Moderate Implement weed eradication programme; ECO Quarterly Low Significance Limited area of vegetation inside the erosion caused by construction activities. Significance disturbance. footprint area. Monitor post construction rehabilitation and remove weeds where necessary. Establishment of alien vegetation. Animal Life Loss of habitat/faunal The animal life will be affected by habitat Moderate Since the fauna is dependent on the vegetation SI Ongoing: Life of mine Low Significance Feedback from diversity. removal during construction and by the Significance it is essential to maintain the best possible environmental disturbance of pathways, which previously indigenous vegetation cover so as to provide forum. crossed the adit and operational areas. habitat for the animals. Guidelines for Traffic on the haul road will disturb animal maintenance of the vegetation have been life, as will other mining-related activities. provided and are emphasised in the biodiversity assessment done by Terratest (refer to Appendix …)

The enclosure fences erected around the operational areas will prevent domestic livestock and discourage larger wild animals from entering the operational sites.

Prohibit activity outside of the demarcated area.

Harm to fauna. Poaching, trapping and killing of animals by Low Significance Clearly demarcate the construction footprint AC Ongoing: Life of mine Low Significance Feedback from construction workers during the area and prohibit movement of workers outside CLO environmental construction activities. the footprint; forum.

Prohibit workers from capturing or handling any animals.

Surface Water Contamination of Chemical spills, oil spills and construction Moderate All “dirty” water runoff should be kept on site SI/ECO Ongoing: Monthly Low Significance Surface water surface water. dumping might be picked up by runoff and Significance and not allowed to mix and contaminate clean quality; contaminate downstream watercourses. runoff; State of the pollution control system. uKhozi: KPS600/0216 Page 143 of 218

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Potential Environmental Activity Environmental Recommended Mitigation Measures Responsible Schedule Environmental Management Impact Significance Party Significance after Indicators Before Mitigation Mitigation The area should be sufficiently bunded, and the water should be collected at the lowest point of the site;

Energy dissipaters should be constructed to prevent erosion;

There should be no mine residue, disposal of industrial waste on site during the construction phase;

Hydrocarbon waste and contaminated waste should be collected for recycling;

Domestic waste should be disposed of at a registered disposal facility;

Ongoing monitoring of surface water quality. Decrease of surface Containment of rain water falling onto the Moderate Construct clean water diversion structures prior SI Ongoing: Monthly Low Significance Feedback from the water runoff into the construction site thereby affecting the runoff Significance to the construction to divert clean water away CLO water monitoring surrounding that generates stream flow. from the construction area and prevent forum. catchment. damming of clean water. Complaints from Water users should be consulted with on a downstream water regular basis. Should the downstream users users. suffer a loss of water, the mine should offer an alternative supply or pay compensation as agrees by proactive consultation. Disturbance of the bed Expansion/upgrade of the five low level High Significance The disturbance footprint should be kept as AC Construction phase Moderate Flow of the stream; and banks of the water bridges. small as possible in order to minimize the Significance courses running impacts on the riparian habitat. Signs of through the mining sedimentation site. Care must be taken to ensure that watercourses around the are not impacted upon at road crossings. Roads structures. should have adequate drainage to remove stormwater as rapidly as possible. No drains should discharge directly into watercourses or within 15 m of a watercourse.

If a road crosses a watercourse on a low level causeway that will be inundated from time to time, then the road should be either tarred or concreted for a distance of at least 20 uKhozi: KPS600/0216 Page 144 of 218

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Potential Environmental Activity Environmental Recommended Mitigation Measures Responsible Schedule Environmental Management Impact Significance Party Significance after Indicators Before Mitigation Mitigation m on either side of the watercourse. The purpose of this guideline is to allow water dripping off vehicles to run back to the watercourse without picking up sediment from the road surface in the process.

Construction waste must be contained and prevented from entering the watercourse. The flow of the stream must in no way be altered or influenced by the upgrading of these crossings. Groundwater Decrease in The opening and dewatering of additional Moderate A Groundwater monitoring program must be SI/ECO Quarterly groundwater Low Significance Groundwater groundwater level. adits. Significance established as soon as possible in order to monitoring levels; generate a database. Complaints from Limit groundwater use as much as possible and water users. measure groundwater abstraction levels. Contamination of the Groundwater seepage flowing into the adit Moderate Any groundwater seepage that may flow into the SI/ECO Ongoing: Construction and Low Significance Groundwater underlying aquifer. during excavation. Significance adit during its excavation will be pumped to the operational phase quality. pollution control dams. This will ensure that Spillage from chemical toilets, oil spills and potentially acid generating rocks (specifically Complaints from construction dumping may infiltrate the the acid generating shale’s) are not in constant water users. groundwater system and contaminate the contact with the water, which will, in turn, groundwater resources. reduce the potential for acid mine drainage during the construction phase. Dirty storm water collecting in the Pollution Control Dams (PCD) during the construction There must be no mine residue, disposal of phase has the potential to leach into the industrial waste on site during the construction groundwater. phase. Hydrocarbon waste and contaminated waste should be collected for recycling as hydrocarbons are a major pollution risk.

Domestic waste must be disposed of at a registered disposal facility.

Remove any oil or diesel spills as soon as it occurs and dispose of it at a registered waste site;

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Potential Environmental Activity Environmental Recommended Mitigation Measures Responsible Schedule Environmental Management Impact Significance Party Significance after Indicators Before Mitigation Mitigation Ensure the impermeability of all storage areas for fuel, lubricants and other chemicals;

Construction vehicles must be kept in a good working order as to prevent unexpected leakages of fuels and lubricants (which could be hazardous substances); All daily maintenance of construction vehicles should be carried out in a demarcated area to limit any possible spills of hazardous materials (oils and greases);

The oils used by the construction vehicles and machines should be collected, stored and transported to an adequate final destination. Air Quality Creation of fugitive Site establishment operation including Low Significance Dust from the internal roads will be suppressed SI/ECO Weekly Low Significance Complaints from dust. stripping of topsoil and grading of access with water and a dust inhibitor. the public. roads. The disturbed area will be rehabilitated in order No excessive, to prevent the generation of dust. chronic dust emanating from Rationalization of the vehicle and machines the operational circulation; area. Air quality pollution. Release of emissions into the atmosphere Low Significance No mitigation measures possible. SI N/A Low Significance Complaints from from the construction vehicles. neighbours. Sensitive Landscapes Disturbance of the bed Construction of the fresh water storage dam High Significance The disturbance footprint should be kept as AC Construction phase Moderate Water quality and and banks of a and low level bridges and culverts. small as possible in order to minimize the SI Significance volume. tributary flowing into impacts on the riparian habitat; the Annysspruit. Riparian habitat up Construction waste must be contained and and downstream of prevented from entering the watercourse. the dam.

Ideally no new roads may pass through a wetland. However, if a new road must pass through a wetland area then care must be taken to ensure that the flow of water through the system is kept diffuse. This implies the use of multiple pipes or culverts and not just a single unit.

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Potential Environmental Activity Environmental Recommended Mitigation Measures Responsible Schedule Environmental Management Impact Significance Party Significance after Indicators Before Mitigation Mitigation

Decrease in the surface Containment of water falling onto the High Significance Construct clean water diversion structures prior SI Construction phase Moderate Water volume. water runoff into the construction site thereby affecting the runoff to construction to divert clean water away from Significance downstream wetlands. that generates stream flow. the construction area and prevent damming of Feedback from clean water. water users. Construction of the fresh water storage dam. Water users should be consulted with on a regular basis. Should the downstream users suffer a loss of water, the mine should offer an alternative supply or pay compensation as agrees by proactive consultation.

Noise Increase in the ambient The use and movement of machines and the Low Significance Carry out the noisiest labours as quickly as SI Construction phase: Weekly Low Significance Complaints from noise level. transportation of materials during possible and during normal working hours AC neighbours. construction. (07:00 – 17:00) or according to applicable legal criteria. The reverse sirens of the construction vehicles and general diesel engine running Follow the equipment’s operation and noise will add to the industrial noise of the maintenance procedures; site. All vehicles must undergo periodic maintenance and inspection;

Visual Change in the visual The mining of additional seams through Moderate Demarcate vegetation clearance areas so as to SI Construction phase: Low Significance Complaints from characteristics of the additional adits and the establishment of the Significance ensure that the minimum amount of vegetation Monthly local people. area. washing plant and its associated is removed; infrastructure will have an impact on the visual character of the area. Remove the minimum amount of topsoil and store for use in post-construction rehabilitation; Lighting from vehicles at night during construction activities, lighting masts and Salvage indigenous vegetation for re-planting security lights. during post-construction rehabilitation;

Removal of vegetation should be done in a 'natural manner', i.e. avoid harsh straight lines;

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Potential Environmental Activity Environmental Recommended Mitigation Measures Responsible Schedule Environmental Management Impact Significance Party Significance after Indicators Before Mitigation Mitigation Use dark paving materials which blend with the natural environment for road surfaces;

Slope berms to resemble the natural surroundings as far as possible;

Vegetate berms as far as possible.

Where possible, use should be made of down- lighting and directional lighting. The height of poles and masts determines how broadly the light is dispensed. If possible, the existing overhead lighting method should be phased out and replaced with an alternative lighting using closer to source, directed LED technology. Socio Economic Additional employment Refurbishment of the defunct Colliery. Moderate Use local workers as far as possible; SI Construction phase Moderate The number of opportunities. Significance AC Significance local jobs created. (Positive) Where possible use local companies to supply (Positive) construction material. The local and regional Transport of construction materials to the Moderate The construction vehicles must remain on site SI Construction phase Low Significance Complaints from road transport network proposed site. Significance as far as possible during the construction road users. will suffer additional period. pressure from the haulage trucks. Perception of the IAPs. Refurbishment of the defunct Colliery. Moderate Ongoing communication with IAPs must be SI/ECO Monthly Low Significance Feedback from Significance conducted and monitoring information must be IAPs. Ongoing rehabilitation of the disturbed area. made available through the annual audit reports.

Heritage/Archaeological Disturbance of heritage Construction and refurbishment activities. Low Significance The following measures should be taken if a SI/ECO Construction phase Low Significance N/A resources heritage resource is uncovered during the construction phase: All construction within a radius of at least 20m of the indicator should cease. This distance should be increased at the discretion of supervisory staff if heavy machinery or explosives could cause further disturbance to the suspected heritage resource.

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Potential Environmental Activity Environmental Recommended Mitigation Measures Responsible Schedule Environmental Management Impact Significance Party Significance after Indicators Before Mitigation Mitigation This area must be marked using clearly visible means, such as barrier tape, and all personnel should be informed that it is a no-go area. A guard should be appointed to enforce this no- go area if there is any possibility that it could be violated, whether intentionally or inadvertently, by construction staff or members of the public. No measures should be taken to cover up the suspected heritage resource with soil, or to collect any remains such as bone or stone. If a heritage practitioner has been appointed to monitor the project, s/he should be contacted and a site inspection arranged as soon as possible.

If no heritage practitioner has been appointed to monitor the project, the head of archaeology at Amafa’s Pietermaritzburg office should be contacted.

The South African Police Services should be notified by an Amafa staff member or an independent heritage practitioner if human remains are identified. No SAPS official may disturb or exhume such remains, whether of recent origin or not.

All parties concerned should respect the potentially sensitive and confidential nature of the heritage resources, particularly human remains, and refrain from making public statements until a mutually agreed time.

Any extension of the project beyond its current footprint involving vegetation and/or earth clearance should be subject to prior assessment by a qualified heritage practitioner, taking into account all information gathered during this initial heritage impact assessment.

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Table 27: Potential impact and mitigation register for the operational phase Potential Environmental Activity Environmental Recommended Mitigation Measures Responsible Schedule Environmental Management Impact Significance Party Significance after Indicators Before Mitigation Mitigation Geological and Geomorphological Altering the geotechnical The coal mining activity will extract coal High Significance The proportion of coal extracted during mining will be AC Operational: Moderate Mining according characteristics of the from the geological seams using limited to ensure that the planned factors of safety are Ongoing Significance to the approved geological strata. conventional bord and pillar underground adhered to in the various sections. plan in the EMP. mining methods. No secondary mining such as stoping and goafing must take place. Topography Change in existing Establishment, moving and growing of coal Low Significance Keep the height of the soil and coal stockpiles under 10 SI/ECO Weekly Low Significance Height of the topography. and soil stockpiles. meters. Inspection stockpiles;

Number of stockpiles;

Visibility of the stockpiles.

Soils Erosion and sedimentation. Stripping of vegetation leaving bare soil Moderate The topsoil must be stockpiled separately and used for SI/ECO Weekly Low Significance Erosion; surfaces. Significance the construction of berms: the gradient of the sidewalls Inspection will be such as to prevent excessive wash during Vegetative growth Stockpiling of soils will expose the soil to storms. These will be grassed and managed to prevent on soil stockpiles. elements of erosion such as wind and water soil loss through erosion and excessive dust. as well as risking the occurrence of compaction. The soils must be stockpiled in the form of a berm not exceeding 1.5 m in height in a position down slope of the adit to contain the contaminated rain water run-off around the area.

Maintain a vegetation layer on the berms.

Construct berms to trap sediment during the operational phase;

Collect eroded sediment to re-use during post- construction rehabilitation.

Contamination of soils. Oil and/or diesel spills from operational Moderate Defining routes for the circulation of heavy machinery SI Ongoing Low Significance Visible oil/diesel vehicles. Significance and vehicles. spills on the operational area.

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Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Potential Environmental Activity Environmental Recommended Mitigation Measures Responsible Schedule Environmental Management Impact Significance Party Significance after Indicators Before Mitigation Mitigation Restricting machines’ movement to the strictly necessary area;

Ensuring the impermeability of all storage areas for fuel, lubricants and other chemicals.

Clean up any spills immediately and disposed of the soil at a registered waste site.

Land Use Reliable water source for Accumulating storm water in the fresh water Moderate The water accumulating in the fresh water dam must be SI Ongoing Moderate Feedback from the local community. dam. Significance made available to the community to use for livestock Significance local people. (Positive) watering and/or irrigation purposes. (Positive) Vegetation Dust outfall on flora outside Operational activities which create fugitive Low Significance Clearly demarcate the area for clearance of vegetation SI Weekly Insignificance Limited area of the development footprint dust, such as the movement of haulage and within which operational activities may take place; disturbance. area. trucks on unpaved surfaces. Prohibit activity outside of the demarcated area;

Implement dust suppression spraying on access roads and the operational area;

Rehabilitate disturbed areas during the operational phase.

Establishment of alien Removal of vegetation and compaction of Moderate A programme of alien weed control should be SI/ECO Quarterly Low Significance Limited area of invasive species on the soils during the operational phase. Significance implemented. Most important in this regard is disturbance. operational area. prevention of the spread of Wattle but effort should also be made to eradicate the species as far as possible.

A veld burning plan should be drawn up by an appropriate ecologist and be implemented. Provisionally the property should be divided into four compartments with there being two at high altitude and two at low altitude. Two of each would be burned in each year with the result that any one is only burned every second year. The boundaries of the compartments as well ancillary guidelines on firebreaks and procedures will be documented in the burning plan. If at all possible, the plan should be done in collaboration with neighbouring property owners.

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Potential Environmental Activity Environmental Recommended Mitigation Measures Responsible Schedule Environmental Management Impact Significance Party Significance after Indicators Before Mitigation Mitigation Loss of Sensitive Species Mining activities including washing and Moderate Since some animals need to drink from streams or SI Ongoing: Low Significance Presence of transporting of coal. Significance wetlands, while others require aquatic systems as their ECO Monthly aquatic species in primary habitat, it is essential to ensure that water watercourses. quality in those features is maintained at as high a level as possible. Additionally, environmental water flows should be maintained. Guidelines for maintenance of the waterways have been provided by Terratest in the Biodiversity and wetland assessment report (refer to Appendix …).. Surface Water Contamination of surface The storm water currently falling on the High Significance Since the condition of the watercourses is largely linked SI Ongoing: Moderate Surface water water polluted areas is flowing into the to the condition of the terrestrial vegetation it is Monthly Significance quality. downstream surface water resources causing important that the latter be maintained. Guidelines for pollution of these streams and wetlands. maintenance of the vegetation have been provided in Complaints from the Biodiversity Assessment done by Terratest and are water users. Storm water which falls directly onto the emphasised here (refer to Appendix …). operational areas will be contained in pollution control dams for use as a dust All “dirty” water must be contained in lined pollution suppressant. control dams.

Leakages from the pollution control dams No outlets from a pollution control dam or any other and septic tank could pollute the source which may contain coal related substances, may surrounding streams and downstream Discharge into a water course. wetland.

No polluted water must be allowed to leave the site or flow into the surface water system.

Inspect storm water infrastructure, berms, culverts, channels around operational areas to ensure they are functioning effectively and are diverting clean water away from all operational areas and containing “dirty water”. Especially around the wash plant, stockpile and discard facilities.

Maintain the septic tank system in good condition to avoid spillages.

Regular maintenance of the operational vehicles and machinery to avoid leaks and spillages.

All “dirty” water runoff must be kept on site and not allowed to mix and contaminate clean runoff; uKhozi: KPS600/0216 Page 152 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Potential Environmental Activity Environmental Recommended Mitigation Measures Responsible Schedule Environmental Management Impact Significance Party Significance after Indicators Before Mitigation Mitigation

Domestic waste should be disposed of at a registered disposal facility;

Ongoing monitoring of surface water quality. Decrease of surface water All “dirty water” will be contained. No Moderate The affected area must be minimised to ensure that SI Monthly Low Significance Surface water runoff into the surrounding polluted water will leave the site or flow into Significance effective control of the water balance can be quantity. catchment. the surface water system. maintained. Complaints from The fresh water dam will contain storm Clean storm water run-off must be diverted around the water users. water runoff thus reducing the quantity operational areas so as to discharge into the natural entering downstream water resources. surface water courses;

The diversion of storm water will include berms and channels around the workings.

Construct clean water diversion structures prior to the construction to divert clean water away from the construction area and prevent damming of clean water. Water users should be consulted with on a regular basis. Should the downstream users suffer a loss of water, the mine should offer an alternative supply or pay compensation as agrees by proactive consultation. Effective surface rehabilitation can influence the quality and volumes of surface water that can be released from the site.

Surface rehabilitation. Surface rehabilitation will start during the Low Significance No mitigation measures needed. SI/ECO N/A Low Significance Limited disturbed construction phase and continue into the (Positive) (Positive) area. operational phase thus reducing the footprint of the colliery. Groundwater Decrease in groundwater Underground mining and dewatering of the High Significance A groundwater monitoring should be established as SI Quarterly Moderate Groundwater level. adits. soon as possible in order to generate a database. monitoring Significance levels.

Potential cracking of the impermeable layers Limit groundwater use as much as possible and during mining. measure groundwater abstraction levels.

Should there be a significant reduction in supply of groundwater to legitimate groundwater users, the applicant should undertake to supply the affected groundwater user(s) with water of equal quantity and quality. uKhozi: KPS600/0216 Page 153 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Potential Environmental Activity Environmental Recommended Mitigation Measures Responsible Schedule Environmental Management Impact Significance Party Significance after Indicators Before Mitigation Mitigation Contamination of the Water infiltrating into the mine workings will High Significance Any groundwater seepage that may collect inside the SI Operational Moderate Groundwater underlying aquifer. generate acid mine drainage. underground workings during mining operations will be phase: Significance quality. pumped to the PCDs for use during dust suppression. Ongoing Dirty water contained in the pollution Complaints from control dams could contaminate the Underground water seepage will further be contained in water users. underlying aquifer through seepage. designated sumps to avoid uncontrolled flooding of the workings during the operational phase, and to keep the Seepage could also occur on the operational contaminated water in the smallest possible area. areas (stockpile and discard facility) if storm water is allowed to pool. Any groundwater seepage into the underground workings must be re-used and contained on site. The potential exists that leakages from the septic tank system can seep through and Separate the aquifer from the facility by lining the contaminate the underlying aquifer. pollution control dams with HDPA (2mm) and clay on top.

Compact the soil of the operational area;

Slope the surface of the stockpile areas to avoid pooling.

Maintain the septic tank system in good condition to avoid spillages.

Regular maintenance of the operational vehicles and machinery to avoid leaks and spillages. Air Quality Creation of fugitive dust. Dust will be created during the operational Moderate Dust from the discard dump and haul roads will be SI/ECO Weekly Low Significance Complaints from phase by the activities at the beneficiation Significance suppressed as necessary with water bowsers at regular the public. plant, the discard dump and the haulage intervals. The water will be sourced from the pollution trucks driving from the western adit (with control dams. No excessive, run-of-mine, raw coal) to the plant and chronic dust from the plant (with product) along the Rationalization of the vehicle and machines circulation; emanating from district (gravel) road to the R543 (tarred) the operational road. Transport powdered materials in covered trucks. area. Air quality pollution Release of emissions into the atmosphere Low Significance No mitigation measures possible. SI N/A Low Significance Complaints from from the construction vehicles. neighbours.

Sensitive Landscapes Degradation/damage to the Operational activities such as washing of High Significance All “dirty” water must be contained in lined pollution SI/ECO Operational Moderate Water quality and wetlands and streams due to coal, stockpiling, transport of product, and control dams. phase: Significance volume of mining operations. dirty water handling. Ongoing uKhozi: KPS600/0216 Page 154 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Potential Environmental Activity Environmental Recommended Mitigation Measures Responsible Schedule Environmental Management Impact Significance Party Significance after Indicators Before Mitigation Mitigation Since the condition of the wetlands is largely linked to downstream the condition of the terrestrial vegetation it is important wetlands. that the latter be maintained. Guidelines for maintenance of the vegetation have been provided in Biodiversity of the Terratest Biodiversity and wetland assessment wetlands. report and are emphasised here (refer to Appendix …). Complaints from No outlets from a pollution control dam or any other landowners. source which may contain coal related substances, may discharge into a wetland.

No polluted water must be allowed to leave the site or flow into the surface water system.

The disturbance footprint should be kept as small as possible in order to minimize the impacts on the riparian habitat;

A 500m buffer zone must be maintained around all wetland areas.

Ensure that the riparian vegetation along the main stream channel is maintained in its present ecological state in order to ensure that the services provided by marginal vegetation such as erosion control, maintenance of biodiversity and sediment trapping persists.

Clearing of alien vegetation from the riparian zone must take place.

On-going maintenance of the riparian zone will be required in order to prevent the re-establishment of an alien vegetative community.

All effort should be made to ensure that mine process water does not come in contact with water in the receiving environment. Noise Increase in the ambient noise The washing of coal and transportation of Moderate Mining activities must be carried out during normal SI/ AC Operational Low Significance Complaints from level. product during the operational phase. Significance working hours (07h00 – 17h00); phase: neighbours. Ongoing

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Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Potential Environmental Activity Environmental Recommended Mitigation Measures Responsible Schedule Environmental Management Impact Significance Party Significance after Indicators Before Mitigation Mitigation The reverse sirens of the operational Follow the equipment’s operation and maintenance vehicles and general diesel engine running procedures; noise will add to the industrial noise of the site. All vehicles and machines must undergo periodic maintenance and inspection;

Visual Change in the visual The mining of additional seams through Moderate Demarcate vegetation clearance areas so as to ensure SI Ongoing Low Significance Complaints from characteristics of the area. additional adits, coal washing along, Significance that the minimum amount of vegetation is removed; local people. establishment of the discard dump with the related operational requirements. Remove the minimum amount of topsoil and store for use in post-operation rehabilitation; Dust pollution through the movement of haulage trucks. Salvage indigenous vegetation for re-planting during post-construction rehabilitation; Lighting from vehicles at night during operational mining activities, lighting masts Removal of vegetation should be done in a 'natural and security lights. manner', i.e. avoid harsh straight lines;

Use dark paving materials which blend with the natural environment for road surfaces;

Slope berms to resemble the natural surroundings as far as possible;

Vegetate berms as far as possible.

Where possible, use should be made of down-lighting and directional lighting. The height of poles and masts determines how broadly the light is dispensed. If possible, the existing overhead lighting method should be phased out and replaced with an alternative lighting using closer to source, directed LED technology. Socio Economic Additional employment Operation of the Kwasa Colliery. Moderate Use local workers as far as possible; SI Operational Moderate Number of local opportunities. Significance phase Significance workers employed. (Positive) Where possible use local companies for transport (Positive) services and security. The local and regional road Transport of product from the proposed High Significance No mitigation measures possible. SI N/A High Significance The district road transport network will suffer site. condition. additional pressure from the haulage trucks. uKhozi: KPS600/0216 Page 156 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Potential Environmental Activity Environmental Recommended Mitigation Measures Responsible Schedule Environmental Management Impact Significance Party Significance after Indicators Before Mitigation Mitigation The local community will The accumulating of storm water in the Moderate Make the water in the fresh water dam available to the SI/CLO Operational Moderate Feedback from have a reliable water resource fresh water dam. Significance local community and farmers for use during irrigation and after Significance local people. to use for irrigation and stock and livestock watering. closure (Positive) watering. Heritage/Archaeological Disturbance of heritage Operational activities such as underground Low Significance The following measures should be taken if a heritage SI Operational Low Significance N/A resources mining, disposal of discard. resource is uncovered during the construction phase: phase  All construction within a radius of at least 20m of the indicator should cease. This distance should be increased at the discretion of supervisory staff if heavy machinery or explosives could cause further disturbance to the suspected heritage resource.  This area must be marked using clearly visible means, such as barrier tape, and all personnel should be informed that it is a no-go area.  A guard should be appointed to enforce this no- go area if there is any possibility that it could be violated, whether intentionally or inadvertently, by construction staff or members of the public.  No measures should be taken to cover up the suspected heritage resource with soil, or to collect any remains such as bone or stone.  If a heritage practitioner has been appointed to monitor the project, s/he should be contacted and a site inspection arranged as soon as possible.  If no heritage practitioner has been appointed to monitor the project, the head of archaeology at Amafa’s Pietermaritzburg office should be contacted.  The South African Police Services should be notified by an Amafa staff member or an independent heritage practitioner if human remains are identified. No SAPS official may disturb or exhume such remains, whether of recent origin or not.  All parties concerned should respect the potentially sensitive and confidential nature of the heritage resources, particularly human remains, and refrain from making public statements until a mutually agreed time. uKhozi: KPS600/0216 Page 157 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Potential Environmental Activity Environmental Recommended Mitigation Measures Responsible Schedule Environmental Management Impact Significance Party Significance after Indicators Before Mitigation Mitigation  Any extension of the project beyond its current footprint involving vegetation and/or earth clearance should be subject to prior assessment by a qualified heritage practitioner, taking into account all information gathered during this initial heritage impact assessment.

Table 28: Potential Impact ad Mitigation Register for the Decommissioning Phase Potential Activity Environmental Recommended Mitigation Measures Responsible Schedule Environmental Management Indicators Environmental Impact Significance Party Significance Before after Mitigation Mitigation Geological and Geomorphological Altering the The underground mine will be left Low Significance Control the mining to remain within the agreed AC Operational and Low Significance Surface stability: key points will geotechnical with the pillars intact. parameters of safety (during mining) and stability Decommissioning be surveyed as part of the characteristics of the (after mining). phase monitoring programme. geological strata. The adits will be plugged. Extra-ordinary recharge of the underground workings, caused by increased infiltration through cracks to surface: the groundwater rest levels in the underground workings will indicate a deviation from the predictions of the groundwater model. Topography Altering the The decommissioning activities will Moderate The area will be shaped to emulate the pre- SI Decommissioning Moderate Local subsidence. established cause the man-made landscapes to Significance mining topography where practicable-this would phase: Monthly Significance topography. look more natural and be stable and (Positive) probably take the form of terraces. (Positive) Noticeable erosion. free-draining. Emphasis will be on ensuring that the area is Pooling of surface water. safe, stable and free draining.

Sloping of remaining structures to ensure that they blend with the natural topography;

Soils Replacing of topsoil The areas to be rehabilitated will have Moderate Topsoil will be replaced over the area to SI/ECO Decommissioning Moderate Growth of vegetation. and landscaping of the soils recovered from the stockpiles Significance complement the growth medium (subsoil) in phase: Monthly Significance disturbed area. and replaced with some compaction (Positive) order to meet the two primary criteria, namely: (Positive) Soil fertility tests.

- topography management (stability) and uKhozi: KPS600/0216 Page 158 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Potential Activity Environmental Recommended Mitigation Measures Responsible Schedule Environmental Management Indicators Environmental Impact Significance Party Significance Before after Mitigation Mitigation Amelioration of Soils. over the cleaned (of carbonaceous - water management (free-draining). Abnormal erosion. material) and landscaped areas. All unrequired mining-related infrastructure including roads, buildings and conveyor lines will be demolished on closure.

All rubble on site will be removed to either the discard dump or the adits and these areas landscaped, top-dressed with sufficient material and the appropriate vegetation. Unrequired roads will be ripped to correct any compaction created by the heavy traffic utilized during the mining operation and rehabilitated with the addition of appropriate fertilizers, lime and grass seed mixes.

The areas to be planted will need to be landscaped and engineered to a slope not greater than 1:6. The replaced soils will then be ripped to a depth of 20mm to loosen the soil, and all weeds will be removed. A fertilizer mix if required (of 3:2:1 at a rate of 200kg/ha) will be applied at time of planting. In addition, and if available, chicken litter should be applied to add bulk (organic matter) to the heavy, clay rich soils.

For areas that are considered too steep, and where a gradient of 1:6 cannot be achieved, the use of Vetiver grass (Vetiveria zizanoides) or an appropriately designed erosion control method is recommended, and in places will be essential to prevent erosion, and to stabilize the soils.

If Vetiver is used it must be planted according to the slope gradient, length of slope, and degree of erosion potential. A spacing of approximately one row every five (5m) meters of vertical drop is recommended. This might alter as the slope becomes very steep, or very shallow. It is uKhozi: KPS600/0216 Page 159 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Potential Activity Environmental Recommended Mitigation Measures Responsible Schedule Environmental Management Indicators Environmental Impact Significance Party Significance Before after Mitigation Mitigation recommended that a specialist be used for the specific areas of concern.

The top dressed areas will then be rolled and seeded, preferably in February/March, or as soon as the soil moisture is sufficient (monitor with tensiometers) to guarantee that the seed has a chance of germinating. A suitable seed mix should be used to stabilize the replaced soils. Compaction of the sub soils should be carried out to an 85% Mod AASHTO, and monitored, so as to achieve the required permeability rate for the underlying materials, and minimise infiltration.

The planting will be undertaken with water, either, by making use of natural rainfall, or by hydro seeding the seed mix onto the ground, or having pre-wet the soils prior to planting, with a weekly watering program (15 to 20mm/week) for one month after planting, or until germination has occurred.

A horticulturist will examine the grass stands one year after planting to ensure that the grass has established itself satisfactorily. A soil sample will be taken in the June following planting, and analysed to determine the required maintenance fertilizer applications.

The establishment of grass will prevent erosion and dust. Vegetation and soil rehabilitation will continue until the land is self-sustainable, well grassed until closure. The soils have moderate erosion potential and therefore specific attention must be paid to the implementation of rigorous erosion control measures. Land Capability

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Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Potential Activity Environmental Recommended Mitigation Measures Responsible Schedule Environmental Management Indicators Environmental Impact Significance Party Significance Before after Mitigation Mitigation The mining area will be The land capability will be positively Moderate The topsoil will be spread over the whole area, SI Monthly Inspections Moderate Vegetative cover rehabilitated to an affected during the decommissioning Significance and a grazing potential will be achieved. Significance applied grazing land phase in that the disturbed areas with (Positive) (Positive) Vegetative production. capability (actually a a compromised capability will be rehabilitated mining rehabilitated and the land capability Plant species diversity. area). returned to a wilderness capability class (as it was before mining).

Land Use Change in land use The land use will be changed from Moderate The land will be managed and used in such a way SI/ECO Decommissioning Moderate Sustainable (applied) farming on mining back to agriculture. (Positive) that good farming practice is possible and phase: Monthly (Positive) the rehabilitated areas. implemented. Visual assessment of the The unrequired pollution control dams, dam wall, stability of rehabilitated areas. berms, haul roads and stockpile areas will all be removed and rehabilitated.

Pollution control dams will be breached and rehabilitated when the water qualities are such that the water can be released, or pumped into the underground workings.

All the temporary facilities, including caravans, ablutions and workshops will be removed from the site. Vegetation Re-establishment of The areas under rehabilitation will be Moderate The indigenous flora will be encouraged to re – SI/ECO Decommissioning Moderate Soil fertility. indigenous vegetation. re-vegetated. Significance establish itself over time as part of the CLO phase: Weekly Significance (Positive) maintenance programme. (Positive) Vegetative (basal & ground) cover. A seed mix will be used to act as a nurse crop to Erosion. speed up the vegetation establishment rate to

ensure that erosion does not occur. Species count (species/m2).

Mulching with veld grass (preferably in seed) will Productivity (tons grass/ha). take place during the first spring of the rehabilitation programme. This will reduce the potential for erosion from storm water and uKhozi: KPS600/0216 Page 161 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Potential Activity Environmental Recommended Mitigation Measures Responsible Schedule Environmental Management Indicators Environmental Impact Significance Party Significance Before after Mitigation Mitigation increase the re-seeding of indigenous species in the area.

While the ideal result would be to have a sward of indigenous, hardy, palatable, perennial grass species capable of growing under conditions of low soil fertility, such species are less easy to establish on disturbed sites. It is thus planned to make use of commercial (“artificial” pasture) species for rehabilitation of the disturbed sites for use as a pasture. Over time, this will also enable the establishing of pioneer species and natural succession of the ecological system.

Animal Life Habitat and animal re- Domestic livestock will be used to Low Significance The pastures will be grazed and maintained CLO Ongoing Low Significance Productivity (Large stock establishment. graze the pastures established on the (Positive) according to a formal pasture management (Positive) units/ha) disturbed areas. programme by the future land owner/user to ensure the organic matter and nutrient build-up The larger wild life will be kept out of to the target (pre-mining) levels). these camps by fences.

No trapping or snaring of wildlife will be permitted within the area under management.

Surface Water Maintenance of the The unrequired surface water Moderate Pollution control dams that are not needed for SI Decommissioning Moderate Surface water quality. pollution control pollution control structures will be Significance future use will be breached and rehabilitated phase Significance structures. rehabilitated during the de- (Positive) when the water qualities are such that the water (Positive) Erosion. commissioning phase. can be released, or pumped into the underground workings.

Carbonaceous material (sediment) will be returned to the discard dump before it is finally closed.

The legitimate requirements of the surface water users will not be infringed upon and will be addressed through the environmental monitoring forum and the Authorities.

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Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Potential Activity Environmental Recommended Mitigation Measures Responsible Schedule Environmental Management Indicators Environmental Impact Significance Party Significance Before after Mitigation Mitigation All legitimate requirements of the downstream water users will be considered and closure objectives set in consultation with users.

Mine residue deposits Rehabilitation of the residue deposits Moderate Discard, slurry and any other mine residue SI Decommissioning Moderate Vegetative growth. and disposal facilities. and removal of disposal facilities Significance deposits from the clean-up operation during phase Significance (Positive) rehabilitation of the site will be disposed of on (Positive) the discard dump, which then will be finally shaped, capped and vegetated.

Industrial and domestic waste will no longer be used (and thus no longer disposed of) on site.

The septic tank for sewage disposal will be left if required for future use. The surface water run- All material used for storm water Moderate Rehabilitation of the soils and vegetation must be SI Decommissioning Moderate Localised settling, especially off will return to its diversions and dam walls will be Significance done such that the surface of the land will phase and after Significance along back-filled areas. pre-mining state reused during final rehabilitation (Positive) emanate, as far as is practicably possible, the closure quarterly (Positive) (Positive). where required for decommissioning. pre-mining state. monitoring Erosion.

The rehabilitation of the soils and the vegetation. Groundwater Contamination of the After mining, the abandoned High Accelerated infiltration into the underground SI/AC Quarterly monitoring High Groundwater quality. underlying aquifer underground workings will be left to Significance workings will be limited by ensuring stability of Significance through Acid Mine fill with groundwater flowing in to the the geological strata above the mine cavity. This Complaints from water users. Drainage (AMD). underground cavity up to the pre- precautionary approach will prevent the surface mining groundwater rest levels. rehabilitation required for the underground work.

Risk of decant. The rate of recharge to the High The volume of decant should be confirmed by the SI Quarterly monitoring Moderate Erosion. underground workings after Significance aid of a groundwater model; Significance rehabilitation has been completed will determine the risk of decant. Ongoing monitoring of the groundwater level.

Ongoing Seepage. The discard dump will (probably) Moderate The groundwater modelling exercise will quantify SI Quarterly monitoring Moderate Vegetative growth. continue to produce seepage until the Significance the volume, quality and phreatic zones where Significance water table stabilizes, after which this (Positive) seepage is expected to occur. (Positive) should reduce to an insignificant volume (the infiltration through the Landscaping (to free-draining) and re-vegetation capping will be very small). of the disturbed areas will minimise infiltration uKhozi: KPS600/0216 Page 163 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Potential Activity Environmental Recommended Mitigation Measures Responsible Schedule Environmental Management Indicators Environmental Impact Significance Party Significance Before after Mitigation Mitigation rates and thus the potential for seepage of contaminated water. Air Quality Creation of fugitive Removal of infrastructure. Moderate Unacceptable dust generated a long haul roads SI Decommissioning Low Significance Feedback through the dust. Significance will be suppressed with a bowser. phase: Weekly monitoring committee. Stabilising and levelling of the disturbed area. The disturbed areas (including unrequired haul No excessive, chronic dust roads) will be rehabilitated in order to prevent emanating from the rehabilitated areas. ongoing dust production. Air quality pollution. Release of emissions into the Low Significance No mitigation measures possible. CLO N/A Low Significance Complaints from neighbours. atmosphere from the vehicles and machines. Noise Increase in the ambient Final landscaping of the disturbed Low Significance Carry out the noisiest labours as quickly as SI Ongoing Low Significance Complaints from neighbours. noise level. areas; possible and during normal working hours (07:00 – 17:00) or according to applicable legal criteria. Demolition of infrastructure and machinery used for these activities. Follow the equipment’s operation and maintenance procedures;

All vehicles must undergo periodic maintenance and inspection; Visual Visual impact on Rehabilitation of discard dump, Moderate Good housekeeping will mitigate against visual SI Ongoing Moderate Feedback from local people. adjacent land users. removal of coal waste and ripping of Significance impacts. Significance hard surface areas, re-shaping of (Positive) (Positive) Vegetative cover. surfaces, and re-vegetation of the Sloping of remaining structures to ensure that footprint area. they blend with the natural topography;

Limit vehicles to established routes as far as possible; Re-vegetate disturbed areas with indigenous vegetation. Socio Economic Unemployment On decommissioning of the mine Moderate A complaints register must be made available at SI Ongoing Moderate N/A various labours will be left without Significance the mine reception and a toll- free complaints Significance employment. number made available for the first year after the operation.

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Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Potential Activity Environmental Recommended Mitigation Measures Responsible Schedule Environmental Management Indicators Environmental Impact Significance Party Significance Before after Mitigation Mitigation An environmental monitoring committee must be established. Perception of the IAPs Rehabilitation of the Colliery. High Ongoing communication with IAP’s will be SI Decommissioning Moderate Complaints from IAPs. Significance conducted where monitoring information will be CLO phase: Monthly Significance Ongoing rehabilitation of the made available through the annual audit reports. disturbed area. A complaints register will be made available at the security gate and a toll- free complaints number made available for the first year of the operation. An environmental monitoring committee will be established.

Heritage/Archaeological Disturbance of Decommissioning activities. Low Significance The following measures should be taken if a SI Decommissioning Low Significance heritage resources heritage resource is uncovered during the phase decommissioning phase:  All activities within a radius of at least 20m of the indicator should cease. This distance should be increased at the discretion of supervisory staff if heavy machinery or explosives could cause further disturbance to the suspected heritage resource.  This area must be marked using clearly visible means, such as barrier tape, and all personnel should be informed that it is a no-go area.  A guard should be appointed to enforce this no-go area if there is any possibility that it could be violated, whether intentionally or inadvertently, by construction staff or members of the public.  No measures should be taken to cover up the suspected heritage resource with soil, or to collect any remains such as bone or stone.  If a heritage practitioner has been appointed to monitor the project, s/he should be contacted and a site inspection arranged as soon as possible. uKhozi: KPS600/0216 Page 165 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Potential Activity Environmental Recommended Mitigation Measures Responsible Schedule Environmental Management Indicators Environmental Impact Significance Party Significance Before after Mitigation Mitigation  If no heritage practitioner has been appointed to monitor the project, the head of archaeology at Amafa’s Pietermaritzburg office should be contacted.  The South African Police Services should be notified by an Amafa staff member or an independent heritage practitioner if human remains are identified. No SAPS official may disturb or exhume such remains, whether of recent origin or not.  All parties concerned should respect the potentially sensitive and confidential nature of the heritage resources, particularly human remains, and refrain from making public statements until a mutually agreed time.  Any extension of the project beyond its current footprint involving vegetation and/or earth clearance should be subject to prior assessment by a qualified heritage practitioner, taking into account all information gathered during this initial heritage impact assessment.

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Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Probability of Impacts Occurring Pre and Post Mitigation

A summary of the probability (%) of the identified impacts occurring during the construction, operation and decommissioning phases pre and post mitigation have been given in Table 31 below. The aspects have been divided into biophysical, socio economic, health and safety and heritage.

Certainty (probability) of occurrence or fact has been assigned five levels or categories, namely:  Already happened: 100%  Definite: >90% of occurrence or fact  Probable: >70% of occurrence or fact  Possible: >40% of occurrence or fact, and  Unlikely: used also for the groundwater assessment to indicate that it is not anticipated (through scientific methods) <=40% of occurrence or fact.

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Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Table 29: Probability of Impact Occurring Pre and Post Mitigation Phase 1 Phase 2 Phase 3

Construction Operational Decommissioning

Pre Post Pre Post Pre Post Mitigation Mitigation Mitigation Mitigation Mitigation Mitigation (%) (%) (%) (%) (%) (%) Geology 100 100 100 100 100 100 Topography 100 100 >70 >40 100 100 Soils 100 100 >40 <40 >70 100 Biophysical Vegetation 100 100 >40 <40 >40 >70 Animal life >40 <40 N/A N/A <40 >40 Surface water contamination >40 <40 >70 <40 >70 <40 Decrease in surface water runoff 100 100 100 100 >70 >40 Disturbance of the bed and banks of water courses 100 100 N/A N/A N/A N/A Surface Rehabilitation N/A N/A >70 >70 >70 100 Groundwater contamination >40 >40 >40 >40 >70 >40 Decrease in the groundwater level >40 >40 >40 >40 >70 >40 Sensitive landscapes >40 >40 >40 >40 N/A N/A

Air Quality >70 >40 >70 >40 >70 >40 Noise pollution 100 100 100 100 100 100 Socio-Economic Land capability 100 100 N/A N/A >40 >70 Land use 100 100 100 100 >40 >70 uKhozi: KPS600/0216 Page 168 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Visual 100 100 100 100 >70 >70 Employment 100 100 100 100 100 100 Damage to regional road network 100 100 100 100 >70 >40 IAPs perceptions 100 >70 100 >70 >70 >40 Reliable water resource for local community through the fresh water dam >70 >70 >70 100

Sites of Archaeological importance Heritage aspects >40 >40 >40 >40 N/A N/A Archaeological Sites >40 >40 >40 >40 N/A N/A

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Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga Environmental Objectives and Goals for Mine Closure

The primary closure objective is to return the area disturbed by mining operations, as closely as is practicable, to its pre-mining state within the decommissioning phase (three years). The pre-mining state referred to is defined as the state the environment was found in before any mining activities took place on the RE of Goedehoop 169 HT.

To achieve this objective, it is critically important to:  Stabilise the affected areas by landscaping and vegetation to the pre-mining topography and cover, affording a land capability of grazing and wilderness potential.  Establish a sustainable post closure land use that is ecologically sustainable, and which would not preclude a nature reserve, eco-tourism or grazing for domestic livestock.  Manage the surface and groundwater to ensure that the mining activities do not cause an unacceptable, negative impact on the receiving environment (Inkomati catchment) nor on the affected groundwater aquifer.

The plant along with its associated infrastructure, Co-Disposal dump site, pollution control dams and the access roads will be rehabilitated and planted to artificial pastures for grazing. The whole area would need to be considered for extensive grazing depending on the involvement of the landowner. The land choice option would have little impact on the rehabilitation options as any of the potential options would require climax veld that can sustainably support domestic and wild animals.

Annual environmental reports detailing the progress of the rehabilitation programme will be submitted to the Authorities and made available to the environmental monitoring committee.

7.4.1 Geology Closure objective An area that has a stable geological foundation.

The impact on geology cannot be prevented, and mitigation by reduction and containment of the impact through the application of proven and acceptable mining methods, including a factor of safety that will continue to ensure a stable surface which will accommodate the planned land uses for the area.

Management Indicators  Factor of safety: prevent subsidence – especially to surface.  Acid mine drainage: the surface must be free-draining with no extra-ordinary infiltration and groundwater make. uKhozi: KPS600/0216 Page 170 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

7.4.2 Topography Closure Objectives An area having slopes and features which emulate the pre-mining topography, and which is stable and safe to people.

The post-mining, disturbed topography must be similar to the pre-mining topography where practicable. The area must be free-draining so as not to inhibit the surface water flow, thus causing excessive infiltration and extra-ordinary erosion.

Management Indicators  No pooling of surface water.  No visible erosion.

7.4.3 Soils Closure Objective The establishment of a self-sustaining growth medium for grassveld vegetation.

The chemical (pH and nutrient status) and physical (microstructure) status of the replaced soil must be stable (dynamic equilibrium) and not susceptible to erosion to ensure that the residual impact of mining-related activities on the soil and consequently the land capability is effectively mitigated.

Management Indicators  Growth of vegetation, and  Stability of soil nutrient levels.

7.4.4 Land Capability Closure Objectives A land capability that will sustain an applied and controlled grazing programme.

The land should be suitably rehabilitated to sustain the planned post closure use with a stocking rate of one large stock unit per ten hectares per annum.

Management Indicators  Vegetative bio-diversity;  Vegetative cover;  Vegetative production.

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Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga 7.4.5 Land Use Closure Objectives Establish an area that can be used for the sustainable grazing of domestic and wild animals.

The pre-mining land use on the undisturbed areas was one of grazing, while that of the disturbed area was mining. The pre-mining undisturbed land use will revert back after mining to what it was, while the rehabilitated, disturbed area will be able to be used as an area for the grazing of artificial pastures.

Management indicators  Land use records;  Sustainability of land uses.

7.4.6 Vegetation Closure objectives Maintain the species diversity and productivity of the undisturbed areas. On the rehabilitated areas, establish a vegetation cover which will stabilize the soil cover.

The re-establishing natural vegetation in the adit area will be assisted by a “nurse crop” of artificial pastures grasses, while the operational area including the plant and discard dump will be vegetated with artificial pasture grasses and managed as such.

While the ultimate goal should be to have indigenous, hardy, palatable, perennial grass species capable of growing under conditions of radical disturbance and low soil fertility, such species are generally commercially unavailable and less easy to establish on disturbed sites. It is thus preferable to make use of commercial species to help the site to become stable. This provides for pioneer growth, which allows the natural succession of the ecological system to encourage indigenous growth. The objective is to establish a variety of species that will produce cover at a variety of growth forms and which would occur during as much of the growing season as possible. This is especially relevant to the decommissioned adit and associated infrastructure areas further up the slope, as opposed to the operational below on the flatter ground.

Management indicators The vegetation of the rehabilitated areas will be monitored during the maintenance phase to determine:  soil fertility;  vegetation ground/basal cover;  erosion potential; and  the possible need for revision of the rehabilitation programme to increase stability through the bio-diversity. uKhozi: KPS600/0216 Page 172 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

7.4.7 Animal Life Closure objectives A non-aggressive environment, suitable to the natural re-habitation of indigenous and domestic animal life.

Management Indicators  Visual survey of an increase in faunal bio-diversity.

7.4.8 Surface Water Closure objectives The objective regarding surface water after the decommissioning phase is to:

 ensure that not only the surface water remaining on the site, but also the surface water leaving the site is of acceptable quality, and  to enable through landscaping, as much as possible of the storm water runoff to flow off the rehabilitated site without undue delay, so as to minimise infiltration without causing unacceptable erosion;  accumulate storm water runoff in the fresh water dam in order to supply the landowner and local community with a more reliable source of fresh water.

Management Indicators:  Surface water quality and hydrological yield.

Maintenance of pollution control structures and fresh water dam

The surface water pollution control facilities along with the fresh water dam will either be maintained or decommissioned as required by the post-mining land users during the de- commissioning phase. All unrequired pollution control facilities will be rehabilitated by the end of the maintenance phase.

Legitimate requirement of surface water uses on affected water courses.

Requirements of the downstream water users will be addressed through the environmental monitoring forum and the DWS. All legitimate and reasonable requirements of the downstream water users will be considered during the catchment reserve determination process and closure objectives will be set in consultation with users during the water use registration / licence application process.

uKhozi: KPS600/0216 Page 173 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga 7.4.9 Groundwater Closure Objectives The mine will ensure that private water users, if affected by mine dewatering, have a reliable alternative source of water.

An ongoing, three-monthly monitoring programme will be implemented during operations. The data obtained from the programme will be used to verify the predictions made in this report.

The adits will be rehabilitated according in order to minimise the risk of acid mine drainage. Carbonaceous material will be replaced at the bottom of the decommissioned adit, and where possible, beneath the groundwater rest level, to ensure early flooding and the limitation of oxidation processes.

Surface rehabilitation strategies to minimise groundwater impacts

Reference is made Table 30 the sections on Topography and Soils for supplementary rehabilitation and remediation strategies.

Requirements of legitimate groundwater users in affected zones

The legitimate requirements of downstream water users will be used to determine the closure objectives. This will be determined by the Reserve Determination process and finalised during the water use licence application process.

Management Indicators  Water quality;  Groundwater rest levels.

7.4.10 Air Quality Closure objective Restore ambient air quality to pre-mining levels.

The rehabilitation of the disturbed areas must be of such a standard that the level of dust generated from (decommissioned) mining activities is insignificant. The generation of dust will be adequately minimised through vegetative cover. This is both a health and aesthetic aspect.

Management Indicators  Visual detection by the IAP’s of unacceptable levels of particulate matter generated from the site;  Visual assessments;  Feedback via the environmental monitoring committee. uKhozi: KPS600/0216 Page 174 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga 7.4.11 Noise Closure objectives Restore the ambient noise levels to the pre-mining levels.

Once the decommissioning phase has been completed, the activities associated with mining area would have ceased, and thus there would be no sources of noise. The typical noise level for rural areas is 40dB.

Management Indicators Reports of incidents from the environmental monitoring committee.

7.4.12 Sites of Archaeological and Cultural Interest

Sites of archaeological importance

Closure objectives There are no recorded sites of archaeological importance within the area planned to be disturbed.

It is considered important to ensure that the IAP’s associated with post-mining land use have an adequate awareness of any significant sites in the study area.

Management Indicators Feedback through the monitoring committee.

7.4.13 Sensitive Landscapes Closure objective No further damage to sensitive landscapes.

Where wetlands have been damaged by past agricultural activities there is opportunity to rehabilitate some systems so as to mitigate for any new impacts which might arise as a consequence of the mine operations. The systems which would be most amenable for rehabilitation are those at the far north of the property. Depending on the degree of rehabilitation it might be possible to trap a large part of the contaminants from the mine. The sensitive landscapes outside the areas of disturbance should continue to be conserved by the post closure land users as do the measures implemented by the mine.

Management Indicators  Feedback from the monitoring committee;  Maintenance of the bio-diversity status quo.

uKhozi: KPS600/0216 Page 175 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga 7.4.14 Visual Aspects Closure Objectives There will be no unacceptable impact on the aesthetic nature of the site.

Many of the pre-mining disturbances of the study area are no longer responsible for causing a negative visual impact as they have become effectively grassed. Certain of these disturbed sites will again be disturbed by mining activities: these will be mitigated from a visual impact point of view by the rehabilitation thereof (landscaping and vegetating the area). There will be no unrequired mining super-structures left on the property for future use, except for the access road.

Management Indicators  Visual assessments;  Environmental Monitoring Forum.

7.4.15 Regional Socio-economic Structure Closure objectives Ensure that both the rehabilitated, (previously disturbed) mining area develops and retains a positive and sustainable economic dynamic for the benefit of the community.

Management Indicators  Continued economic growth in the community associated with the mine;  Feedback from the forum.

7.4.16 Interested and Affected Parties (IAP’s) Closure objectives To reach consensus on the achievement of closure objectives for the mine, and consequently have a satisfied collective of IAP’s that would again consider a coal mine in their area to be a positive opportunity.

Ongoing communication with IAP’s is of cardinal importance. For example, monitoring information will be made available through the annual audit reports and the environment monitoring committee, which will continue to facilitate communication with the IAP’s. The complaints register will continue to be available throughout the decommissioning phase.

Management Indicators  Dynamics of the environmental monitoring committee.  Interested and Affected Parties feel they have been adequately and meaningfully involved throughout the life of mine and the rehabilitation/maintenance phase.  Feedback from the forum. uKhozi: KPS600/0216 Page 176 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga 7.4.17 Infrastructure areas Adequately rehabilitate all unwanted infrastructure.

All buildings will be removed unless identified for post closure use and an agreement with the post closure user drawn up whereby the end user takes full responsibility for the use, maintenance and liabilities associated with the said building/ infrastructure.

Management Indicators  Reach consensus on the achievement of closure objectives for the mine;  Ongoing communication with IAP’s;  Stability of rehabilitated areas.

7.4.18 Mine residue deposits The following six categories are included below under the environmental objectives for mine closure:  Disposal facilities;  Ongoing seepage and control of rain water;  Long term stability;  Final rehabilitation in respect of erosion and dust control;  Sealing of underground workings and of rehabilitation of dangerous excavations;  Final rehabilitation of opencast mine haul ramps, roads and final voids (not applicable).

7.4.19 Disposal facilities Closure objective There will be no operating disposal facilities other than the rehabilitated Co-Disposal Dump site. The septic tank for sewage disposal may be required for post-mining use.

Management Indicators  No latent impacts;  No residual visual impacts.

7.4.20 Ongoing seepage, control of rainwater Closure objective Any ongoing seepage will be pro-actively identified and adequate measures implemented before or during the decommissioning phase. The clean rain water falling on to the (previously disturbed) rehabilitated site will not be contaminated by residual carbonaceous (and other) pollutants remaining on the surface.

uKhozi: KPS600/0216 Page 177 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga Management Indicators  Effective clean-up, landscaping and re-vegetation of former operational areas to reduce the infiltration and contamination of rain water falling on, and flowing over the area.  The storm water run-off should flow along the landscaped water courses to ensure free drainage from the site once rehabilitation has been completed and the topography has been landscaped to the levels envisaged in the rehabilitation programme.  The re-vegetation of the area (and especially the landscaped water courses) will minimise soil erosion.  The re-vegetation of the area will assist in reducing infiltration rates.  Monitor the rest water level in terms of flows and water quality. Proactively determine if the predictions that the groundwater rest table is at a sufficient depth to ensure that seepage on surface will not occur from the old workings.

7.4.21 Long-term stability Closure objective Ensure that the planned secondary mining safety factors are adhered to during the end of mining and landscape the disturbed areas with slopes that are stable.

Management Indicators  No localised settling or subsidence;  No (extra-ordinary, visible) erosion.

7.4.22 Final rehabilitation in respect of erosion and dust control Closure objective Landscape the disturbed areas with slopes that are stable and an effective vegetative cover.

Management Indicators  No (extra-ordinary, visible) erosion;  No dust generated from mining-related activities.

The mixture of grass species will be determined in conjunction with the Department of Agriculture (Resource Conservation), Mpumalanga Parks Board and the post-mining land user(s). It has been planned in this EMP to establish the rehabilitated areas to artificial pastures, to be used and managed as separate units to the areas that will not be disturbed.

7.4.23 Sealing of underground workings and rehabilitation of dangerous excavations. Closure objective uKhozi: KPS600/0216 Page 178 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga The underground workings are to be plugged and made safe. Any dangerous excavations are to be sloped or terraced.

Management Indicators  No access to defunct underground workings;  No accessible slopes that are dangerous to people or animals.

7.4.24 Final rehabilitation of mine haul ramps. Closure objective Only roads required by the post-mining land users will remain on the property. Roads not required will be rehabilitated (ripped, top soiled and vegetated).

Management Indicators  No unrequired roads remaining;  Rehabilitated areas to be stable.

uKhozi: KPS600/0216 Page 179 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga 8 Public Participation Process Stakeholder Participation is a legal requirement, where the potential exists for individuals and /or parties to be affected by a proposed activity.

According to the principles of Integrated Environmental Management (IEM), these individuals and/or parties should be involved in the decision-making process from an early stage in the project, with regard to any relevant issues and concerns complementing the information on which the Regulating Authorities would base their decision.

The decision would entail either,  proceeding to the next phase in the project,  supplementing inadequate information, or  not approving the project.

The decision for the project application is made on the basis of adequate information. The decision-making framework will - in practice, comprise the Authorities and the Proponent. This facilitation of effective communication between the Authorities, the Public and the Applicant, forms the primary role of the Stakeholder Participation Process. Certain key terminology needs to be clarified from the outset.

“Stakeholders” and “the Public”

“Stakeholders” refers to all individual(s) and institutions that are (potentially) associated with the project including:  the Applicant, namely Siphiwo Investments(Pty) Ltd;  regulating (“Competent”) Authorities namely DMR (Witbank), DEDET (Ermelo), Department of Water Affairs (DWS), Gert Sibande District Municipality;  “Commenting” Authorities, namely the Mkhondo Local Municipality, IUCMA, DWS, DMR;  Neighbouring and downstream communities (potentially affected parties);  Other interested and affected parties (IAPs).

It is the right of the IAP to decide whether or not she/he will participate in the process.

The “Public”, more specifically, refers to the last two categories described above, namely:

 surface owners and residents;  Catchment Water Forum;

uKhozi: KPS600/0216 Page 180 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga  neighbouring and downstream (water users) communities (potentially affected parties);  other interested and affected parties (IAPs).

Consultation – a level of Participation

“Participation” refers to a broad term of communication between parties, and includes various levels of intensity in joint decision-making across a continuum, namely:

 inform,  consult,  involve,  collaborate,  empower.

The specific level is dependent on the requirements of the project and its Stakeholders.

The Stakeholder Participation process intends to include the following actions to ensure that the various individuals and parties will be included in the process, namely:  Stakeholder scan (inclusive and will be ongoing during the scoping process);  Distribution of Stakeholder letters;  Individual discussions as may be necessary with  neighbouring landowners;  surface rights holders;  officials administering the application procedure;  Interested and Affected Parties (IAPs).

The focus of the public participation process will be to:  Identify and register potential Interested and Affected Parties (IAPs);  Empower the IAPs as to their participative process rights as “registered IAPs”;  Define roles and responsibilities in the scoping process, namely to raise concerns through response to a project notice placed in the press, public meetings and reports;  Access to documentation, including:  Accessibility of the reports and clarity of the reports;  Access to information on decisions made by the Authorities and Proponent;  Elicit comments in response to the decisions;  Raise issues and/or concerns for further investigation.

uKhozi: KPS600/0216 Page 181 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga Notification Criteria

The Regional Manager or designated agency must make known to Stakeholders and Interested and Affected Parties by way of a notice, that an application has been accepted in respect of the land. This notice must be placed on a notice board that is accessible to the public at the office of the Regional Manager or designated agency.

In additional to the notice, the Regional Manager or designated agency must also make known the application by at least one of the following methods:  Publication in the applicable Provincial Gazette;  Notice in the Magistrate’s Court in the magisterial district applicable to the land in question; or  Advertisement in a local or national newspaper circulating in the area where the land to which the application relates is situated.

A publication, notice or advertisement must include:

 An invitation to members of the public to submit comments in writing on or before a date specified in the publication, notice or advertisement, which date may not be earlier than 30 days from the date of such publication, notice or advertisement;  The name and official title of the person to whom any comments must be sent or delivered, and  The work, postal and street address and, if available, an electronic mail address;  Work telephone number, and  Facsimile number, if any, of the contact person.

In addition, key Stakeholders will need to be individually informed of the application, with communication via fax, e-mail or telephonically.

Creating Public Awareness

8.1.1 Site Notice A site notice was placed at the entrance of the defunct Kwasa Colliery informing the local people that an application for environmental authorisation has been lodged with DEDET (Ermelo) and inviting them to form part of the public participation process (Refer to Appendix A.1.1).

8.1.2 Newspaper Adverts The key stakeholders were notified personally of the 1st public participation meeting that was held on the 25th of February 2014. A press notice was placed in the local newspaper uKhozi: KPS600/0216 Page 182 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga (Excelsior) notifying the public of the intention of Siphiwo Investments (Pty) Ltd to apply for environmental authorisation and inviting participation at a public meeting and / or directly with the Public Participation office (refer to Appendix A.1.2.1).

The registered IAPs were personally invited to the 2nd public participation meeting that was held on the 05th of December 2014 specifically to discuss the Water Use License application. A press notice was placed in the local newspaper (Excelsior) notifying the public of the intention of Siphiwo Investments (Pty) Ltd to apply for a Water Use License and inviting participation at a public meeting and / or directly with the Public Participation office (refer to Appendix A.1.2.2).

8.1.3 Background Information Document

A Background Information Document was handed out at the public meeting and given to Foster Attorneys during the meeting in Ottosdal. The BID gave a background description of Siphiwo Investments involvement and future plans for the mine. The BID further explained the different development alternatives as well as a preliminary development plan (refer to Appendix A.3.1 for a full copy of the BID).

Public Meetings

8.2.1 Public Meeting The 1st public meeting was held on the 25th of February 2014 at 5pm in the Annysspruit Farmers Association Hall. At the public meeting Siphiwo Investments explained that the purpose of the meeting was to inform the key stakeholders that Siphiwo Investments had started the process to apply for environmental authorisation in keeping with their plans to resume mining at the defunct Kwasa Colliery. It was further explained that a formal process has been initiated under Section 11 of the MPRDA for the transfer of ownership of the mine. Background on the mine, the process followed to date, and context for the planned activity was given, including the background and details of the due diligence and remediation plans. uKhozi Environmentalists presented a presentation explaining what environmental authorisations are needed as well as the preliminary plan of development.

The main concerns raised at the public meeting were (refer to the issues and response report for detailed concerns raised by each stakeholder):  Livestock & crops: there is a concern that profitability of agriculture would be compromised by mining activities;  Environmental provision: there is a concern about whether there would be enough funds –and control thereof, for rehabilitation and pollution control;

uKhozi: KPS600/0216 Page 183 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga  Traffic and maintenance: stakeholders are concerned about the expected increased traffic, especially large trucks, in terms of safety, and who would be responsible for the much needed maintenance and upkeep of the roads;  Profitability of mine: stakeholders are concerned that the mine would not be financially feasible, and would thus like to see the mining model;  Labour – has a big effect on the social and financial security of the community. If the mine fails it would have a pronounced negative effect on those aspects of the community.

The 2nd public meeting was held on the 05th of December 2014 at 5pm in the Annysspruit Farmers Association Hall. At the public meeting uKhozi explained that the purpose of the meeting was to discuss the WULA and to obtain issues and concerns specifically relating to the proposed water uses at the colliery. uKhozi Environmentalists presented a presentation explaining the WULA as well as the process. The following main points were dealt with in the presentation (refer to Appendix A.3.5 for the full presentation):

 Background of the proposed project;  Property Description;  Project description (Planned activities for the Construction, Operational and Decommissioning phases);  Section 21 Water uses that will be applied for;  The water balance;  Potential Biophysical and Socio Economic Impacts;  Management/ Mitigation measures;  Planned Specialist studies;  The way forward in terms of the WULA and Environmental Authorisation process.

The main concerns raised at the public meeting were (refer to the issues and response report for detailed concerns raised by each stakeholder):  The construction of the in stream fresh water storage dam will reduce the surface water runoff significantly and could result in the streams and wetlands downstream of this dam drying up;  The planned product stockpile area at the entrance of the colliery is too close to the wetland. It was requested that this stockpile area is moved further south away from the wetland.  Environmental provision: there is a concern about whether there would be enough funds –and control thereof, for rehabilitation and pollution control;

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Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga 8.2.2 Focus Group Meetings A target group meeting was held with the key stakeholders on the 5th of September 2014 to discuss the intention of Siphiwo Investments to resume mining at the defunct Kwasa Colliery and to get preliminary input from them. (Refer to Appendix A.6.1 for the Note for the Record). The main concerns raised at this meeting were:  The costs to rehabilitate the footprint and to establish pollution control measures. The available reserve is not big enough to justify carrying all these costs;  Storm water runoff into the surrounding water resources. At the moment coal waste from the disturbed footprint is ending up in the surrounding rivers during rain events;  Erosion;  Health and Safety issues. There is an open power line on site that can result in serious injury or death.

A target group meeting was held with the local community on the 6th of December 2014 to discuss the intention of Siphiwo Investments to resume mining at the defunct Kwasa Colliery.

Authority Meetings

The Department of Water Affairs conducted a site inspection on the 21st of May 2013. The site visit convinced the department that Kwasa Colliery has water uses that are unlawful. Following this the DWA issued a letter of non-compliance to Kwasa Mining Services requesting them to make a written representation if they believe that there are compelling reasons for the department not to issue a directive.

Siphiwo Investments responded to the above mentioned letter addressing the issues raised by DWA as follows (refer to Appendix A.4.2 for copies of the letters).

As per the requirements the letter received from the Dept. Water Affairs on the 24th June 2013, the following has reference:  There are several non-compliances at the mine, as noted during the visit by Officials of the Department in May 2013.  Although Kwasa Mining Services (Pty) Ltd. is currently the responsible party, a formal process has been initiated under Section 11 of the MPRDA for the appointed Business Rescue manager to apply to the DMR to transfer the Mining Right to Siphiwo, who is able and willing to take this over, together with the environmental liabilities.  Siphiwo recognises the urgency of the pollution control measures needed on the site.  uKhozi Environmentalists prepared an application for a Water Use Licence which was submitted to Kwasa Collieries in March 2010. Siphiwo is currently following up to determine the date and office to which this application was submitted. The Department is requested to indicate if a copy of this application can be made available. uKhozi: KPS600/0216 Page 185 of 218

Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga  Siphiwo recognises the need for a coal washing plant to beneficiate the Run-of-Mine coal to an acceptable product specification, and this implies the need for a discard dump.  Siphiwo has accepted a proposal from uKhozi Environmentalists to do the following in order to become environmentally compliant:  Water Use Licence in terms of the National Water Act, 1998 – revision and amendment as per the requirement for a washing plant and discard dump;  Environmental Authorisation in terms of the Mineral and Petroleum Resources Development Act, 2008 – revision and amendment;  Environmental Authorisation in terms of the National Environmental Management Act, 1998– as may be relevant.

The DWA did not issue a directive.

The Department of Water Affairs and Sanitation (DWS) met with uKhozi on the 22nd of September 2014. uKhozi presented the WULA to them. The department raised the following main points (refer to the minutes of the meeting in Appendix A.6.4):  Good clarification is needed regarding the separation of the clean and dirty water on site. Details must be given on how this will be done;  Proof of public participation must be included in the report. This includes Note for the Records of meetings held, proof of newspaper notices, proof of site notices, issues and response report etc.  S27 motivations must be done in detail especially the investments already made by the applicant. It must indicate every cent spent to date on the proposed project.  The impacts of granting of WULA and not granting WULA must be assessed.  The current Infrastructure on site as well as the planned infrastructure must be described.  The PCDs must be lined with HDPA (2mm) and if possible with clay on top;  All facilities on site must be fenced;  Overflow scenarios must be assessed if the PCDs don’t have 0.8m freeboard. If according to the civil engineer designs all PCDs will have a freeboard of 0.8m then the overflow scenarios don’t need to be assessed.

The Inkomati-Usuthu Catchment Management (IUCMA) Agency conducted a site visit on the 17th of November 2014 in order to advise on the way forward with regards to the Water Use License application. On the 25th of February 2015 a meeting was held with the Inkomati- Usuthu Catchment Management Agency (IUCMA) and the DMR to discuss a collective way forward as to who is liable to rehabilitate or to contain the pollution at Kwasa Colliery.

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Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Register of IAPs

Table 30: IAPs Register Surname First name Organisation / Department Tel Nr Cell Nr Fax Nr Postal/

E-mail address

Mtshali BH Ward Councillor 0176048484 0823623952 0178268127 [email protected] (Mkhondo Municipality)

Nkosi Bob Siphiwo Investments 074 104 [email protected] 0662

Dane Greg STA/Siphiwo 082 8549848 [email protected]

Nhlapho Shadrack Community Development 0822696907 [email protected] Worker

Trebble Mike Goedehoop 0824184347 0178241131 [email protected]

Trebble Bruce Goedehoop 0825712624 [email protected]

Van Wyk Miranda Land Owner 0125473289 0822569383 [email protected]

Prigge Sven Land Owner 0825608179 [email protected]

Prigge Erich Goedehoop 0178262478 0823874031 [email protected]

Boshoff Reinette Land Owner 018 571 018 571 [email protected] Lawyer 0031 0036 (Guillaume Foster) Roodewald Ralf Goedehoop 0836610465 [email protected]

Weber Werner Land Owner 0846529164 [email protected]

uKhozi: KPS600/0216 Page 187 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Surname First name Organisation / Department Tel Nr Cell Nr Fax Nr Postal/

E-mail address

Beneke Heinz Land Owner 0828252828 [email protected]

Zeelie Vlakhaas Land Owner 0827845816 [email protected]

Gary Day Land Owner 0823784610 [email protected]

Loubser Gudrun Land Owner/ 0721108928 P O Box 682, Piet Retief 2380 Community Activist [email protected]

Meyer Jenny Driehoek 082 686 [email protected] 8079

Fourie Manie Private 082 404 [email protected] 7404

Weber Ewald Land Owner 082 371 [email protected] 4713 Gibbons Bradley Endangered Wildlife Trust 082 568 [email protected] 5803 Mathavha Lutendo Environmental Liaison Officer 087 310 076 424 086 668 12 A Theo Mocke Street. Kiepersol Colliery 2952 1381 4799 Piet Retief, 2380 South Africa

[email protected]

Mthembi Golden IUMCA Environmental Office: 013 753 083 825 086 668 [email protected] Resource Protection and Waste 9000 8894 8681

uKhozi: KPS600/0216 Page 188 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Surname First name Organisation / Department Tel Nr Cell Nr Fax Nr Postal/

E-mail address

Rasiuba Thabo IUMCA Environmental Office: 013 753 N/A 086 668 [email protected] Resource Protection and Waste 9000 8681

Ramovha Matshilele Department of Mineral Resources 013 653 [email protected] (Mpumalanga) 0500

uKhozi: KPS600/0216 Page 189 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Issues Raised

Issues identified should be recorded and the assessment based on:  The participation of IAPs as an indication of the success of the scoping exercise,  The perceived significance of the issues, and  A measure of the sustainability of the outcome/solution.

The overriding objective during this consultative process is to create an atmosphere conducive to sharing knowledge between all Stakeholders to ensure that issues identified are used in a positive and constructive manner.

All parties will be given the opportunity to raise their issues – be they fact or perception. The number and frequency with which issues are raised, and the intensity and extent to which they are debated gives a direct indication of the following:  The success of the process;  The perceived significance of the issues; and  A measure of the sustainability of the outcome/solution.

The primary objectives of the scoping exercise include:  Identification and evaluation of existing relevant information;  Identification of a broad range of issues of concern to the Stakeholders through a consultative process, and  Identification of alternatives accommodating a wide range of criteria, and falling into three broad categories, namely:  Social,  Biophysical / “Environmental”  Economic.  Consultation with the relevant Authorities, on a formal basis as to their requirements for administration of the issues and concerns provisionally raised during scoping.  Identification of additional Interested and Affected Parties (IAPs) and the recording of their issues of concern in response to information in local newspapers, consultation with local associations and other key community representatives.  Discussion of the comments raised at scoping meetings with focus groups.

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Issues and Responses

The issues and concerns recorded during the public participation process to date are tabled below along with the response from the Environmental Assessment Practitioner (EAP) and/or Siphiwo Investments.

Table 31: Issues and Responses

Name: Capacity: Issues & Concerns: Responses:

Gudrun Loubser Private At the key stakeholder meeting that was held on the (1) The area will be cleaned and storm water 5th of September 2013 Mrs Loubser had the following control measures will be implemented during comments and concerns: the construction phase to contain the current sources of pollution. (1) Coal lying around on site.  The coal lying around on site would need to Siphiwo Investment started to remove the be cleaned up before operations start. Who is coal. going to remove this coal and who would profit from this? What the mining company must do is: Firstly make money available upfront to clean  Some of the coal on site has already been up the area before mining starts. removed. Who was responsible for this? Secondly during operations for every ton coal sold the mining company need to put money  The profit made from the coal removed from aside for rehabilitation. site must go to community and rehabilitation

of the area. (2) The applicant’s representative Mr Bob Nkosi should speak to the local people and (2) Job opportunities uKhozi consult with the Ward Councillor during the public participation process. uKhozi: KPS600/0216 Page 191 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Name: Capacity: Issues & Concerns: Responses:

 When the mine operated under Kwasa (3) The life of mine is not 1.5 years as Collieries Chief Mathetwa’s people were given previously indicated. It is estimated to be the available jobs and the closer community between 6 – 10 years including the closure felt that they were being neglected. phase.

 Advised that the closer community needs to be (4) Noted. involved in discussion in order to avoid conflict. (5) A hydrosensus and groundwater study will be done using previous work. A

hydrology study will also be done using civil (3) Life of Mine engineers.  Why is Siphiwo Investments interested to do all

the environmental studies and take over the (6) Noted. liability just to mine for 1.5 years (7) Noted.

(4) Criminal Case against Kwasa Collieries (8) The Section 11 was the ownership  Siphiwo Investments must be aware that there transfer from the previous owner to the new is still a criminal case against the mine. Should mine owner. Operations may begin under a Kwasa Collieries be found guilty they will need contract mining arrangement before the to pay the legal and environmental costs to the s.11had been granted and the ownership concerned residents of Mkhondo. transferred, and the coal would be sold as Run-of-Mine. (5) Extent of Kwasa’s footprint (9) The relationship between Siphiwo, STA and Jindal were explained as follows:

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Name: Capacity: Issues & Concerns: Responses:

 Siphiwo Investments must determine the  Bob Nkosi is a shareholder in STA; footprint of Kwasa by taking water and soil  Siphiwo is owned by Bob, but samples to see how far seepage has occurred. financing is done through STA; (6) Environmental Impact Assessment  Jindal has an arm’s length contract  The EIA baseline information from before mining arrangement with STA. mining must be used for the new studies. Not after the damage has occurred.  Jindal had wanted to purchase Kwasa, but this had not been successful. The

coal in the stockpile area at Kwasa (7) Sensitivity of the area No mining should take place in the Piet was sold to Jindal to cover costs and Retief/Wakkerstroom area. The area is too sensitive to remove this pollution source. with regards to water resources and because of this With regards to Kwasa they have complied there are no mitigation measures, just damage control with all the DMR requirements, and with measures. Due to the water resources found in the regards to the Dundas seem at Jindal they area it is a strategic important area for the country. were told to go ahead and as a contractor

they did their job. (8) What is a Section 11 Transfer?

(10) Siphiwo have capital and overseas (9) Relationship between Siphiwo Investments and investments, and have made sure everything Jindal is in order to make sure the funding is  Requested clarity regarding the collaboration adequate. The project team know the area between Siphiwo and Jindal. and know what needs to be done to mine the reserve at Kwasa successfully. For example  Is Siphiwo or their mining contractor involved they plan to establish a washing plant at the in any illegal mining? According to Mrs Loubser mine which was not done in the past and this uKhozi: KPS600/0216 Page 193 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Name: Capacity: Issues & Concerns: Responses:

Jindal is mining the Dundas seam illegally and is considered critical to ensure successful as a contractor STA is also then conducting an production. illegal activity. Siphiwo have already appointed uKhozi to conduct the EIA and Water Use (10) Rehabilitation of the area Licence application as part of the  Siphiwo might also fail like previous mining environmental authorisation process. This company’s attempting to mine at Kwasa was not done by previous companies. successfully. This would mean that the area Siphiwo are waiting for the Section 11 would stay un-rehabilitated and continue to process to be completed after which they will pollute the surrounding environment. go ahead and do a proper Social and Labour Plan (SLP) to ensure it addresses the  What security can be shown to ensure the community and their best interests, and same mistake won’t happen again. submit it to the DMR. The whole process will take time but that it is needed in order to do

it properly. (11) Sustainability of Kwasa Colliery

 Siphiwo want to mine at Kwasa for profit and (11) There is always a qualitative element to to recover revenue – making the prime reason business. Siphiwo realises that the world is a business. finite resource and that they have to look  She requested honesty in what the venture is after each other. They do have to make truly about, which in her opinion was to make money, but also have to put aside the funds money. A concern was voiced that if the land is to rehabilitate to make sure the activity is sustainable. damaged then they cannot move forward with

other opportunities (such as renewable It was suggested that a separate fund is put energy). together which would be open to the public uKhozi: KPS600/0216 Page 194 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Name: Capacity: Issues & Concerns: Responses:

 It was requested that Siphiwo come back to the to show the money that is available for stakeholders with their business proposal to environmental provision. satisfy them that the planned operation is feasible.

Bruce Trebble Landowner Goedehoop Mr Bruce Trebble had the following comments and (1) What the mining company must do is: concerns: Firstly make money available upfront to clean (1) Rehabilitation of the area up the area before mining starts.  He is not necessarily concerned about the reopening of the colliery because the area was Secondly during operations for every ton coal left in such a bad state that it is currently sold the mining company need to put money polluting the surrounding water resources. aside for rehabilitation. However he is concerned about what they leave The amount of tons would be difficult to behind after the remaining reserve is mined state off hand, but there would be enough out. for STA to conservatively mine 1.5 Million  From his experience mines never tidy up tons and perhaps more beyond the barriers afterwards because it is not in their interest. (subject to the necessary permits). The only way the mine can really function is to bring in  How much coal there is at Kwasa, and if there an operator to mine at cost to ensure capital will be enough money to cover the cost of for environmental provisions, and have rehabilitation? money at the DMR for the environmental liability. STA and Siphiwo feel confident

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Name: Capacity: Issues & Concerns: Responses:

 What happened to the money set aside for about increasing the provision because they rehabilitation by the previous mine? know they will get a higher price for the coal.

 The rehabilitation after the mining was the Not sure what happened to that money but main concern. Money should be put aside for it most probably nothing had been set aside. and should be managed by a committee which Each mine should have an environmental would keep track of where the funds are used provision fund and Siphiwo believes that the and how they are used. stakeholders should be privy to that  It would be advantageous to get people from information. It is unacceptable for a mine to come in, rape the land, and then leave it for the community to work with the mine who the community to handle. would use the capital efficiently to rehabilitate. In terms of mine closure, it would be the  It was suggested that the Annysspruit Farmers responsibility of the mine, but it would be association Chairman and Vice Chair should important to get the stakeholders into the form part of the rehabilitation fund and be two process. They could get an independent of the signatories. company to do the rehabilitation, but  How many signatories is required for the rehabilitation would remain their (the mine’s) rehabilitation fund? responsibility ultimately. It would be perfectly feasible to get people such as Mkhondo  It was suggested that the Annysspruit Farmers Green in to assist with the rehabilitation. Association will have the majority of the The request to have signatories on the control (65%) over the funds. rehabilitation trust fund was noted and will be discussed with the applicant. (2) Discard Disposal

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Name: Capacity: Issues & Concerns: Responses:

 Siphiwo know they want to mine and sell the The number of signatories for a rehabilitation product but don’t know what to do with the trust fund usually ranges from 3-5. discard. Will Siphiwo start mining if they don’t (2) Department of Water Affairs (DWA) will find an appropriate place to dispose of the not issue a water use license if there isn’t an discard? appropriate plan to dispose the discard, which would mean they may only start (3) The in stream fresh water dam mining without the updated WUL through the  The proposed fresh water dam must rather be Jindal adit into a block within their Mining Rights area and the coal would be sold as constructed off-stream as the stream plays a Run of Mine. major role for the watering of livestock and the health of the wetlands especially during the (3) This is the reason for applying for a dry winter months. Section 21(c&i) water use. The DWA will assess the impact of the dam on the surface  The wetland downstream of the proposed fresh water runoff and if it is decided that the water dam is used for grazing and is very impact will be too severe on the downstream important for the local community. If the dam water uses they will not grant the Water Use is constructed in-stream, the stream will not License for the construction of the in stream flow which will result in the wetland drying up. fresh water dam. The dam would then be This will have a major impact on the local moved to an off stream location. community. The wetland also forms part of a The location of the dam will be discussed breeding site for water fowl and crested with the applicant and the engineer. cranes, blue cranes and a number of game According to the engineer the amount of species (Reedbuck). water which will be stored in the dam is 90 000m3/annum and the total amount of (4) Ground and Surface water monitoring uKhozi: KPS600/0216 Page 197 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Name: Capacity: Issues & Concerns: Responses:

 Who will do the ground and surface water runoff from the catchment area is 670 monitoring at the proposed mine? 000m3/annum.

 Who will pay for monitoring after the operation (4) The applicant will decide who to appoint has seized and what will happen after the two to do the water monitoring at the colliery but year monitoring that is needed after the that there is a good chance that uKhozi will operation has seized? do the monitoring. The colliery must continue with monitoring for two years after the operation has ceased and they need to (5) Water Use License Application make provision for this in their financial Who is the representative from DWS to contact provision for rehabilitation. The outcome of regarding the proposed project? the water monitoring results will determine the way forward. (6) Job Creation No unrealistic promises regarding job creation should (5) It was Zethu Makwabasa from the Durban be made as this will create expectations. office and now it is Golden Mthembi from IUMCA (DWS Nelspruit office). Nelspruit DWS is the regulating authority for the Usutu/Inkomati Catchment.

(6) This was noted and agreed to on behalf of the applicant.

Erich Prigge Landowner Mr Prigge raised the following comments and (1) A meeting should be had regarding the concerns: Social and Labour Plan (SLP), to see what commitments were made by the previous (1) Rehabilitation of the area company.

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Name: Capacity: Issues & Concerns: Responses:

 In principle mines need to put money aside for (2) uKhozi have already been appointed by rehab but no one does. the applicant to conduct the EIA as well as the Water Use Licence Application for the  The IAPs should have a guarantee that the refurbishment of the colliery. The mine can deal with the environmental construction phase will only go ahead once the necessary environmental authorisations Liability. have been obtained.  Money set aside for rehabilitation could be

squandered on other things, where individuals Siphiwo will take small steps to build up or organisations would benefit instead of the trust, and this would be aided by working environment. together.

(2) Environmental Authorisations and adhering to the (3) Noted. laws  Previously Kwasa Colliery did not have the (4) A portion of the discard will be sold. necessary environmental authorisations. There will be an element of discard remaining on site and the correct procedures  The stakeholders are weary of anyone wanting will be followed to dispose of it. to mine – which is because they have heard the same story before. However at least Siphiwo is (5) Siphiwo has people that know how to run starting with an environmental process and are a mine. It must be run ‘lean’ with the right having environmental studies done. amount of money being spent on the right things (not luxuries). Siphiwo is a South  He is concerned about corruption. Most mining African company, and they already have a companies have government connections and market for the coal within South Africa, which according to him they get away with doing will generate a cash flow for STA.

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Name: Capacity: Issues & Concerns: Responses:

what they want without having proper Siphiwo and STA are professional miners, and environmental studies done. since STA has been contracted to Jindal they (Jindal) have had more tons of coal mined  Mining can’t be stopped however the mine than ever before. must follow the rules and commitments made in the EIAR, EMPR and WUL in order to minimise the environmental impacts.

(3) Access Road  Siphiwo Investments must use a different access road. The Jindal road can’t take any more traffic.

(4) Discard Disposal  What will happen to the discard?

(5) Feasibility of Kwasa Colliery  How are Siphiwo going to make money when surrounding mines were struggling?

Mike Trebble Landowner Mr Mike Trebble had the following comments and (1) Noted. Mitigation measures will be concerns: described in the EIAR. It would make sense for Jindal (Goedehoop) and Kwasa to work (1) Dust Pollution together.

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Name: Capacity: Issues & Concerns: Responses:

 He is concerned about dust pollution that will (2) Noted. be caused by the additional haulage trucks on the Jindal access road. (3) Noted.

 The applicant should get the extension of the (4) Noted. This is what Siphiwo is planning to road tarred passed the entrance to Kiepersol to do. Kwasa. (5) The life of mine is approximately 6 – 10

years, based on a figure of 20 000 to 30 000 (2) Erosion tons planned to be mined per month.  During previous operations Kwasa dug out

ditches to allow water to flow out in order to (6) There were no environmental policies in continue mining. These ditches are becoming place in the past, and that now they are dongas now and influencing the boundary trying to correct all that and trying to sort fences. things out. Siphiwo have said the water use licence must be in place first before mining

starts. Siphiwo will implement proper (3) Involvement of local communities mitigation measures to avoid or limit the  Local people do not see the broader picture. pollution caused by Kwasa Colliery. Siphiwo The local people do not care about have already started removing the coal that environmental issues like the water quality or was lying around at Kwasa. air pollution they are only thinking about job

opportunities. The location of the product stockpile will be investigated and if necessary it will be able to

move it south. The specific location was (4) Rehabilitation of the area chosen for the easy access for the transporting of the product but it could be uKhozi: KPS600/0216 Page 201 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Name: Capacity: Issues & Concerns: Responses:

 If DWA can’t get the money from Kwasa moved further up the access road if Collieries to rehab the mine it would be a good necessary to reduce the risk of impacting the alternative if a company comes in, mine the wetland. remaining reserve and rehabilitate the area when they leave. (7) Noted. The use of the main access road and maintenance thereof will be discussed Mkhondo Green does a lot of good work and with Jindal. The internal roads at Kwasa has necessary skills. They should sit on the Colliery will be upgraded. committee and assist the mine in managing the environmental rehabilitation process. (8) Water found underground in the underground workings would be used as (5) Life of Mine make up water, and based on the current  What is the expected life of mine? estimates there will be enough water. Water from pollution control dams will be reused,

and in dry cycles water from boreholes will (6) Contamination of surrounding water resources by be used as make up water for the washing Kwasa Colliery plant.  Mr Erich Prigge had lost 8 calves and another

farmer lost 11 pigs after they drank water from (9) According to the title deeds, the a stream running below Kwasa Colliery – which remaining extent refers to portion 0. was the source of their anger towards mining in that it affects their people and livelihood. (10) Siphiwo plans to buy the whole farm. The plan is to allow the current activities on  The location of the product stockpile area at the farm to continue. the entrance of the colliery is located very

close to the wetland on his farm. It was

suggested that it is moved further south. uKhozi: KPS600/0216 Page 202 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Name: Capacity: Issues & Concerns: Responses:

(7) Increased Traffic and Safety on the roads  The stakeholders are concerned about the increased traffic expected on the roads due to mine operations and the transport of coal. They have wives and children using the roads, and would like to ensure their safety.

 The maintenance of the roads would be crucial with increased use. Currently, the Kwasa road is badly eroded and there are cattle on the road that gain access through the gaps in the fences created by the erosion. Safety on the roads is a concern.

(8) Water availability  Will there be enough water for a washing plant.

(9) What portion of Goedehoop is involved the RE or portion 0?

(10) Does Siphiwo plan to buy the whole farm or only the area where the coal reserve is and what will

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Name: Capacity: Issues & Concerns: Responses:

happen to the current lease agreements that are in place for Goedehoop portion 0. ?

Sven Prigge Landowner (1) Kwasa has two options with regards to (1) Storm water runoff screening:  He is concerned about storm water runoff from  Do screening out at the old the mountain. People don’t realise how much Goedehoop footprint; water comes off the mountain during rainfall  Do screening at the mine; events and because of this proper measures are not put in place to manage these events. Both these options will be included in the EIA  He is concerned that Kwasa do not have access and WULA in order to compare the different to enough land to build proper pollution environmental and socio economic impacts control dams. He said Kwasa has 30 ha and to determine which of the two the better according to him it is difficult to put in option is. pollution control measures in such a small area. (2) Noted. A mine manager will be on site permanently. uKhozi: KPS600/0216 Page 204 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Name: Capacity: Issues & Concerns: Responses:

 He suggested that Kwasa must consider doing screening off site. (3) Noted.

(4) The PCDs will contain contaminated water (2) Oversee and Control from the site in order to prevent it from  From previous experience the mine owner is entering the surrounding streams. The water never on site only a contractor. There is from the PCD’s will be recycled and used for nobody accountable on site when there is a dust suppression as well as make-up water problem. in the washing plant. The water will not be treated (other than the

settling out of solid particles), and this is why (3) Coal Washing Plant a Section 21(g) water use is applied for. If coal washing is going to take place at the old (5) The dam will be constructed with an Goedehoop site then the road there needs to be overflow or an outlet of sorts. The dam will tarred. The current state of the road will not allow be located close to the community on the trucks or even normal bakkies to drive on it when it eastern side of the access road into Kwasa. rains. One must look at the proportion of water

coming from the mining area catchment (4) Pollution Control Dams which will be stored in the dam. The in-  What are the function of the four pollution stream construction will result in less control dams? operating costs for the local community and  What will the water from these dams be used farmers in the future because the water for? stored in the dam will be available to be used by the community and farmers for stock  Will the water undergo treatment before being watering and irrigation. The DWS will assess utilised for dust suppression? the impact of the dam on the surface water runoff and if it is decided that the impact will uKhozi: KPS600/0216 Page 205 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Name: Capacity: Issues & Concerns: Responses:

be unacceptable (too severe) on the (5) In stream Fresh Water Dam downstream water uses the department will  Where will the freshwater dam be located and not grant the Water Use License for the will it have an overflow or some sort of outlet? construction of the in stream fresh water dam. The dam is also being considered at an  If too much water is used, the dam will not be off-stream location. able to overflow and therefore the stream and wetland downstream of the dam will dry up. The location of the dam will be discussed with the applicant and the engineer.  The stream flowing into this dam is the only According to the engineer the amount of stream in the area that has not been polluted water which will be stored in the dam is 90 yet, and therefore the dam should rather be 000m3/annum and the total amount of constructed off-stream because during the runoff from the catchment area is 670 winter months there will be no runoff, and 000m3/annum. therefore the stream won’t be flowing. (6) No the conveyor only forms part of the

Goedehoop project. Kwasa has nothing to do (6) Goedehoop’s proposed conveyor belt with the conveyor.  Does the proposed conveyor of the Goedehoop This suggestion was noted. It does make Project form part of the Kwasa project. sense to do it that way from the  Kwasa must consider making use of the environmental (and economic) perspective conveyer belt to transport the ROM to and that Ken Smith would continue to Kiepersol and do the washing there. This will encourage discussions between Siphiwo and Jindal to try to reach an agreement. mean that no wash plant or discard facility

would be needed at Kwasa and therefore the (7) The applicant would like to sort out the impacts on the environment will be minimised. current pollution but have to wait for the WUL uKhozi: KPS600/0216 Page 206 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

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to be granted and Environmental (7) When do the applicant want to start operation? Authorisation. This could take up to a year. However DWS has been on site and would (8) Job Creation support actions to sort out the current If there are any meetings with the communities no pollution. promises should be made if they cannot be kept. (8) This was noted and it was agreed on behalf of the applicant. Jenny Meyer Landowner Mrs Meyer raised the following comments and (1) Water will be directed to pollution control concerns: dams. Berms and trenches will be constructed to separate clean water from (1) Storm water runoff dirty water and direct the dirty water to  What would happen to runoff water from the pollution control dams thus protecting the plant? surrounding environment. A civil design engineer will be appointed to design the storm water management plan. (2) Dust Pollution  What will be done to minimise dust pollution The intensity of rainfall is important, and the from stockpiles during windy conditions. engineer that will be used, knows the area well, and will take all aspects into account

when designing the pollution control dams (3) What will happen to the rehabilitation funds if the and storm water management. Regulation mine is bankrupt? 704 governs how those dams are designed,

so it will be according to that. The current (4) The landowners would like to be part of the trust dam was designed for a smaller area, so the fund controlling body. There should be at least two new design will need to be larger. signatories from the community for the fund.

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(2) Dust suppression would be undertaken on stockpiles to minimise dust pollution. The water used for dust suppression will mainly be sourced from the PCD’s.

(3) The money for pollution control and rehabilitation should be dedicated to a specific mine and should be used to rehabilitate the specific area, but that in practice the funds could be allocated by the DMR to other higher priority mining areas

(4) This was noted.

Guillaume Foster Representative of Reinette Mr Foster had the following comments and concerns: (1) A previous Mining Right had been granted (attorney) Boshoff in terms of the Mineral and Petroleum (1) Previous Environmental Impact Assessments Resources Development Act, 2002. The current EIA is to fulfil the terms under the uKhozi: KPS600/0216 Page 208 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Name: Capacity: Issues & Concerns: Responses:

 Haven’t there been previous EIA’s done at the National Environmental Management Act, Kwasa Colliery? 1998 newest amendments, together with the Water Use Licencing programme. (2) Business Rescue Process  Ms. Boshoff had a land use and rental (2) Mr. Ken Smith, as representative of agreement with Kwasa Mining Services for the Siphiwo Investments, acknowledged the lease of the farm house on the property. points made, and expressed his intentions to Currently, Kwasa Mining Services are in debt to discuss them with Siphiwo and its strategic Ms. Boshoff in the amount of approximately partner, STA. R412 500.00, plus escalation at 15.5% p.a. (3) Noted. These potential impacts will be  Ms. Boshoff was not informed about the assessed in the EIAR. business rescue application or plan, and thus was not initially registered as a creditor in the process.

 Foster Attorney wrote a letter to the business rescue practitioner, and in response was sent documentation and a claim form with the regret that they were unaware that the property owner had a claim. Ms. Boshoff is concerned over her recognition of a claim, should the Section 11 (transfer of Mining Right) go ahead, and if there are sufficient funds to meet her claim. uKhozi: KPS600/0216 Page 209 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Name: Capacity: Issues & Concerns: Responses:

 Foster Attorney highlighted irregularities within the business rescue plan (additional details of which can be sourced directly from Mr. Guillaume Foster).

 As a result of the frustration caused through this process, Ms. Boshoff has decided not to allow anyone onto the property until the situation is resolved. Ms. Boshoff has an appeal pending with the

Department of Mineral Resources, against the Section 11 application from Kwasa Mining Services (Pty) Ltd to Siphiwo.  Foster Attorney requested Siphiwo Investments to make a reasonable offer to compensate Ms. Boshoff, which takes into account the past rent with interest that was not paid, the value of the farm in terms of the coal reserves, the agricultural value, and environmental liability causing the depreciation of her property.

(3) Environmental Considerations  There is a concern that the mining operation will prove too costly for Kwasa Colliery to be successful, and specifically that the uKhozi: KPS600/0216 Page 210 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Name: Capacity: Issues & Concerns: Responses:

rehabilitation will prove too costly to complete since Ms. Boshoff has doubts regarding the amount set aside (of R2 000 000.00) as the rehabilitation guarantee with the Department of Mineral Resources.

 Extensive erosion has occurred through poor management of the previous mining area, which will need to be addressed.

 Coal discard is polluting the wetland and river areas, which will require clean up.

Bradley Gibbons Endangered Wildlife Trust (1) Who will do the ground and surface water (1) The applicant will decide who to monitoring at the proposed mine? appoint to do the water monitoring at the colliery but that there is a (2) What will happen if the applicant is unable to possibility that uKhozi will do the rehabilitate the area due to a lack of funding? monitoring. (3) What specialist studies are planned? (2) Siphiwo will need to make provision (4) People from the outside will come in to look for rehabilitation. It would not make for jobs, which will change the culture of the sense for Siphiwo to take over the local community. For example new people can liability of the area if they did not introduce AIDS in the area. have the financial ability to rehabilitate. (5) The specialist doing the wetland delineation should take the weather into account as the uKhozi: KPS600/0216 Page 211 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Name: Capacity: Issues & Concerns: Responses:

wetlands will look different during the dry (3) The following specialist studies are season. planned:

(6) Who will be in control of the re-vegetation  Hydrogeological and Geochemical during the rehabilitation process? Study;

 Hydrology Study (still needs to be commissioned)

 Fauna and Flora studies as well as the Bio monitoring and Wetland Delineation (Terratest)

 Soil Specialist Study (uKhozi Environmentalists)

 Visual Impact Assessment (uKhozi Environmentalists)

 Heritage Impact Assessment (eThembeni Cultural Heritage)

 Integration of the Social and Labour Plan with the Socio Economic Assessment (uKhozi Environmentalists)

(4) There is a section in the WULA which focusses on the socio-economics of uKhozi: KPS600/0216 Page 212 of 218 Proponent: Siphiwo Investments (Pty) Ltd February 2016 Draft EIA/EMPr for the Refurbishment and Recommissioning of Kwasa Colliery, Piet Retief, Mpumalanga

Name: Capacity: Issues & Concerns: Responses:

the area. These issues will also be addressed during the integration of the Social and Labour Plan with the Socio Economic Assessment.

(5) This was noted. The specialists will be able to delineate the wetlands based on soils as well as vegetation.

(6) A vegetation specialist will be involved in order to ensure the correct vegetation is used to re- vegetate the areas. The farmers will also be included during this process.

Ralf Rodewald Landowner (1) Will the proposed conveyor from Goedehoop (1) The preferred location of the miss the Kwasa operation? conveyor has not been finalised yet but according to the conceptual plans for Goedehoop the conveyor will run through Kwasa’s mining right area to the north of the operational area.

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9 Methodology The report has been compiled through the analysis of various sets of data and reports, a desk-top analysis, site visits and discussions with mine management. The planned future operations are described and the related proposed commitments listed. Updated information regarding predicted impacts on the bio-physical (specifically - ground and surface water) environment will be made available from specialist studies which are in the process of being undertaken at the Kwasa Colliery. The following specialist studies will be incorporated in the final EIA/EMPr upon completion:

 Hydrogeological and Geochemical Study;  Hydrology Study;  Fauna and Flora studies as well as the Bio monitoring and Wetland Delineation;  Soil Specialist Study;  Visual Impact Assessment;  Heritage Impact Assessment;  Integration of the Social and Labour Plan with the Socio Economic Assessment.

The current state of the environment and the proposed construction, operation and decommissioning activities are described in the report.

Desktop Analysis

A desktop analysis of various sets of information has been conducted during the compilation of this report. Documents which had been reviewed include the following:

 Addendum to the approved EMPR (March 2010);  Water Use Licence Application report (December 2014);  Specialist groundwater assessment reports all of the above from the previous Protea Colliery;  Jindal Mining: Africa (Pty) Ltd: Kiepersol Colliery, approved EMPr compiled by uKhozi Environmentalists;

Various sets of legislation had further been taken into consideration during the compilation of the report such as:

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 The National Environmental Management Act, 1998 (Act No 107 of 1998) (As amended) (NEMA);  Mineral and Petroleum Resources Development Amendment Act 49 of 2002 (MPRDA);  The National Water Act, 1998 (Act No 36 of 1998)(NWA);  Mpumalanga Nature Conservation Act, 1998 (10 of 1998) and the South African Biodiversity Institute (SANBI);  Conservation of Agricultural Resources Act, 1983 and Section 28 of the National Environmental Management Act, 1998);  National Environmental Management Waste Amendment Act, 2014 (Act No. 26 of 2014);  National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004); and  National Veld and forest Fire Act, 1998 (Act No. 101 of 1998).

Guiding Principles

Several crucial guiding principles govern the environmental impact assessment exercise, and have been summarised below to give the reader an informed perspective of this process.

9.2.1 Balanced sustainable approach The primary objective of arriving at a sustainable solution is to ensure that an acceptable trade-off is determined, developed and maintained between three categories of criteria namely;

 Social (individual and corporate rights, consultation),  Bio-physical (“environmental”) – no significant compromise in the ecosystems within the zone of influence, and  Economic factors (feasibility).

The approach of Integrated Environmental Management (IEM) is used as a guiding principle.

9.2.2 Best Practicable Environmental Option (BPEO) The activities and processes for the proposed project are influenced by the following issues, namely;

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 Affording the most benefit to the broadest spectrum of the community;  Causing the least (“ecological”) damage;  Catering for both short and long term impacts;  Identification and evaluation of practicable mitigation alternatives, and  Optimisation of the cost: benefit ratio.

9.2.3 Precautionary Principle Where risk and/or uncertainty exist, the precautionary principle will be applied, whereby additional measures are proactively implemented to prevent an occurrence rather than to have to remedy the consequences of such risk becoming manifest.

Assumptions and limitations

The following assumptions and limitations are relevant to this study:  The report is based on project descriptions from the EMPR that was done for Kwasa Mining Services in March 2010 and these are likely to undergo a number of iterations and refinements before it can be regarded as definite.  A project description based on the final design would be provided if changes occur.  It is assumed that all planned construction activities will use the existing footprint and related infrastructure where possible;  It is assumed that new adits will be excavated from the existing adit complex for future planned mining of all the mine-able coal seams.

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10 Environmental Impact Statement Kwasa Colliery is an abandoned small underground coal mine located on the farm Goedehoop 169 HT in the Piet Retief district. The colliery was left in an un- rehabilitated state by the previous owners, Kwasa Mining Services (Pty) Ltd. The surrounding environment, mainly the surface and groundwater resources are currently being polluted. The abandoned Kwasa Colliery is a significant point source of surface and groundwater pollution of the receiving environment. The polluted water also flows into the sensitive wetlands located in close proximity to the mine.

The Mining Right for Kwasa Colliery has recently been applied to be transferred to Siphiwo Investments (Pty) Ltd., for which a S.11 transfer of ownership is required, and has been submitted to the DMR. Discussions are currently being in held in this regard with the surface owner. Once the Mining Right is transferred to Siphiwo Investments (Pty) Ltd, they will be responsible for the environmental liabilities. Siphiwo Investments have committed to implement a designed storm water management system in order to contain the source of pollution and to rehabilitate the mine at the end of life. The construction activities can only start once environmental authorisation is received and the Water Use License is granted by the Department of Water Affairs.

The most significant negative biophysical and socio economic impacts identified in this report will mainly occur during the construction and operational phases of the mine and are listed below (some of these impacts are already occurring and will continue until the mine is rehabilitated):  Surface and groundwater contamination (currently occurring, high significance);  Groundwater seepage and lowering of the groundwater levels could lead to springs and fountain drying up (operational phase, high significance)  Reduction in the surface water runoff (construction and operational phase, moderate significance);  Degradation of sensitive landscapes (currently occurring, high significance)’  Air pollution (construction and operational phases, moderate significance);  Increase traffic which could lead to further degradation of the district roads (construction and operational phases, moderate significance)

The main positive biophysical and socio economic impacts identified in this report are:  Containment of the pollution source (construction phase, high significance)  Rehabilitation of the disturbed area during and after mining (decommissioning phase, high significance)

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 Increase in employment opportunities (construction and operational phases, high significance)

When comparing the environmental impacts that will occur if the Kwasa Colliery is recommissioned to those that is currently occurring due to the state the environment was left in, the recommissioning of the Kwasa Colliery should not have unmanageable additional impacts. Some of the impacts that are currently occurring especially those pertaining to the contamination of the surface and groundwater will be reduced if proper mitigation measures are installed.

Considering the above the option of mining out the remaining reserve and then using the funds to rehabilitate the area should be assessed further by undertaking the specialist investigations identified in Section 10 and incorporating these findings in the Final EIA and EMP for further consideration by the key stakeholders and authorities.

The following recommendations are made:  The Authorities (formally) and Stakeholders should provide comments on the Draft EIA/EMPr in order for an objective and relevant impact assessment to be finalised, and for informed decisions to be made on the basis thereof.  The decision-making process should proceed to the next step, namely completion and submission of the Final EIA/EMP Report supplemented by all the relevant documentation and based on inputs from the specialist studies.

11 Appendices Appendix A: Public Participation Appendix B: Historical Data Appendix C: Motivation for the consideration of the Wakkerstroom Wet Grasslands Appendix D: Layout Plan Appendix E: Site Photographs Appendix F: Specialists Studies Appendix G: Environmental Awareness Plan

Project Manager: Tommy Olivier Alternate: Inus de Wit uKhozi Environmentalists uKhozi Environmentalist

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