8 environmental monitoring plan - erm€¦ · environmental resources management kangra coal (pty)...

ENVIRONMENTAL RESOURCES MANAGEMENT KANGRA COAL (PTY) LTD.

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8 ENVIRONMENTAL MONITORING PLAN

This chapter relates to the following sections of the MPRDA and Regulation

527 (GNR 527) of 23 April 2004 promulgated in terms of the MPRDA:

“Sections 50(h) and 51(b) of the MPRDA Regulations, 2004 under the MPRDA,

2002 requires that an environmental monitoring programme must be developed for a

mining operation.”

Monitoring programmes are also a requirement of Section 24Q of the National

Environmental Management Amendment Act (NEMAA) 2008, (Act No. 26 of

2008) and have to comply with the requirements of the NEMA and associated

Regulations promulgated thereunder. In order for Kangra Coal to comply

with the requirements of the MPRDA and NEMA, monitoring programmes

have to be developed for the different components of the environment that

will be impacted on by the proposed mining and related activities.

The key to the success of environmental management lies in the effective

implementation of the proposed mitigation and management measures.

Monitoring provides qualitative and quantitative information pertaining to

the possible impacts of the development on the environment, and enables the

measurement of the effectiveness of environmental management measures.

Monitoring plans have been developed for the various components of the

EMPr Consolidation and are described in this Chapter. This includes the

monitoring of:

Surface water;

Groundwater;

Biodiversity;

Ambient Air Quality;

Noise; and

Soils

The monitoring plan for each of these potentially impacted areas is described

in the following sections and is an extension of the monitoring programme

currently being undertaken at Kangra’s operations.

8.1 SURFACE WATER MONITORING

Monitoring of surface water is required for the following purposes:

1. To detect the actual impact on surface water quality/quantity timeously.

2. To assess the cumulative impacts on surface water quality/quantity from

current operational and abandoned mines in the catchment areas.


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3. To assess whether the mitigation/management measures provided in

Chapter 7 are effective, supporting the update of mitigation measures

where necessary.

8.1.1 Central Discard Dump

Surface water monitoring at Maquasa East and West is conducted on a

quarterly basis. There is currently one monitoring point upstream of the

proposed Central Discard Dump and no downstream point.

It is recommended that the programme be expanded to include an additional

upstream monitoring point (Egude River tributary, downstream of the

Rooikop mining area) and a monitoring site downstream of the proposed

facility, as described in Table 8.1 and shown in Figure 8.1.

Table 8.1 Current and Proposed Surface Water Monitoring Sites

Site Description Coordinates Status

Latitude Longitude

977 Tributary of the Egude River, upstream of the

proposed Discard Dump -27.01752 30.37000 Current

DD1

Egude River tributary, downstream of

Rooikop and upstream of the proposed

Discard Dump

-27.007686 30.380717 Recommended

DD1 Egude River, downstream of the Discard

Dump -26.999244 30. 385 721 Recommended

Source: GCS, 2016

Samples should be collected by an independent competent person, using best

practice guidelines and should be analysed by a South African National

Standard (SANS) accredited laboratory.

It is recommended that the samples collected at the points listed in Table 8.1

are analysed for the parameters currently included in the monitoring

programme (Table 8.2), as well as any additional parameters identified by the

DWS (no additional parameters are considered necessary at this stage).

Table 8.2 Water Quality Parameters for Sample Analysis

Parameter Parameter Parameter

pH Magnesium (Mg), Iron (Fe),

Conductivity (EC), Sodium (Na), Aluminium (K),

Total Dissolved Solids (TDS), Potassium (K), Sulphate (SO4),

Calcium (Ca), Manganese (Mn), Chloride (Cl),

Fluoride (F), Total Alkalinity (TALK as CaCO3) Suspended solids (SS).

Source: GCS, 2016

Figure 8.1 Proposed Surface Water Monitoring Points

Source: GCS, 2016


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8.1.2 Adit 5 and Overland Conveyor

The surface water monitoring plan is presented in Table 8.3.

Table 8.3 Surface Water Monitoring Plan

ID Latitude Longitude Location Primary Purpose

Water Quality Monitoring

Frequency Water Flow Monitoring Frequency

C5 260 58’ 11.01” S 300 20’ 38.38” E Hlelo stream, bridge

crossing Road D273

To assess water quality and

streamflow rates within the Hlelo

stream downstream of the oHlelo

stream inflow and immediately

downstream of old mining activities

Monthly field parameters,

Quarterly full analysis

Monthly

C8 260 59’ 45.597” S 300 20’ 19.405” E Tributary to the Hlelo

River upstream of the

abandoned mine,

adjacent to the planned

temporary construction

camp and Nooitgezien

operations, and

downstream of the

conveyor

To assess water quality in the

tributary and any impacts as a result

of the temporary construction camp,

Nooitgezien operations and

operation of the conveyor



-

C9 270 3’ 30.919” S 300 18’ 29.957” E Tributary to the south

east of the Mining Right

area

To assess water quality the south east

of the Mining Right area



-

C13 26°59'27.41"S 30°19'12.47"E Hlelo stream upstream of

inflow point of water

from Kransbank wetland

Monitor the change in water

chemistry in the Hlelo stream related

to the Kransbank wetland inflow.



Monthly

C10 260 59’ 55.591” S 300 19’ 12.080” E Downstream point on the

Kransbank wetland.

Tributary to the Hlelo

stream downstream of

Adit 5 and the conveyor

route. Adjacent to

Nooitgezien operations.

To assess water quality in the

tributary and any impacts as a result

of the temporary construction camp,

operation of the conveyor and Adit 5.



Monthly

C14 27° 1'42.15"S 30°19'2.78"E Tributary of the

Kransbank wetland that

drains the northern side

of Adit 5 location. Also

point at which conveyor

crosses the Kransbank

wetland.

Monitor water quality and flow

impacts related to operations at Adit

5.



Monthly

Point 2 27° 2' 2.744" S 30° 18' 26.647" E Surface water abstraction

point immediately

adjacent to the Adit 5

location, from where

surface water will drain

into the Kransbank

wetland.

Monitor water quality and flow

impacts related to operations at Adit

5.


Monthly full analysis

Monthly


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The monitoring plan is a living document that needs to be updated as

monitoring data results are generated. Details in support of Table 8.3 are as

follows:

Each surface water sampling location was selected in order to gain an

overall understanding on the impacts on surface water.

Surface water flow monitoring will be carried out concurrently with field

parameter measurement and surface water sampling where required.

Field parameters, including pH, electrical conductivity (EC), temperature

and dissolved oxygen (DO) should be monitored on a monthly basis.

Samples should be collected for submission to the laboratory on a

quarterly basis at most monitoring locations, but on a monthly basis at

Point 2.

The list of chemical constituents to be analysed will be routinely updated

based on previous results. Parameters to be tested include, but are not

limited to:

pH, EC (to verify field data) and TDS (for quality control purposes)

Cl, SO4, NO3, total N, F, Ca, Mg, Na, K, total alkalinity.

Major metals by inductively coupled plasma – mass spectrometry

(ICP-MS): Al, Cd, Co, Cu, Fe, Mn, Ni, Pb, Sb, Zn, U.

Parameters identified as potential contaminants of concern include SO4, Fe, Co, Ni.

In addition to the parameters detailed above, Point 2, adjacent to Adit 5

should be monitored on a quarterly basis for:

BTEX (benzene, toluene, ethylbenzene and xylenes);

EPH (extractable petroleum hydrocarbons);

GRO (gasoline range organics);

DOC (dissolved organic carbon);

COD (chemical oxygen demand); and

E. coli.

Samples will be submitted to a SANAS accredited laboratory within

recommended holding times.

Water quality results will be compared to the water quality objectives

(WQO) developed as part of this EIA process rather than to existing

national screening levels. These screening levels are intended to be used to

assess the quality of water in natural surface water systems.

All monitoring records will be stored in a database which is routinely

updated, maintained, and includes all metadata associated with the

monitoring activities.


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The monitoring programme and data will be reviewed annually and

amended if necessary.

The contribution of surrounding land uses will be considered when

conducting the sampling and analysis described above. In particular this

will include the impact of farming and animal husbandry on water

quality.

Figure 8.2 Surface Water Monitoring Points

Source: ERM, 2015


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8.2 GROUNDWATER MONITORING

Monitoring of groundwater is required for the following purposes:

1. To detect impacts on groundwater quantity and quality timeously.

2. To assess whether the mitigation/management measures provided in

Chapter 7 are effective, supporting the update of mitigation measures

where necessary.

3. To support adaptive management in which the numerical groundwater

model can be updated based on new information increasing its confidence

level and then used to predict groundwater impacts and assist with social

and biodiversity impacts and closure planning. With updated high

confidence predictions the mine can act in a pre-emptive manner, thus

reducing risks, rather than acting in hindsight when monitoring data

reveals a problem.

4. To interrogate unknowns identified in this report, in which various field

investigations can be carried out to test and improve the conceptual

hydrogeological understanding of the aquifer system.


It is recommended that groundwater monitoring, particularly in areas down-

gradient of the Central Discard Dump, begin before the construction phase in

order to establish the baseline conditions, i.e. to obtain data regarding the

natural response of the aquifer/s, as well as to detect any changes in

groundwater quality. Monitoring is important because early detection of

potential impacts on surface and groundwater could potentially be managed

through intervention measures before large scale remediation is required.

Kangra Coal currently has a groundwater monitoring programme where

groundwater quality and quantity monitoring is undertaken on a quarterly

basis. It is recommended that this monitoring programme be expanded to

include the Central Discard Dump area (Table 8.4 and Figure 8.3).

Table 8.4 Proposed Groundwater Monitoring Points

Borehole ID Description Coordinates

Latitude Longitude

MONBH03*

Objective: Groundwater

monitoring of deeper fractured

rock aquifer.

Decision: Possible water quality

contribution from existing

Maquasa East mining

operation/s, located to the east of

the proposed Project site.

-27.01316278 30.38823781


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MONBH03-s


monitoring of shallow weathered

aquifer.



Maquasa East mining operations,

located to the east of the

proposed Project site.

-27.01286489 30.38821928

MONBH04*



rock aquifer. Early warning

system with regards to the

ephemeral down-gradient Egude

flow system.


contribution from proposed

pollution control system and

from existing Maquasa East

mining operation/s, located to

the east of the proposed Project

site.

-27.00548839 30.40287769

MONBH04-s



aquifer. Early warning system

with regards to the ephemeral

down-gradient Egude flow

system.



pollution control system and

from existing Maquasa East

mining operation/s, located to

the east of the proposed Project

site.

-27.00554303 30.40298822

MONBH05*



rock aquifer. Early warning

system with regards to the

ephemeral down-gradient Egude

flow system.



discard storage facility and from

existing Maquasa East mining

operations, located to the east and

west of the proposed Project site.

-27.01305328 30.38175961


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MONBH05-s



aquifer. Early warning system

with regards to the ephemeral

down-gradient Egude flow

system.



discard storage facility and from

existing Maquasa East mining

operations, located to the east and

west of the proposed Project site.

-27.0131345 30.38175917

MONBH06-s



aquifer.



Maquasa West mining

operations, located to the south /

southwest of the proposed Project

site.

-27.020133 30.39105172

MONBH06-d



rock aquifer.



Maquasa West mining



site.

-27.02017214 30.38139819

MONBH07-s



aquifer.



Maquasa West mining



site.

-27.00294139 30.39114436

MONBH07-d



rock aquifer.



Maquasa West mining



site.

-27.00297833 30.39133558


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Notes:

Coordinates Projection: Universal Transverse Mercator

Datum: WGS84

-s Shallow monitoring borehole, with depths less than ~20 mbgl

-d Deep monitoring boreholes, with depths greater than ~20 mbgl.

* existing monitoring boreholes (constructed)

Source: GCS, 2016

Groundwater quantity (i.e. levels) and quality monitoring should continue to

be undertaken on a quarterly basis, unless indicated otherwise in the

environmental authorisations (ROD, or IWUL).

Groundwater samples should be collected by an independent groundwater

consultant, using best practice guidelines and should be analysed by a SANS

accredited laboratory. The recommended parameters for groundwater quality

analysis are listed in Table 8.2.

It is recommended that the groundwater monitoring network database is

updated quarterly as information becomes available, analysed and evaluated;

and, reported to the authorities (during construction, operational and closure

phases).

In addition to the above, it is recommended that a monitoring response

protocol is developed in the event of groundwater quality deterioration.

Figure 8.3 Proposed Groundwater Monitoring Locations

Source: GCS, 2016


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8.2.2 MWE Underground Works

Each of the individual fountains and streams proposed for monitoring must

be incorporated into the monitoring system as soon as mining commences in

the respective sub-catchment area of that fountain or stream. If a mining

impact is suspected, the monitoring system must be expanded to include all

the fountains listed and streams included in Figure 8.4, as well as all fountains

and streams where specific complaints arise.

Table 8.5 Fountains to be monitored

Nr on Map Y X Farm Nr

MWG-FII 62493.28 2990975.43 19HT

MWG-F37 63091.17 2990906.51 19HT

MWG-F39 63131.43 2991109.39 19HT

MWG-F40 63135.30 2991330.73 19HT

MWG-F60 66299.75 2988409.76 381 1T

MWG-F63 64671.59 2988308.61 18HT

MWG-F64 64099.55 2988285.96 18 HT

MWG-F65 64085.76 2988107.88 18HT

MWG-F80 64629.87 2993185.79 20HT

MWG-F81 64825.25 2993210.83 20HT

EF-1 67231.29 2991474.52 15HT

EF-2 67279.66 2991521,32 15HT

EF-4 67437.65 2992219.14 15 HT

BF-1 68816.15 2993985.14 34HT

BF-2 67958.69 2994210.92 34HT

Source: Oryx Environmental, 2006

Table 8.6 Streams to be monitored

Nr on Map Y X Farm Nr

MWS-S3 65588.25 2987165.94 381 IT

MWS-S5 61045.94 2991644.42 19HT

MWS-S8 61099.06 2988232.32 18 HT

MWS-S9 62717.21 2994405.25 20HT

ES-15 67449.935 2987361.505 15HT


Figure 8.4 Localities of proposed fountains and streams to be monitored



The Groundwater Monitoring Plan has been developed taking into account

the best practice guidelines for water monitoring in the South African mining

industry (DWAF, 2008). The measurement of water levels and collection of

groundwater samples discussed in this section will proceed according to the

best practice for monitoring methods, as outlined by Weaver (2007).

The groundwater monitoring plan is presented in Table 8.7.

Table 8.7 Groundwater Monitoring Plan

BHID Latitude Longitude Type Primary Purpose

Water Level

Monitoring

Frequency

Flow Rate

(Yield)

Monitoring

Frequency Water Quality Monitoring Frequency

RMBH3

27° 2'10.96"S 30°18'50.65"E

Recommended shallow (10 – 20 m) monitoring BH Water quality impact related to adit

facilities

Monthly Quarterly

RMBH4

27° 2'2.73"S 30°18'42.09"E

Recommended shallow (10 – 20 m) monitoring BH Water quality impact related to adit

facilities

Monthly Quarterly

Notes: BH Borehole


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The monitoring plan is a living document that needs to be updated as

monitoring data and modelling results are generated. Details in support of

Table 8.7 are listed as follows:

Each borehole was selected in order to monitor mining related risks to

particular aquifers, including dewatering risks and impacts to

groundwater quality.

Monitoring boreholes installed by ERM have been selected for monitoring.

ERM recommends installation of additional monitoring boreholes to

provide increased coverage in certain areas, referred to in Table 8.7 as

RMBH3 to RMBH4. The approximate location of these boreholes is shown

in Figure 8.5.

In addition to the existing boreholes and the recommended new boreholes,

Kangra Coal will monitor selected private boreholes, springs and surface

water abstraction points as a risk management measure in order to ensure

a reliable and complete dataset of water levels and water chemistry exists

for these holes.

The frequency of water level measurement is divided between monthly

(manually with a water level or ‘dip’ meter), and continual (automatically

on 1-hour readings, with pressure loggers installed in the borehole).

Certain boreholes are selected for continual measurement for improving

the conceptual understanding of aquifer behaviour. In private boreholes,

water level measurement is not possible because the boreholes are not

accessible for these measurements.

Spring flow should be monitored monthly, with field measurements of

pH, EC, temperature and DO being conducted at the same time.

If any of the currently selected monitoring boreholes should run dry due

to groundwater drawdown, replacement boreholes will be drilled to a

greater depth.

Groundwater quality in monitoring wells will be monitored quarterly and

private boreholes, springs and surface water abstraction points will be

sampled 6-monthly. Monitoring frequency will reviewed once monitoring

data is available.

Sampling protocols as detailed in Weaver (2007) should be followed. In

particular, for groundwater and spring water the following will be

undertaken:

pH and EC will be monitored in the purge water in the field until they

stabilise prior to collecting a sample; and


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Samples for trace element analysis will be appropriately filtered and

acidified in the field to ensure results are representative of dissolved

species in the aquifer.

Samples will be submitted to a SANAS accredited laboratory within

recommended holding times.

The list of chemical constituents to be analysed will be routinely updated

based on previous results. Parameters to be tested include, but are not

limited to:

pH, EC and TDS.

Major constituents - Cl, SO4, NO3, total N, F, Ca, Mg, Na, K, total

alkalinity.

Major metals by inductively coupled plasma – mass spectrometry

(ICP-MS): Al, Cd, Co, Cu, Fe, Mn, Ni, Pb, Sb, Zn, U.

Parameters identified as potential contaminants of concern include

Sulphate, Iron, Cobalt Nickel.

In addition to the parameters detailed above, recommended boreholes

RMBH3 and RMBH4 downgradient of Adit 5 should be monitored for:

EPH (extractable petroleum hydrocarbons);

GRO (gasoline range organics);

DOC (dissolved organic carbon);

COD (chemical oxygen demand); and

E. coli.

Water quality results will be compared to the water quality screening

levels developed as part of this EIA process rather than to existing national

screening levels.

All monitoring records will be stored in a database which is routinely

updated, maintained, and includes all metadata associated with the

monitoring activities.

The monitoring programme and data will be reviewed by an independent

hydrogeologist annually and amended if necessary.

Figure 8.5 Groundwater monitoring points

Source: ERM, 2015


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8.3 AQUATIC BIOMONITORING

Monitoring of the environment prior to the start of activities (establishment of

baseline conditions) and continued monitoring throughout the life of the

operation will help identify environmental impacts by identifying and

tracking potential pollution trends. The monitoring data collected will also

provide input into the planning for closure at the end of the life of the facility.


Biomonitoring was not previously undertaken within the catchments where

the Maquasa East and West mines are located, therefore no historical data is

available. Suitable sites for biomonitoring were located during the Wetland

and Aquatic Assessment undertaken by GCS during 2015 (GCS, 2016).

The aquatic biomonitoring surveys of the aquatic invertebrate community

(SASS5) at the locations identified during the assessment should continue on a

biannual basis. It would also be beneficial to conduct Whole Effluent Toxicity

(WET) testing, bioaccumulation in crabs and sediment samples at the

identified sampling points. This would enable a more accurate interpretation

of the ecological status of the affected catchment areas.

The locations which should be monitored, specifically with respect to the

Central Discard Dump, are included in Table 8.8 and Figure 8.6.

Table 8.8 Proposed Aquatic Biomonitoring Sites

Site Description Coordinates Current

Status Latitude Longitude

K1

This is the most upstream site, situated on a

small tributary above disturbed mining area

(Maquasa West pit).

27° 1'16.14"S 30°21'58.13"E Sampled

K2

This site is situated directly below mining

area (Maquasa West Pit) and next to

transport road and conveyor belt. On small

tributary of the Egude River.

27° 1'2.61"S 30°22'12.82"E

Insufficient

Habitat for

SASS5

K3

Site is situated on a tributary of the Egude

River below a weir. Site is situated

downstream of Maquasa West shaft.

27° 0'31.88"S 30°22'22.81"E Sampled

K4

Site is situated on the Egude River below the

upstream tributary. Area is characterised by

wetland vegetation types.

26°59'54.94"S 30°23'9.03"E Sampled

K5

Site is situated on the Egude River below

small tributary. The site is below an

identified wetland / floodplain area.

27° 0'53.59"S 30°22'49.66"E Sampled

K6 Site is situated on tributary of the Egude

River above wetland / floodplain area. 26°59'53.52"S 30°22'40.58"E Sampled

K7

Furthest downstream site situated on the

Egude River. Site is located at the edge of

the Driefontein Township.

26°59'49.56"S 30°24'21.28"E Sampled


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Site Description Coordinates Current

Status

K8

Site is located to the south of the mining

area on a small tributary to the Mpundu

River.

27° 2'15.48"S 30°23'4.65"E Sampled

Source: GCS, 2016

Figure 8.6 Proposed Biomonitoring Sites

Source: GCS, 2016


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Water quality should be regularly monitored and appropriate and timeous remedial interventions made in the case of non-compliance.

Quarterly monitoring of aquatic ecosystems should be conducted in order to ensure that they stay in their current unimpacted state. Appropriate and timeous remedial interventions should be made in cases where aquatic ecosystems are seen to be deteriorating.

Careful monitoring is needed to ensure erosion nick points (e.g. around gabions) are detected and managed. Sediments eroded from remaining stockpiles should be minimized and prevented from reaching watercourses.

8.4 AIR QUALITY MONITORING


Dust monitoring is required at the mine site, as well as in the vicinity of the

Central Discard Dump. The following dust buckets are located within the

vicinity of the Central Discard Dump:

Dust Yende family: -27.01660°-30.33352°E; and Community 1: --27.016283°S; -30.370031°E

It is recommended that two additional monitoring points are established at

the southern and northern boundaries of the Central Discard Dump.

The dust buckets should be monitored on a monthly basis and reports

compiled on a quarterly basis.


Air quality impacts as result of the operation of Adit 5, the overland conveyor

and servitude road are predicted to be moderate; this is mainly influenced by

sensitive receptors around the project site. Fine particulates (specifically PM10)

and ambient dustfall monitoring is recommended to ascertain the modelling

results. Monitoring should commence during the construction phase and

continue throughout the life of the project. The monitoring programme is

designed to assist in the decision making process around the implementation

of mitigation, verify the efficiency of mitigation measures and ensure that

unacceptable impacts are not arising at nearby sensitive receptors.

Monitoring effort should be focused on the areas defined in Figure 8.7, where

simulated concentrations exceed the PM10 daily standard of 75 µg/m³, such as

at receptors C88, C90 and C72. PM10 monitoring should be undertaken using

devices that are recognised by the DEA for compliance purposes. In this

regard, gravimetric sampling (filter-based methods) is required. The use of

“mini-vol”, filter based sampling requires the daily changing of filters.

Appendix A of the Air Quality Specialist Report (Annex 5B) provides a


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detailed discussion regarding the various types of PM10 monitors on the

market.

During the construction phase the monitoring data should be reviewed on a

daily basis; and during the operational phase, should be considered on a

monthly basis. Where PM10 emissions associated with the site are above the

National Ambient Air Quality Standards (NAAQS), investigations should be

made into the sources of emissions and measures implemented to manage

emissions.

Dustfall monitoring should be carried out using the American Society of

Testing and Materials (ASTM) methodology. The apparatus for monitoring

consists of a bucket approximately 150 mm in diameter and 300 mm deep in

which dust is collected for a period between 28 and 33 days. Solid matter

larger than 2 mm in size (insects etc.) is removed by screening. The remaining

solid matter is washed from the bucket, filtered and weighed. Use of this

method will ensure that sampled dustfall rates are comparable to the National

Dust Control Regulations (NDCR). A dustfall monitoring network should be

expanded to include areas around sensitive receptors, conveyor route and

material handling points. Indicatives sites are illustrated in Figure 8.7. The

proposed monitoring locations may be revised annually or as project phases

and operational areas change, this will assist in obtaining a good baseline and

also identify areas where mitigation measures should be focused.

During the construction and operational phases the monitoring data should be

reviewed on a monthly basis by the environmental manager. Where dust

emissions associated with the site are above NDCR’s residential and non-

residential limits, investigations should be made into the sources of emissions

and measures implemented to manage emissions.

Monitoring will serve to meet objectives such as:

Compliance monitoring;

Validate dispersion modelling results;

Use as input for health risk assessment;

Assist in source apportionment;

Temporal trend analysis;

Spatial trend analysis;

Source quantification; and

Tracking progress made by control or mitigation measures.

Figure 8.7 Air Quality indicative monitoring network

Source: Airshed, 2015


8-27

8.5 NOISE MONITORING

Quarterly noise measurements are recommended to be conducted by an

acoustical specialist for the duration of the operation. This acoustical

specialist, along with Kangra Coal, must determine where noise monitoring is

required and develop a site specific monitoring plan considering the selected

and implemented mitigation measures.

Quarterly noise measurements should also be collected in 10-minute bins over

a period of at least 24 hours during the construction, decommissioning and

closure phases.

Measurements should be collected as defined by SANS 10103:2008 (or any

future updates) using instruments as defined in the National Noise Control

Regulations (or any future promulgated laws).

8.6 SOILS

The project area has a distinct rainy and dry season. It is recommended that

the erosion monitoring programme will include two rounds of evaluation per

year during construction and operations (January and June) to determine if

any seasonal variations do occur. Thereafter, annual monitoring will take

place once per year, preferably at the end of the dry season before the start of

the rainy season (August).

Each monitoring round should include a physical observation and reporting

of the following:

Evidence of erosion or land degradation;

Condition of access roads;

Condition of cleared areas;

Condition of perimeter drains (if installed) and associated settlement

ponds (if installed); and

Compliance with applicable regulatory and corporate requirements.

8.7 GENERAL SITE MONITORING AND REQUIREMENTS

8.7.1 Rehabilitation Progress

The post-construction and post-decommissioning rehabilitation requires

monitoring of the progress/success of the rehabilitation efforts. This

monitoring will involve the inspection of areas which have been disturbed,


8-28

eroded or rehabilitated which should be documented to provide a photolog of

the area.

Vegetation monitoring will assist in determining whether further

rehabilitative measures need to be implemented and if alien plant control

interventions have been successful or if they need to implemented more

intensively.

Alien and invasive species monitoring and control should be done on a

quarterly basis during the entire life of the facility.

8.7.2 Reporting

Monitoring reports must be compiled and submitted to the relevant authority.

These include:

Surface water and groundwater monitoring reports must be compiled on a

quarterly basis, with one annual report being compiled at the end the year.

All reports must be submitted to the relevant officials at the DWS and

DMR.

Aquatic Biomonitoring Reports must be compiled on a bi-annual basis and

submitted to the relevant official at the DWS.

Air Quality Monitoring Reports must be compiled on a quarterly basis and

submitted to the relevant official at the DEA (if requested).

8.7.3 Environmental Performance Audits

Performance assessment audits are required in terms of Regulation 55 (1) of

the MPRDA Regulations, GR527. In order to comply with this regulation, the

following will be undertaken:

Monitoring will be conducted on ongoing basis.

Performance assessments of the approved EMPr will be undertaken by

Kangra Coal on an annual basis, with an external performance assessment

audit every two years. The annual performance assessment will be

undertaken by a suitably qualified person, while the audit will be

undertaken by a qualified, independent third party.

Submission of an annual performance assessment report to the Director:

Minerals at the DMR.

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