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Magdalena Colliery Discard Dump Extension,

Dannhauser, KwaZulu-Natal

Environmental Management Programme

Version – 1

13 September 2014

Zinoju Coal (Pty) Ltd

DAEA Reference Number: DC25/0018/2012

GCS Project Number: 12-094

Zinoju Coal (Pty) Ltd Magdalena Colliery Discard Dump Extension: EMP

Magdalena Colliery Discard Dump Extension, Dannhauser, KwaZulu-Natal:

Environmental Management Programme

Draft Report

Version – 1

13 September 2015

Zinoju Coal (Pty) Ltd

12-094

Report Issue Draft

GCS Reference Number GCS Ref – 12-094

Client Reference 12-094

Title Addendum to the Environmental Management Programme of Magdalena Colliery to incorporate the extension to the Discard Dump Facility

Name Signature Date

Author Christopher Wright

28 Feb 2015

Document Reviewer Russell Stow Kelly Taylor

13 Sept 2015

Director Pieter Labuschagne

13 Sept 2015

LEGAL NOTICE

This report or any proportion thereof and any associated documentation remain the property of GCS until the mandator effects payment of all fees and disbursements due to GCS in terms of the GCS Conditions of Contract and Project Acceptance Form. Notwithstanding the aforesaid, any reproduction, duplication, copying, adaptation, editing, change, disclosure, publication, distribution, incorporation, modification, lending, transfer, sending, delivering, serving or broadcasting must be authorised in writing by GCS.

12-094 14 September 2015 Page ii


CONTENTS PAGE

CONTENTS PAGE ................................................................................................................................ 1 LIST OF TABLES ................................................................................................................................... 1 1 PROJECT DESCRIPTION ............................................................................................................... 2

1.1 INTRODUCTION ............................................................................................................................. 2 1.2 PROJECT LOCATION ........................................................................................................................ 3 1.3 REFERENCE DOCUMENTS ................................................................................................................ 5

2 PROJECT DESCRIPTION ............................................................................................................... 6 3 OBJECTIVES AND PRINCIPLES.................................................................................................... 10

3.1 OBJECTIVES OF THE EMP .............................................................................................................. 10 3.2 ENVIRONMENTAL PRINCIPLES AND BEST PRACTICE GUIDELINES ............................................................ 11

4 DETAILS OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER ............................................. 12 5 IDENTIFICATION OF ENVIRONMENTAL IMPACTS ...................................................................... 12

5.1 CONSTRUCTION PHASE ................................................................................................................. 12 5.2 OPERATIONAL PHASE ................................................................................................................... 13 5.3 DECOMMISSION AND CLOSURE PHASE ............................................................................................. 13 5.4 NO-GO ALTERNATIVE ................................................................................................................... 17 5.5 POSITIVE IMPACTS ....................................................................................................................... 18

6 IMPLEMENTATION INSTRUCTIONS ........................................................................................... 18 6.1 DUTY OF CARE AND REMEDIATION OF DAMAGE ................................................................................ 18 6.2 COMPLIANCE WITH OTHER POLICIES AND LEGISLATION ....................................................................... 18 6.3 APPROVALS ................................................................................................................................ 19 6.4 ENVIRONMENTAL AWARENESS AND COMPLIANCE .............................................................................. 19 6.5 PROPOSED MECHANISMS FOR MONITORING COMPLIANCE AND PERFORMANCE ASSESSMENT .................... 20 6.6 AMENDMENTS TO THE EMP .......................................................................................................... 20 6.7 ROLES AND RESPONSIBILITIES ......................................................................................................... 20

7 ENVIRONMENTAL MANAGEMENT PROGRAMME ..................................................................... 21 8 CONCLUSION ............................................................................................................................ 24

LIST OF TABLES Table 1: Identified Listed Activities in terms of the EIA Regulations to date ................... 2 Table 2: Details of Environmental Practitioner ...................................................... 12 Table 3: Summary of Potential Construction Impacts .............................................. 14 Table 4: Summary of Potential Operational Impacts................................................ 15 Table 5: Summary of Potential Closure and Rehabilitation Impacts ............................. 17 Table 6: Contact Details of Responsible Parties ..................................................... 20 Table 7: Environmental Management Programme for Discard Dump Extension. ............... 22

12-094 14 September 2015 Page 1


1 PROJECT DESCRIPTION

1.1 Introduction

Zinoju Coal (Pty) Ltd (hereafter referred to as Zinoju) proposes the extension of the existing

discard dump facility at Magdalena Colliery, located approximately 25km north-northwest of

the town of Dundee, GPS Co-ordinates: 27° 56' 55.64”S; 30° 10' 39.28”E, KwaZulu-Natal. The

project is located within the magisterial district of Amajuba and the local Municipality of

Dannhauser in the KwaZulu-Natal Province (Figure 1).

In terms of the National Environmental Management Act, 1998 (Act No. 107 of 1998)

(NEMA), the proposed extension is listed as an activity that may be detrimental to the

environment and thus, requires authorisation from the Department of Economic

Development, Tourism and Environmental Affairs (DEDTEA), previously the KwaZulu-Natal

Department of Agriculture and Environmental Affairs (DAEA) before operations can

commence. The activities associated with the project are listed under both Government

Notice Regulations (GNR) 544 (Listing Notice 1) and GNR 545 (Listing Notice 2) and as such

require an application for Environmental Authorisation in the form of a full Environmental

Impact Assessment Process (EIA). Zinoju has appointed GCS as the Environmental Assessment

Practitioner (EAP) to undertake the EIA for the project and submit an application for

Environmental Authorisation (EA) to the DAEA. As part of this application process, an

Environmental Management Programme (EMP) (this document) has been developed in

compliance with Section 33 of GN. R543 of the 2010 Environmental Impact Assessment (EIA)

Regulations.

The relevant activities in terms of the Environmental Impact Assessment (EIA) Regulations

(Dated 2 August 2010) under NEMA are listed in Table 1 below:

Table 1: Identified Listed Activities in terms of the EIA Regulations to date

Activity No. Listed activity Description of the activity

15

Physical alteration of undeveloped, vacant or derelict land for residential, retail, commercial, recreational, industrial or institutional use where the total area to be transformed is 20 hectares or more; Except where such physical alteration takes place for:

• Linear development activities; or • Agriculture or afforestation where

activity 16 in this Schedule will apply.

The clearing and transformation of approximately 36ha of undeveloped land/veld for the Discard Dump extension.



1.2 Project Location

The Discard Dump is located at the Magdalena Colliery which is approximately 25km north-

northwest of the town of Dundee located on the Rem. of Farm Magdalena No. 7574 and

approximately 325km east-northeast of the City of Durban, in the province of KwaZulu-Natal.

The Colliery is located in the magisterial district of Amajuba and the local municipality of

Dannhauser. A locality map is presented in Figure 1. The Discard Dump extension is proposed

to be located contiguous to the existing Discard Dump and will be extended into Portion 1 of

the farm Mooidoorn Hoek No. 3722 as shown in Figure 3-2. Farm Magdalena No. 7574 is owned

by the Mchunu family and Portion 1 of Farm Mooidoorn Hoek No. 3722 is owned by Zinoju

Coal.

The proposed site for the discard dump extension at Magdalena is previously disturbed, and

was previously used for grazing by the local people surrounding the Magdalena Colliery.

Certain portions of the land have evidence of misuse in terms of large erosion gullies and

overgrazing. Local access roads are present throughout the site.



Figure 1: Locality Map of the Proposed Magdalena Discard Dump Extension



1.3 Reference Documents

This EMPr forms part of the Environmental Impact Assessment (EIA) submission for the

Environmental Authorisation of the Proposed Extension of the Discard Dump at Magdalena

Colliery. As such, the following documents have relevance and reference to this EMPr but

have not been included to minimise repetition:

Zinoju Coal (2002) Approved Environmental Management Programme: Coal Mining: Zinoju-

Magdalena.

Zinoju Coal (2008). Magdalena Colliery Extension Project - Environmental Management

Programme Report

GCS (Pty) Ltd (2015). Addendum to the Environmental Management Programme of Magdalena

Colliery to Incorporate the Extension to the Discard Dump Facility. 12-094

GCS (Pty) Ltd (2015). Proposed Magdalena Colliery Discard Dump Extension: Draft

Environmental Impact Assessment Report. 12-094

Inclusive of the following specialist studies:

• GCS (Pty) Ltd (2006). Proposed Magdalena Colliery Discard Facility Results Of

Geotechnical Investigation.

• AfriCan Innovative (2008). Magdalena Colliery, Coal Discard Facility. Report Number:

Report No. AISP 7-3/01.

• AfriCan Innovative (2012). Draft Design Report. Forbes Coal New Discard Dump.

Report Number: AISP/FBC/P12/10/02.

• GCS (Pty) Ltd (2013). Magdalena Discard Dump Extension Groundwater Assessment.

• GCS (Pty) Ltd (2013). Hydrological Assessment for the Magdalena Discard Dump

extension.

• Zunckel Ecological and Environmental Services (June 2013). Preliminary Ecological

Assessment for the Proposed Extension Of The Magdalena Colliery Discard Dump,

Dannhauser Municipality (Kz254).

• Themtek (2014). A Report on Possible Measures to Conserve the Thukela Agate Snail

[Cochlitoma Simplex (Smith, 1878)] on Portion 1 of the Farm Mooidoorn Hoek No.

3722, Magdalena Colliery, Dundee, Kwazulu-Natal.

• Themtek (2014). Results of A Reconnaisance Soil Survey Undertaken to Determine

Possible Measures to Conserve the Thukela Agate Snail [Cochlitoma Simplex (Smith,

1878)] on Portion 1 of the Farm Mooidoorn Hoek No. 3722, Magdalena Colliery,

Dundee, KwaZulu-Natal.



2 PROJECT DESCRIPTION

2.1 Existing Mining Operation

The existing Magdalena Colliery is operated by Forbes Coal (Pty) Ltd. The mineral deposit

extracted at the Magdalena Colliery is coal from two seams. The sub outcrop of the top seam

(Alfred) and the bottom seam (Gus). Mining occurs by opencast method using the sequential

roll over method and underground bord and pillar method accessed by an Adit system from an

old opencast high wall. The production rate of the mine is planned to increase to 152 000 Run

of Mine (ROM) tons per month. The life of the mine is expected to be 17 years.

The ROM from the underground operation is washed and screened at the washing plant

situated within the central section of the Magdalena site. The washed product is stockpiled

alongside the processing plant ready for distribution. The coal is transported from here by

road to the markets with a portion of the product being taken to the Coalfields site ready for

distribution by rail. All ROM from the open cast operation is however taken straight to the

Coalfields plant for washing and processing.

The site’s existing discard dump is located to the south of the washing plants. Deposition is by

upstream mechanical tipping truck. The dump maintains five metre wide berms at every 5

metres vertical lift to enable access by tipper trucks. However, Forbes is planning on creating

higher terraces of 13m. Slope stability is maintained by an overall slope of 1 in 3. Pollution

control measures are installed to ensure clean and dirty water separation such as cut off

trenches. An under drainage system is used to collect seepage.

The existing discard dump takes coal discard from both the Magdalena and Aviemore

collieries. Presently, the discard dump is nearing capacity and needs to be extended to

ensure disposal capacity requirements of the life of the mine for both these operations. The

existing dump has a design life of 3 years and storage capacity of circa 2 million tonnes

(53000 tonnes per month) and is therefore not sufficient to accommodate the life of mine

requirements. Therefore, it is proposed to extend the discard dump to achieve a design life

of 22 years with a maximum storage capacity of 9.5 million cubic metres. Refer to Figure 2

for the proposed discard dump extension layout.



Figure 2: Proposed Magdalena Discard Dump Extension Layout



2.2 Proposed Discard Dump Extension

The existing discard dump is 3.33ha in extent and is proposed to be extended (increased in

size) by approximately 36ha. The details of the discard dump extension have been taken

from the Draft Design Report prepared by AfriCan Innovative dated 19 June 2012. The

proposed project will involve establishment of the following:

1. New tailings storage facility (extension to existing)

2. Return water dam

3. Decant system

4. Under drainage

5. Clean and dirty water separation canals

6. Solution trench

7. Access road

2.2.1 Tailings Storage Facility (Discard Dump Extension)

The proposed geometry was influenced by the existence of underground mine workings to

the east of the discard dump extension stretching from the north to the south. The design

criteria are as follows:

• Type of facility: Coal discard dump

• Design life of mine: Estimated at: 22 years

• Tonnage production per year: 640 000t

• Assumed in-situ density: 1.469tm-3.

• Total tonnage in life of mine: 14 080 000t

• Total volume of residue: 9 584 751.5m3

2.2.2 Return Water Dam

The return water dam design will be designed to adhere to the National Water Act (1998)

and SANS 10286: 1998 regulations, and therefore the criteria for the design of the same are

as follows:

• Design return period: I:100year

• Design flood: 146.2mm

• Required volume: 14 500m3

• Freeboard: 0.8m

• Depth including freeboard: 4m



The return water dam will be designed with a clay / HDPE composite liner in line with

statutory requirements for surface and ground water pollution control.

Due to the topography of the site, two return water dams will be designed: one with a

capacity of 8000m3 and the other for a capacity of 7500m3. Under normal operations, the

volume of water in the return water dam will be kept not more than 4 000m3.

2.2.3 Decant System

The coal will be deposited in “dry” state and as such, no conventional decant system will be

designed for this project. However, momentary rising of the water table can be expected

from seepage especially after a prolonged low frequency storm. Thus, supernatant (surface)

water will need to be drained off the top of the dump as soon as possible. To achieve this,

an “emergency type” pump budge will be utilised. The system must be sized to decant a 24

hour 1:100 year storm in not more than 72 hours (three days).

2.2.4 Under Drainage

Previous site studies have indicated that the water table is high and that there is need for

pollution control measures to ensure seepage does not come into contact with groundwater

under the impoundment. The topography of the site is such that seepage flows downhill.

Thus, an under-drainage system will be incorporated at the toe to capture all seepage and

also help with consolidation necessary for strength gain and stability of the discard dump.

The system will consist of perforated or slotted geo-pipes just behind the starter push-up

walls connected to out-falling solid pipes discharging into the solution trench and then to the

return water dam.

2.2.5 Clean and Dirty Water Separation Canals

To prevent the contamination of stormwater, cut off trenches will be excavated in phases on

the upstream of the facility to divert “clean” storm water received on the upstream

catchment to the stream without passing through the contaminated site. The positions of

the storm diversion trenches will be clearly marked on the detailed layouts.

2.2.6 Solution Trench

The solution trench will be designed to contain flows resulting from the cumulative effects

of the seepage from the under drains and discard dump supernatant water resulting from a

1:100 year 24 hour storm.

2.2.7 Access Road

Since the envisaged method of deposition is upstream mechanical tipping by truck, the



impoundment has been designed with five metre wide berms at every five metre vertical lift

to enable access by tipper trucks at any point around the dam. Maintenance shall follow

procedures stipulated in the Operations Manual to ensure access under any weather

conditions and at any time.

2.2.8 Method of Deposition

The method of deposition will be by upstream mechanical tipping truck which is the current

method of deposition. In addition, 5 metre wide berms will be created at every 5 metres

vertical lift to enable access by tipper trucks. Slope stability will be maintained by an overall

slope of 1 in 3.

Pollution control measures such as cut off trenches will be installed to ensure clean and

dirty water separation. In addition, an under drainage system will be used to collect seepage

as process water which will initially be directed to a Return Water Dam.

3 OBJECTIVES AND PRINCIPLES

3.1 Objectives of the EMP

The purpose of the EMP is to manage the impacts associated with the construction,

operational and closure activities within the Magdalena Colliery Discard Dump Extension

project. Environmental impacts and associated mitigation measures and recommendations

identified during the course of the EIA are included to ensure they are adopted and

implemented. In addition, the EMP is designed to assist Zinoju and their contractor/s to

plan and implement effective site-specific strategies that will minimise the potential

environmental impacts associated with their activities and maintain compliance with

environmental legislative requirements. This EMP serves as a stand-alone document to be

disseminated to, and used by, the contractor/s and project managers during all phases of

the project. By its very nature, the EMP is a dynamic document and updating may be

required (with written approval from the DAEA).

Note that should the authorisation from the DEDTEA be granted for the project, this

document is to be updated with any specific conditions contained therein.

The purpose of the EMP is to:

• Promote understanding of the common environmental impacts associated with the

construction and possible mitigation measures.



• Ensure that the construction activities associated with the project are undertaken

in a controlled and organised manner, thereby managing and minimising potential

environmental and social impacts.

• Encourage good management practices through planning and commitment to

environmental issues.

• Outline the developer’s environmental management commitments for the site.

• Recognise health and safety issues related to the project.

• Act as a performance standard that activities can be audited against.

• Provide rational and practical environmental guidelines to:

- Minimise disturbance of the natural environment.

- Prevent or minimise all forms of pollution.

- Comply with all applicable laws, regulations, standards and guidelines for

the protection of the environment.

- Adopt the best practicable means available to prevent or minimise adverse

environmental impacts.

- Develop waste management practices based on prevention, minimisation,

recycling, treatment or disposal of waste.

- Describe all monitoring procedures required to identify impacts on the

environment.

3.2 Environmental Principles and Best Practice Guidelines

• The environment is considered to be composed of both biophysical and social

components.

• Construction is a disruptive activity and all due consideration must be given to the

environment, including the social environment during the execution of the project

to minimise the impact on affected parties.

• Minimisation of areas disturbed by construction activities (i.e. the ‘footprint’ of the

construction area) should minimise many of the construction related environmental

impacts of the project and reduce rehabilitation requirements and costs.

• All relevant standards relating to international, national, provincial and local

legislation, as applicable, should be adhered to. This includes requirements relating

to waste generation and emissions, waste disposal practices, noise regulations, road

traffic ordinances, etc.

• Every effort should be made to minimise, reclaim and/or recycle waste materials.



4 DETAILS OF THE ENVIRONMENTAL ASSESSMENT PRACTITIONER

Table 3 below provides details of the Environmental Assessment Practitioner (EAP) who

prepared this report.

Table 2: Details of Environmental Practitioner

Business name of EAP: GCS Water and Environmental Consultants (Pty) Ltd

Contact: Russell Stow

Physical address: 4a Old Main Road, Judges Walk, Kloof, 3610

Postal address: PO Box 819, Gillitts, South Africa

Postal code: 3603 Cell: 083 633 7636

Telephone: 031 764 7130 Fax: 031 764 7140

E-mail: [email protected]

5 IDENTIFICATION OF ENVIRONMENTAL IMPACTS

The negative environmental impacts and issues identified to date have been summarized

into the following categories:

5.1 Construction Phase

The construction phase consists of the following activities that may give rise to

environmental impacts:

• Construction of:

o tailings Storage Facility

o return water dam;

o under drainage;

o cut-off trenches and storm water berms

o Clean and Dirty Water Separation Canals;

o pollution control dam (s);

o Solution trench; and

o Access and haul roads

o Footprint area clearance.

o The maintenance and upgrading of the total clean water and dirty water

diversion trenches; and

o Handling of truck fuel and oil spills.



5.2 Operational Phase

During the operational phase of the proposed discard dump at Magdalena Colliery the

following activities that may impact on the health and social aspects of the surrounding

communities will occur:

• Use of slurry ponds to collect and keep or dam all the coal slurry coming from coal

mining and preparation processes;

• Use of return water to receive and temporarily store storm run-off from the slurry

dams;

• Maintenance and inspection of slurry dams, return water dam and the effluent

trench on a regular basis (deficiencies will be rectified immediately) and

• Stockpiling and transporting of coal discard material.

5.3 Decommission and Closure Phase

Closure for mining activities is highly important as far as the environmental factors are

concerned. If mitigation measures are not followed properly it could have devastating

impacts. As closure without mitigation factors could have permanent impacts on the

environment. The decommissioning of the proposed Magdalena Discard Dump extension will

form part of the mine closure.

The mine will be required to apply for a Closure Certificate according to Section 43 of the

MPRDA. Section 43 (1) of the MPRDA stated that “the holder of a … mining right …remains

responsible for any environmental liability pollution or ecological degradation, and the

management thereof, until the Minister has issued a closure certificate to the holder

concerned”.

During closure, most discard dump infrastructure will be dismantled and removed from site

and all disturbed areas will be rehabilitated, except a few roads remaining to provide

access for monitoring and follow-up rehabilitation.

It is therefore assumed that all environmental impacts will be successfully addressed and

managed at this phase. When the decision is taken to decommission the mine, the activities

below will be implemented:

• Dismantling of infrastructure / removal of infrastructure:



o Linear infrastructure constructed will be removed if it proves to inhibit land

use at decommissioning. Where possible, infrastructure will remain for

future operations as determined by Forbes Coal or future land use (social

investment opportunities). The soils and land capability will be

rehabilitated to near pre-mining conditions;

o All roads will be rehabilitated by ripping these structures to a depth of 500

mm; and

o All fences erected will be dismantled and either disposed of at a permitted

disposal site or sold as scrap (provided these structures will no longer be

required by the post-mining land owner). Fences erected to cordon-off

dangerous excavations will remain in place and will be maintained as and

when required.

• Removal of waste;

• Amelioration and vegetation of all disturbed areas;

• Maintenance the re-vegetated dump up until succession initiate to create a

sustainable cover;

• Monitoring of key environmental variables (i.e. soils, vegetation, groundwater and

surface water) in order to demonstrate stability of the rehabilitated dump;

• Weed management after closure, limited to discard dump activity affected area.

• Monitoring will be undertaken for a specific period after closure or up until the

discard dump area create a sustainable cover and ecosystem and

• Cessation of labor contracts.

• Rehabilitation of pollution control dams and reuse of water contained therein for

dust suppression.

• Surface and ground water monitoring.

A summary of the impact assessment ratings are tabulated below.

Table 3: Summary of Potential Construction Impacts

POTENTIAL ENVIRONMENTAL IMPACT ACTIVITY W/O M WM

SOILS Loss of soil resource and agricultural potential (grazing) / loss of soil profile. Construction activities. M M

AGRICULTURAL POTENTIAL AND LAND CAPABILITY Loss and reduction in agricultural potential and land capability.

Clearing of vegetation and disruption of soil profile. M L

VEGETATION

Vegetation clearing for the Discard Dump extension construction phase will result to complete loss of vegetation.

The secondary vegetation occurring within the extension footprint will be cleared and destroyed for construction activities.

H M

Alien vegetation proliferation and Without proper management, M L



encroachment. rehabilitation and monitoring, it is likely that the disturbed surfaces associated with the establishment, operation and closure of the Discard Dump will become preferential sites for the colonisation of exotic and alien invasive plant species.

FAUNA Loss of endemic snail species (Thukela Agate Snail).

Disturbance during land clearing of the construction phase. M M

Disturbance / migration of fauna resulting to loss of available habitat. Land clearing during construction phase. M L

SURFACE WATER Siltation of water resources and associated soil erosion. Construction activities. M L

GROUND WATER No particular impacts to groundwater during this phase. Construction activities.

AIR QUALITY / DUST CREATION Dust pollution and greenhouse gas emissions. Construction activities. M L

Degeneration in local air quality as a result of dust pollution and greenhouse gas emissions.

Construction activities. M L

NOISE POLLUTION Increased noise levels (Noise pollution) coming from construction activities. Construction activities. L L

Increased noise levels coming from transportation vehicles and machinery on site

Construction vehicles and machinery. L L

VISUAL INTRUISION

Disturbed Aesthetics. Vegetation creating during construction phase. M M

Dust pollution and Discard Dump view. Reduce exposed surface areas M M SOCIAL Degeneration in local quality of life as a result of dust pollution, noise pollution, and visual impacts.

Noise and dust during construction phase. L L

HEALTH IMPACTS Dust inhalation. Dust generated by construction activities L L

Table 4: Summary of Potential Operational Impacts

POTENTIAL ENVIRONMENTAL IMPACT ACTIVITY W/O M WM

SOILS Gully erosion. Construction activities. M M Loss of soil resource and loss of soil profile. All construction activities. M M

AGRICULTURAL POTENTIAL AND LAND CAPABILITY Loss of agricultural potential and land capability as a result change of land use and of disruption of soil profiles.

Disruption of soil profiles and change of land use from grazing land to mining land.

M M

Land use change from Agricultural / Wilderness to activities related to mining.

Discard Dump extension operational phase activities. M M

VEGETATION Loss of biodiversity – the dumping of mining discard on the proposed Magdalena Discard Dump Extension will result in complete loss of vegetation.

Discard Dump extension and associated activities. H M

FAUNA



SURFACE WATER Deterioration of surface water quality. Discard Dump contaminated run-off. L L

Siltation of water resources and stream peak flow reduction.

All operational activities - exposure of soil surface and ineffective rehabilitation.

M M

Pollution of water resources. All operational activities- discard deposition -risk of failure. M L

GROUND WATER Groundwater contamination via seepage from the Discard Dump.

Discard Dump Expansion and associated activities.

H M

AIR QUALITY / DUST CREATION

Dust generated by wind blowing over exposed soils and unprotected discard material.

The extension of the Discard Dump will increase the area of land susceptible to the generation of dust pollution. However, judging from the fact that the Discard Dump is not the large generator of dust, it is therefore anticipated that upon operation of the proposed Discard Dump extension, the dust levels may increase but will still remain within the prescribed limits.

M L

Degeneration in local air quality as a result of dust pollution and greenhouse gas emissions.

The extension of the Discard Dump will increase the area of land susceptible to the generation of dust pollution as well as increase the risk of spontaneous combustion and greenhouse gas emissions.

M M

NOISE POLLUTION Operators and residents close to the mine machinery and mining operation may be affected by the noise generated.

Trucks / transportation of coal discard during operation phase. M L

VISUAL INTRUISION

Disturbed aesthetics / All Discard Dump surface activities will be visible from a certain distance from the mine.

During operation, the dump will pose a visual impact to those rural residents that look onto the dump site and road users that regularly use the main road.

M M

Visual intrusion resulting from dust pollution and Discard Dump view.

Extension of the discard dump increases the surface area and creates more exposed areas to generate dust

L L

HERITAGE / ARCHAEOLOGICAL SITES None identified in this phase. SOCIAL Degeneration in local quality of life as a result of dust pollution, noise pollution, and visual impacts.

The extension of the Discard Dump. L L

Safety of children playing near/on proposed Discard Dump.

If unfenced, poorly graded and/or characterised by steep slopes, the dump may pose a safety risk to people traversing and/or playing on the dump, particularly children.

L L



Table 5: Summary of Potential Closure and Rehabilitation Impacts

POTENTIAL ENVIRONMENTAL IMPACT ACTIVITY W/OM WM

DECOMMISSIONING PHASE ACTIVITIES: REHABILITATION OF DISTURBED AREA AND CLOSURE

SOILS Soil profile and agricultural potential restored. Rehabilitation and closure activities. M

AGRICULTURAL POTENTIAL AND LAND CAPABBILITY Restoration of soils from stockpiles to pits, increasing soil capability for vegetation establishment.

Rehabilitation and closure activities. M

VEGETATION Seeding of all rehabilitated areas during the operational and decommissioning phase will ensure that a sustainable vegetation cover will establish in the proposed project area.

Discard Dump extension and associated activities. H

Alien vegetation proliferation and encroachment

Without proper management, rehabilitation and monitoring, it is likely that the disturbed surfaces associated with the establishment, operation and closure of the Discard Dump will become preferential sites for the colonisation of exotic and alien invasive plant species.

M L

FAUNA

Following rehabilitation of Discard Dump, animals will begin to migrate back into the area.

Rehabilitation and closure activities. H

SURFACE WATER Runoff and drainage from the rehabilitated Discard Dump may continue to yield polluted water.

Runoff from the rehabilitated Discard Dump. M L

GROUND WATER

Groundwater contamination via seepage from the Discard Dump.

Seepage from the rehabilitated Discard Dump.

M M


Dust inhalation. Rehabilitation and closure activities. L L

NOISE POLLUTION

Noise disturbance to local residents. Rehabilitation and closure activities. L L

VISUAL INTRUISION

Improved aesthetics Rehabilitation of the Discard Dump. M

5.4 No-Go Alternative

• Loss of Local Employment

• Soil Erosion and Habitat Degradation



5.5 Positive Impacts

A number of positive impacts have been identified in terms of beneficial environmental

changes resulting from mining activities on site. These are as follows:

• Local Employment

• Increase in Land Capability

• Soil Replacement

• Rehabilitation of Watercourses

6 IMPLEMENTATION INSTRUCTIONS

6.1 Duty of Care and Remediation of Damage

Zinoju, as the developer, is responsible for compliance with the provisions of duty of care

and remediation of damage in accordance with Section 28 of NEMA and its obligations

regarding the control of emergency incidents in terms of Section 30. Failure to comply with

this EMP will constitute an offence and Zinoju and/or their Contractor/s may be liable to

penalties and/or legal action. Therefore, it is important for all the responsible parties to

understand their duties and undertake them with duty and care.

6.2 Compliance with Other Policies and Legislation

The EMP has been developed in line with South Africa’s environmental legislation so as to

ensure that reasonable measures are taken to warrant environmental protection and to

promote sustainable development. The adherence of the contractors to the stipulations

outlined in this EMP will ensure compliance with the applicable legislation outlined below:

• The Constitution of the Republic of South Africa Act (No.108 of 1996).

• Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002).

• National Environmental Management Act (NEMA) (No.107 of 1998).

• National Environmental Management Waste Act (No. 59 of 2008).

• National Environmental Management Protected Areas Act (No. 57 of 2003).

• National Environmental Management: Biodiversity Act (No. 10 of 2004).

• Occupational Health and Safety Act (No. 85 of 1993) and regulations.

• National Water Act (No.36 of 1998).

• South African National Standards (SANS 10103:2008).

• The National Heritage Resources Act 25 of 1999.



• KwaZulu-Natal Heritage Act No. 10 of 1997.

• Animal Protection Act (No. 71 of 1962).

• Atmospheric Pollution Prevention Act (No. 45 of 1965).

• Conservation of Agricultural Resources Act (No. 43 of 1983).

• Hazardous Substances Act (No. 15 of 1973).

• National Veld and Forest Fire Act (No. 101 of 1998).

6.3 Approvals

A water use license amendment from the Department of Water Affairs is required to include

the potential water uses that will result from the discard dump extension activities. The

potential water uses to be included in the water use license amendment includes section

21(b),(c), (g) and (i) of the National Water Act. This license or approval is required prior to

construction commencing.

6.4 Environmental Awareness and Compliance

The philosophy adopted in this EMP is derived from the principles of the National

Environmental Management Act (No. 107 of 1998) (NEMA) which states that development

must be socially, economically and environmentally sustainable. Sustainable development

requires that:

• The disturbance of ecosystems and loss of biodiversity are avoided (minimised or

remedied).

• Pollution and degradation of the environment are avoided or minimised and

remedied.

• Waste is avoided or minimised and re-used or re-cycled where possible and

otherwise disposed of in a responsible manner.

• A risk averse and cautious approach is applied.

• Negative impacts on the environment and on people’s environmental rights be

anticipated and prevented, and where they cannot altogether be prevented, are

minimised and remedied.

NEMA makes provision that anyone who causes pollution or degradation of the environment

is responsible for preventing impacts occurring, continuing or recurring and for the costs of

repair of the environment.



6.5 Proposed Mechanisms for Monitoring Compliance and Performance

Assessment

Appropriate monitoring and review of the EMP is required to ensure effective

implementation of the EMP and to identify and implement corrective measures in a timely

manner. In the event where discrepancies are identified, the problem must be investigated

and attended to. All the results obtained during environmental monitoring must be

documented for audit purposes.

Compliance with the approved EMPR and EMPR Amendment has to be audited in terms of

the Mineral and Petroleum Resources Development Act (MPDRA), 2002 (R527 r55).

Specifically, the regulation requires that monitoring of the EMPR is undertaken on an

ongoing basis and performance assessments (audits) are undertaken every two years. The

continued appropriateness and adequacy of the EMPR needs to be evaluated during the

audits. The specifications contained within this EMP are included in the EMPR Amendment

to be submitted to the DMR, and will be audited against during the EMPR audits.

6.6 Amendments to the EMP

Amendments to the EMP may be required as the project proceeds. Any proposed

amendments to the EMP will be confirmed with Zinoju and the EAP prior to being issued as

a formal amendment to the DEDTEA. Copies of the amendments will be issued to all

relevant parties.

6.7 Roles and Responsibilities

The project applicant, Zinoju Coal (Pty) Ltd, will be ultimately responsible for

environmental management on site during all phases of the project. Contact details for

parties involved in the application and relevant authorities are outlined in Table 4 below.

Table 6: Contact Details of Responsible Parties

DEDTEA ASSESSING OFFICER PROPONENT Department of Economic Development, Tourism and Environmental Affairs (DEDTEA) Environmental Management Unit Ms S Myeza PO Box 170 Newcastle, 2940 Tel: 034 315 3936 Fax: 034 312 9986

Zinoju Coal (Pty) Ltd Mrs Pearl Nkosi Commercial Road Dundee 3000 Reg No.: 2001/011130/07 Tel: (034) 212 1455 Fax: (034) 212 1232



REPSONSIBLE PERSON – MINE MANAGER ENVIRONMENTAL ASSESSMENT PRACTITIONER

Mr Gideon Odendaal Magdalena Colliery P.O.Box 684 Dundee 3000 Tel: (034) 212 1455 Fax: (034) 212 1232

GCS Water and Environment (Pty) Ltd Mr Russell Stow Environmental Scientist Principal Environmental Scientist P.O. Box 819 Gillits, 3603 Tel: 031 764 7130 Fax: 031 764 7140 Email: [email protected]

MINE RIGHTS HOLDER Zinoju Coal (Pty) Ltd Commercial Road Dundee 3000 Reg No.: 2001/011130/07 Tel: (034) 212 1455 Fax: (034) 212 1232

7 ENVIRONMENTAL MANAGEMENT PROGRAMME

The management of Magdalena Colliery is committed to managing and rehabilitating the

mine area in a responsible manner. Magdalena Colliery will use cost effective Best Available

Technology (BAT) to adequately manage the mine so as to limit the negative environmental

impacts. These impacts may arise from normal mine operation or the expansion and

addition of mining infrastructure.

Where pertinent negative issues have been identified (impacts with a medium to high

significance), specific measures are presented to address the issue. For impacts not of a

significant nature, measures have been presented for the prevention of impacts as well as

the overall mitigation of impacts on specific biophysical and social aspects. Management

measures that the mine intends to implement are defined in terms of objectives. The

recommended management measures for each of the impacts are described in this section.

Management measures that the mine intends to implement are defined in terms of

objectives. The recommended management measures for each of the impacts are outlined

in Table 6-1 below.

NOTE: The management measures detailed below are specific to the extension of the

discard dump and are supplementary to those contained in the approved MPRDA EMPR

and Addendum.



Table 7: Environmental Management Programme for Discard Dump Extension.

POTENTIAL ENVIRONMENTAL IMPACT PHASE ACTIVITY MITIGATION MEASURES ACTION PLAN RESPONSIBLE PERSON

SOIL Loss of soil resource and agricultural potential (grazing) / loss of soil profile

Construction Construction of Discard Dump Minimise construction footprints and adhere to the action plan to minimise additional impacts.

Discard Dump construction area will be pegged and demarcated prior to construction activities commencing.

Environmental officer

Loss of Soils resources through erosion Construction/ Operation

Construction of Discard Dump Storm water Management to be integrated into Discard Dump

Storm water management will be implemented into design. Design Engineer

Loss of soil resource and agricultural potential (grazing) / loss of soil profile

Construction/ Operation

Construction of Discard Dump Topsoil should be stripped to a soil depth of 150mm from the extension areas and relocated into areas being re-vegetated or suitably stockpiled to be utilised during rehabilitation.

Topsoil will be stripped and stockpiled prior to construction. The stockpile sites must be recorded and mapped.


LAND USE

Reduction in agricultural potential and land capability.

Construction Clearing of vegetation and disruption of soil profile

Keep vegetation removal to a minimum. Discard Dump construction area will be pegged and demarcated. Environmental officer

VEGETATION

Vegetation clearing for the Discard Dump extension construction phase will result to complete loss of vegetation

Construction Vegetation clearing Relocate vegetation to the adjacent natural veld areas undergoing rehabilitation.

Relocate vegetation to adjacent areas. Environmental officer

Vegetation clearing for the Discard Dump extension construction phase will result to complete loss of vegetation

Construction Vegetation clearing The Contractor is to check that vegetation clearing has the prior permission of the Ecologist / ECO.

Ensure initial site clearance is supervised/authorised by environmental officer.


Alien vegetation proliferation and encroachment

Operation/ Closure

Disturbed surfaces associated with the establishment, operation and closure of the Discard Dump will become preferential sites for the colonisation of exotic and alien invasive plant species.

Implement alien plant eradication and control programme.

Implement alien plant eradication and control programme. Environmental officer

FAUNA

Loss of endemic snail species Construction Disturbance during land clearing of the construction phase

Secure an offset area following the Norms and Standards for Biodiversity Offsets: KwaZulu-Natal Province (EKZNW, Feb. 2013) to replace the loss of natural habitat and to ensure the persistence of the snail and potentially also the millipede and butterfly if they exist on site.

Ensure that an offset and translocation of any endemic snails occurs prior to the establishment of the Discard Dump.


Disturbance / migration of fauna resulting to loss of fauna in the area

Construction Land clearing during construction phase

Ensure footprint is kept as small as possible. Discard Dump construction area will be pegged and demarcated. Environmental officer

SURFACE WATER

Surface water and watercourse contamination


Prevent Spillage of fuel and oil. Refuelling and maintenance of machinery on Discard Dump prohibited. No long-term storage of any machinery should occur on the Discard Dump.

Ensure no maintenance or refuelling of vehicles occurs on the Discard Dump. All mechanical work must take place at designated workshops.

Environmental officer/ Contractors

Surface water and watercourse contamination

Operation Dirty water runoff from storm events

Ensure that clean and dirty water separation infrastructure is in place prior to the commencement of construction.

Ensure site is compliant with GN 704 requirements under National Water Act.


Siltation of Water resources and associated soil erosion.

Construction Discard Dump extension construction activities.

Ensure that clean and dirty water separation infrastructure is in place prior to the commencement of construction.

Ensure storm water design principles are implemented. Contractors

Slope Stability and Soil erosion Construction/ Operation

Discard Dump extension construction and operation activities.

Maintain berms and cut-off trenches. Regular monitoring of side slope stability. Run-off water from the Discard Dump will be stored on pollution control dams. Seepage will be pumped out via the under drainage system.

Slope stability to be monitored. Site must be assessed by a Geotechnical Engineer on an annual basis as per DMR requirements.

Geotechnical Engineer



POTENTIAL ENVIRONMENTAL IMPACT PHASE ACTIVITY MITIGATION MEASURES ACTION PLAN RESPONSIBLE PERSON

GROUND WATER

Groundwater quality Operation Mitigate seepage from Discard Dump facility

Compact Discard Dump in layers so that a 1% recharge is achieved. Normal recharge is 3 to 5%. Slope the dump to achieve maximum runoff and prevent ponding. Construct toe drains if groundwater levels increase to +5m from surface. Plant 5 rows of Eucalyptus trees to intercept any seepage from the dump. A full phyto-remediation program will be considered as part of the groundwater management system. Storm water management. Optimize water re-use. Line return water dams. Ongoing discard rehabilitation and looking at ways to re-use discard material.

Ensure design principles are implemented. Implement phytoremediation.

Contractor/ Environmental Officer


Dust pollution Construction Construction of Discard Dump Minimise dust generation by implementing dust suppression techniques including sprays. Ensure no slopes exceed 1:5 design. Extend dust monitoring network to the boundaries of the proposed Discard Dump area. Ensure discard is compacted.

Utilise dust suppression techniques. Ensure that dump is compacted. No slopes must exceed the 1:5 design criteria. Dust monitoring network must be extended to include Discard Dump.

Environmental Officer

NOISE POLLUTION

Increased noise levels (Noise pollution) Construction Construction activities Limit construction activities to the day time. Dumping to occur during daylight hours only. Environmental Officer

Increased noise levels coming from transportation of discard material.

Operation Construction vehicles and machinery

Equipment on site to be properly muffled and maintained so as to reduce noise generation.

Regular checks to be done on vehicles to ensure they are in good working order.

Environmental Officer

VISUAL INTRUISION

Disturbed Aesthetics Vegetation removal during construction phase

Keep vegetation removal to a minimum. Implement a complaints register and advise nearby residents of complaints procedures. Ensure mitigation measures are followed.

Social Manager

Dust pollution and Discard Dump view Reduce exposed surface areas Design infrastructure to take cognisance of the environment where possible.

SOCIAL

Degeneration in local quality of life as a result of dust pollution, noise pollution, and visual impacts.


Noise and dust during construction phase

Implement dust suppression measures. Extend air monitoring network to the proposed Discard Dump area. Limit construction activities to the day time.

Implement a complaints register and advise nearby residents of complaints procedures. Ensure mitigation measures are followed.

Social Manager

SAFETY

Safety of Discard Dump Operation Safety issues Ensure that warning signs and road safety measures are implemented.

Ensure that warning signs and road safety measures are implemented. Spot checks of vehicle speeds to be conducted.

Health and Safety Officer

Access to the site must be restricted, and the site must be fenced off.

Access to the site must be restricted, and the site must be fenced off. Health and Safety Officer

Ensure that all earth moving / mining vehicles use only dedicated access routes to mining areas.

Ensure that all earth moving / mining vehicles use only dedicated access routes to mining areas.

Health and Safety Officer



8 CONCLUSION

The implementation of this EMP will ensure that negative environmental impacts resulting

from the proposed project are minimised or prevented. It is the responsibility of the

applicant (Zinoju) to enforce the implementation of the EMP in conjunction with the

approved EMPR and current EMPR Amendment which forms part of the Magdalena Discard

Dump Extension.
