external environmental audits of the impumelelo colliery · 2020. 12. 15. · external...

Digby Wells and Associates

(South Africa) (Pty) Ltd

Company Registration: 2010/008577/07

Turnberry Office Park,

Digby Wells House.

48 Grosvenor Road,

Bryanston,2191

Phone: +27 (0) 11 789 9495

Fax: +27 (0) 11 789 9495

E-mail: [email protected]

Website: www.digbywells.com

Directors: J Leaver (Chairman)*,

NA Mehlomakulu*, A Mpelwane, DJ Otto,

M Rafundisani

*Non-Executive

External Environmental Audits of the Impumelelo Colliery

Environmental Audit Report

Prepared for:

Sasol Mining (Pty) Ltd

Project Number:

SAS6652

December 2020

mailto:[email protected]

DIGBY WELLS ENVIRONMENTAL

www.digbywells.com ii

This document has been prepared by Digby Wells Environmental.

Report Type: Environmental Audit Report

Project Name: External Environmental Audits of the Impumelelo Colliery

Project Code: SAS6652

Name Responsibility Signature Date

Anela Sotashe Report Compiler

November 2020

Justin du Piesanie Report Reviewer

November 2020

Mia Smith Senior Reviewer

December 2020

This report is provided solely for the purposes set out in it and may not, in whole or in part, be used for any other purpose

without Digby Wells Environmental prior written consent.


External Environmental Audit of the Impumelelo Colliery

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EXECUTIVE SUMMARY

Sasol Mining (Pty) Ltd (hereinafter Sasol Mining) appointed Digby Wells Environmental

(hereinafter Digby Wells) to undertake an environmental audit at the Impumelelo Colliery,

located near Greylingstad in the Mpumalanga Province. The independent external

environmental audit was undertaken in terms of Regulation 34 of the Environmental Impact

Assessment Regulations, 2014 (GN R982 of 04 December 2014, as amended) (the “EIA

Regulations, 2014”) promulgated under the National Environmental Management Act, 1998

(Act No. 107 of 1998) (NEMA). The Impumelelo Colliery holds an Environmental Authorisation

(EA) and associated Environmental Management Programme (EMPr) (Clean Stream, 2009)

for mining of coal and relevant listed activities.

The main objectives of this Environmental Audit Report are therefore to:

● Provide the Department of Mineral Resources and Energy (DMRE) and other relevant

stakeholders with appropriate information on the colliery’s compliance to stated

commitments;

● Determine the colliery’s level of compliance with the EA and EMPr and identify

potential non-compliances;

● Propose mitigation measures for environmental impacts not previously identified in the

EMPr and recommend measures to address areas of non-compliance; and

● Supply a basis for the initiation of corrective action where necessary or appropriate as

identified through the assessment.

An initial audit opening meeting was held on 21 October 2020, after which the site assessment

was completed from 21 to 23 October 2020 with the representatives from the Impumelelo

Colliery.

Compliance with the commitments of the both the EA and EMPr were rated using the

evaluation criteria described in the table below.

Evaluation Criteria

Not Compliant

(NC)

These areas were found non-compliant as observed during the site visit with the

commitments of EMPr conditions.

Compliant (C) These are areas of complete fulfilment of the stated commitment/ requirement.

Not Applicable

(N/A)

These areas which were found not to be relevant to the operations at this phase

of the activity, i.e. pre-construction, construction and decommissioning phase

commitments.



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The table shows the percentage of non-compliances, compliances and commitments that are

no longer applicable on both the EA and EMPr. Detailed tables of the conditions and the audit

findings can be found in Section 9 of this report.

Overall Compliance for Impumelelo Colliery

Total

Number of

Conditions

Total

Compliance

Total Non-

Compliances

Total Not

Applicable

Total

possible

score

Score

EA 84 57 3 24 60 95%

EMPr 328 196 39 93 235 83.4%

Summary of the Findings

The main findings and areas of non-compliance included the following:

● Erosion was noticed at various areas, including at the Sewage Treatment Plant (STP),

the outlet of the stormwater drain and at the reservoirs. This is due to the lack of

vegetation. Erosion was also noted along the Sasol Coal Supply (SCS) conveyor as a

result of steep slopes and lack of stability measures;

● Contaminated water (oily water) was observed in clean water areas on site;

● Various oil spills were noticed on the paved areas where vehicles are parked;

● The general housekeeping around the site was found to be insufficient. Stormwater

drains were clogged with mixed mine waste, thus preventing the flow of water through

the system. Clean and dirty water drains were not separated; and

● Dirty oily rags were found in clean water trenches. Sediment and coal dust was also

observed in clean water trenches during the time of audit.



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TABLE OF CONTENTS

1 Introduction ....................................................................................................................... 8

2 Project Description ............................................................................................................ 8

3 Terms of Reference .......................................................................................................... 8

4 Details and Declaration of the EAP ................................................................................. 10

5 Scope and Purpose of the Audit ..................................................................................... 10

6 Methodology.................................................................................................................... 11

6.1 Audit Initiation Meeting .......................................................................................... 11

6.2 Site Assessment and Interviews ............................................................................ 12

6.3 Site Observations .................................................................................................. 12

6.3.1 Sewage Treatment Plant ............................................................................... 12

6.3.2 Waste Management ....................................................................................... 13

6.3.3 Bunker and the Conveyor .............................................................................. 14

6.3.4 Pollution Control Dam .................................................................................... 15

6.3.5 Hydrocarbon Spillages ................................................................................... 16

6.4 Document Review ................................................................................................. 17

6.5 Performance Assessment and Reporting .............................................................. 19

7 Evaluation of the Relevance and Effectiveness of the EMPr .......................................... 19

8 Assumptions, Uncertainties and Gaps in Knowledge ..................................................... 19

9 Audit Findings ................................................................................................................. 20

9.1 Detailed Audit Findings.......................................................................................... 20

9.2 Summary of Level of Compliance .......................................................................... 54

10 Conclusion and Findings ................................................................................................. 54



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LIST OF FIGURES

Figure 6-1: Sewage Treatment Plant ................................................................................... 13

Figure 6-2: ISO Yard (Waste Management area) ................................................................ 14

Figure 6-3: SCS Conveyor Infrastructure ............................................................................ 15

Figure 6-4: Silt trap and PCD .............................................................................................. 16

Figure 6-5: Hydrocarbon Spillages ...................................................................................... 17

LIST OF TABLES

Table 3-1: Contents of the Report as per Appendix 7 of the EIA Regulations, 2014 .............. 9

Table 4-1: Details of the EAP .............................................................................................. 10

Table 6-1: Auditors’ Details ................................................................................................. 11

Table 6-2: Interviewed Personnel during the Compliance Audit .......................................... 12

Table 6-3: Evaluation Criteria .............................................................................................. 19

Table 9-1: Assessment of Compliance to the Operational Requirements of the EA ............ 21

Table 9-2: Assessment of Compliance to the Operational Requirements of the EMPr ........ 29

Table 9-3: Compliance Rating: EA and EMPr ..................................................................... 54



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LIST OF ACRONYMS AND ABBREVIATIONS

DEDET Department of Economic Development, Environment and Tourism

Mpumalanga

Digby Wells Digby Wells Environmental

EA Environmental Authorisation

EAP Environmental Assessment Practitioner

EIA Environmental Impact Assessment

EIA Regulations,

2014

Environmental Impact Assessment Regulations, 2014 (GN R982 of 04

December 2014, as amended)

EMPr Environmental Management Programme

IMP Integrated Management Plan

IWWMP Integrated Water and Waste Management Plan

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

2002)

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

ROM Run of Mine

RSIP Rehabilitation Strategy and Implementation Plan

PCD Pollution Control Dam

ROM Run of Mine

Sasol Mining Sasol Mining (Pty) Ltd

SOP Standard Operating Procedure

STP Sewage Treatment Plant

WUL Water Use Licence



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1 Introduction

Sasol Mining (Pty) Ltd (hereinafter Sasol Mining) appointed Digby Wells Environmental

(hereinafter Digby Wells) to undertake an audit at the Impumelelo Colliery, located near

Greylingstad in the Mpumalanga Province. The independent external environmental audit was

undertaken in terms of Regulation 34 of the Environmental Impact Assessment Regulations,

2014 (GN R982 of 04 December 2014, as amended) (the “EIA Regulations, 2014”)

promulgated under the National Environmental Management Act, 1998 (Act No. 107 of 1998)

(NEMA). The Impumelelo Colliery holds an Environmental Authorisation (EA) and associated

Environmental Management Programme (EMPr) (Clean Stream, 2009) for mining of coal and

relevant listed activities.

2 Project Description

Sasol Mining developed the Impumelelo Colliery as an underground bord and pillar operation,

with the intention to satisfy the existing Sasol Synfuels market after the closure of the

Brandspruit Colliery. Impumelelo is located southwest of Secunda, east of Greylingstad and

northwest of Standerton. An Environmental Authorisation (EA) was granted for the Impumelelo

Colliery by the Mpumalanga Department of Economic Development, Environment and

Tourism Mpumalanga (DEDET) on 11 August 2010 and amended on 12 December 2011.

The Sasol Coal Supply (SCS) blending plant is located near the Brandspruit Colliery. To

deliver coal to the blending plant, Sasol Mining has constructed a conveyor belt (the “SCS

Conveyor”) from the Impumelelo Colliery to the plant. The SCS Conveyor servitude includes

a service road, water pipelines, as well as power and communication lines.

Process water transfer pipelines have been installed between the Impumelelo Colliery and

Brandspruit. All effluent water captured at the Impumelelo Colliery is disposed of via concrete-

lined trenches to containment dams. The colliery currently operates three dams 7 and 84

megalitre (Mℓ) where all effluent water and water that has been removed from the underground

workings is collected and stored. This water is reused as process water as far as possible.

Water from these dams is also transferred to the Brandspruit Colliery and SCS blending plant

to be used in the coal-washing process where required.

3 Terms of Reference

The environmental audit is a systematic, periodic, objective and documented evaluation of the

continued relevance and effectiveness of the contents of an EA and approved EMPr, as well

as the execution thereof.

This Environmental Audit Report has been compiled to comply with Regulation 34 of the EIA

Regulations, 2014 (as amended). Compliance of this Environmental Audit Report with

Appendix 7 of the EIA Regulations, 2014 is summarised in Table 3-1.



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Table 3-1: Contents of the Report as per Appendix 7 of the EIA Regulations, 2014

No. Requirement Section of this Report

Content of the Environmental Audit Report

3 (1) (a)

An environmental audit report prepared in terms of these

Regulations must contain (a) details of-

i. the independent person who prepared the

environmental audit report; and

ii. The expertise of independent person that compiled

the environmental audit report.

See 4: Details and

Declaration of the EAP

3 (1) (b) A declaration that the independent auditor is independent in

a form as may be specified by the competent authority.

See 4: Details and

Declaration of the EAP

3 (1) (c) An indication of the scope of, and the purpose for which,

the environmental audit report was prepared.

See Section 5: Scope

and Purpose of the

Audit.

3 (1) (d) A description of the methodology adopted in preparing the

environmental audit report.

See Section 6:

Methodology.

3 (1) (e)

An indication of the ability of the EMP, and where

applicable, the closure plan to

i. sufficiently provide for the avoidance, management

and mitigation of environmental impacts associated

with the undertaking and closure of the activity on an

on-going basis;

ii. Ensure compliance with the provisions of the EA, EMP,

and where applicable, the closure plan.

See Section 7:

Evaluation of the

Relevance and

Effectiveness of the

EMPr.

3 (1) (f) A description of any assumptions made, and any

uncertainties or gaps in knowledge.

See Section 8:

Assumptions,

Uncertainties and

Effectiveness of the

EMPr

3 (1) (g)

A description of any consultation process that was

undertaken during the course of carrying out the

environmental audit report.

Consultation with Site

staff was undertaken.

No consultation with

the public was

undertaken as part of

this audit. 3 (1) (j)

A summary and copies of any comments that were received

during any consultation process; and

3 (1) (k) Any other information requested by the competent

authority. None.



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4 Details and Declaration of the EAP

Sasol Mining appointed Digby Wells as the independent Environmental Assessment

Practitioner (EAP) to undertake the environmental audit. Details and experience of the person

who compiled this report are provided in Table 4-1 below.

Table 4-1: Details of the EAP

Name Mia Smith

Qualifications MSc Geography (University of Johannesburg)

EAPASA Registration No. 2019/1282

Experience 13 years

Company Digby Wells and Associates (South Africa) (Pty) Ltd

Telephone 011 789 9495 Email: [email protected]

I, Mia Smith, herewith declare that:

● I act as the independent environmental practitioner in this Audit;

● I will perform the work relating to the Audit in an objective manner, even if this results

in views and findings that are not favourable to the Holder;

● I declare that there are no circumstances that may compromise my objectivity in

performing such work;

● I have expertise in conducting environmental audits, including knowledge of the Act,

Regulations and any guidelines that have relevance to the activity;

● I have no, and will not engage in, conflicting interests in the undertaking of the audit;

● declare that all the information furnished by me in this application are true and correct;

● I will perform all other obligations as expected from an environmental assessment

practitioner in terms of the Regulations; and

● I realise that a false declaration is an offence in terms of section 24F of the Act.

Signature of the EAP:

Date: December 2020

5 Scope and Purpose of the Audit

An Environmental Audit Report must determine compliance with the EA and EMPr and the

appropriateness and adequacy of the EA and EMPr through on-going assessment.

mailto:[email protected]



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The objectives of the Environmental Audit Report are to:

● Report on the level of compliance with the conditions of the EA and the EMPr and the

extent to which the avoidance, management and mitigation measures provided for in

the EMPr are implemented;

● Identify and assess any new impacts and risks as a result of undertaking activities at

the colliery;

● Evaluate the effectiveness of the EMPr;

● Identify shortcomings in the EMPr; and

● Identify the need for any changes to the avoidance, management and mitigation

measures provided for in the EMPr.

6 Methodology

The methodology used in the undertaking of the environmental audit was as follows:

● Review of the conditions of the EA and EMPr commitments;

● Review of all documentation required to assess compliance with the EA and EMPr;

● Undertake a site visit of the colliery from 21 to 23 October 2020 to identify instances of

compliance and non-compliance with the EA and EMPr; and

● Compilation of this Environmental Audit Report.

6.1 Audit Initiation Meeting

An initial audit opening meeting was held on 21 October 2020, after which the site assessment

was completed from 21 to 23 October 2020 with representative of the Impumelelo Colliery.

The meeting was attended by the Digby Wells Auditors and representatives of the Impumelelo

Colliery, which are listed in Table 6-1 and Table 6-2.

Table 6-1: Auditors’ Details

Digby Wells Auditors Qualifications

Carol Hooghiemstra MSc (Environmental Management)

BSc Hons (Agriculture)

BSc (Agriculture)



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Stephanie Aken BSc Hons, PG Diploma Environmental Management

Anela Sotashe BSc (Environmental Studies)

Tshepiso Ratlagane BSc Hons (Environmental and Water)

Table 6-2: Interviewed Personnel during the Compliance Audit

Impumelelo representatives Position and Department

Duane MacPherson Environmental Control Officer

Boipelo Mongale SHE

Johan Rensberg Survey

Mxolisi Motshwane SHE

JR Phiri Engineer

D Mapleeson Environmentalist

Lawrence Maben Production

6.2 Site Assessment and Interviews

During the site assessment, the auditors undertook interviews, reviewed relevant

documentation and completed an inspection of the site.

The following areas were assessed by the auditors:

● Sewage Treatment Plant (STP);

● Waste Management Area (ISO yards);

● Pollution Control Dam (PCD);

● Bunker area and emergency stockpile;

● Overland conveyor belt and its servitude; and

● Contractors yards.

6.3 Site Observations

Observations made during the site assessment undertaken from 21 to 23 October 2020 are

presented in the section below.

6.3.1 Sewage Treatment Plant

The STP is well fenced and access is controlled. Sewage is treated and the treated effluent is

discharged to the environment and later make its way to the farm dam situated outside of the

boundaries of the Impumelelo Colliery. However, Proxa was appointed to operate and

maintain the STP and conduct monthly samples of the treated effluent.



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Figure 6-1 below shows the components of the STP. The dried sludge is removed from the

sludge drying bed and stored in hazardous waste bins, which are later removed by a

contractor.

Aerator

Chlorine tank

Balancing tanks

Dried Sludge

Figure 6-1: Sewage Treatment Plant

6.3.2 Waste Management

All waste types at the Impumelelo Colliery is collated and stored at the ISO yard where it gets

sorted into different waste streams. The ISO yard is concreted and separated into the different

waste streams, e.g. recyclable waste, domestic waste and hazardous waste, plastic waste,

cable waste, steel waste, rubber waste, old oil, wood, as well as geological core waste.

Hazardous waste is contained in skips that are covered by a roof to prevent ingress of

rainwater. Figure 6-2 below provides few waste types that are generated and found at the

Impumelelo Colliery.



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ISO Yard

Pastic waste

Cable waste

Figure 6-2: ISO Yard (Waste Management area)

6.3.3 Bunker and the Conveyor

All dirty runoff from the bunker area and emergency throw-out area is diverted to the 84 Mℓ

PCD. This water is then used underground for dust suppression and for other mining

purposes.

Runoff from the bunker is diverted through a silt trap which is inspected and cleaned on a

regular basis. The drains and the silt trap were maintained to ensure that the runoff from the

emergency throw-out area will be contained. The silt trap is concrete lined.

The overland conveyor conveys the coal mined at the Impumelelo Colliery to the SCS site

where it is blended and conveyed to the Sasol Synfuels Operations. Due to unavailability of

responsible people from SCS and time constraints, the total length of the conveyor was not

visited (see Figure 6-3).



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Shaft

Silt trap

Conveyor belt

Figure 6-3: SCS Conveyor Infrastructure

6.3.4 Pollution Control Dam

All PCDs are locked to prevent unauthorised entrance to these dams and prevent any potential

harm to people and animals. Signage indicating persons in charge and the risks associated

are adequately displayed at the entrance to the PCDs. These PCDs are kept at 30% or less

to avoid overflows; however, no overflow was reported since the commencement of the

operation. The silt traps are used to trap coal sediments in water that is pumped from the

underground mine workings, as well as the bunker. Overflow from the silt traps make its way

to the PCD. The silt trap is inspected on a weekly basis; however, the silt trap was not in good

condition at the time of the site visit, as it appeared to be overflowing (Figure 6-4).



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Silt trap

Pollution control dam

Figure 6-4: Silt trap and PCD

6.3.5 Hydrocarbon Spillages

Housekeeping throughout the shaft area were not of a high standard. Various spillages (i.e.

hydrocarbon and fine coal) were noticed which were not cleaned immediately after the spill,

as indicated in Figure 6-5 below.



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Figure 6-5: Hydrocarbon Spillages

6.4 Document Review

The auditors conducted a document review based on the commitments set out in the EA and

commitment contained in the EMPr. The following documents are considered as relevant to

the audit and these were provided and reviewed during and/or after the site assessment. The

following documentation was reviewed and available in an electronic format device:

● IsoMetrix checklist of the Impumelelo EMPr;

● IsoMetrix checklist of the Impumelelo EA;

● EA approval dated 15 September 2010;



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● EA Amendment approval dated 12 December 2011;

● EMPr dated 06 July 2010;

● Impumelelo Colliery: Environmental Noise Monitoring Survey 2019;

● Job Cards generated for the maintenance of the 7 megalitre (Mℓ) dam;

● Job Cards generated for the maintenance of the 84 Mℓ dam;

● Job Card: Inspection on erosion;

● Job Card generated for the inspection on LHD 0218;

● SCS Job Card inspection of the silt traps and trenches;

● Job Card created for the pipeline inspection;

● Job Card generated on visual inspection of V drain;

● Certificates of Safe Disposal (Interwaste Environmental Solution);

● SCS Integrated Management Plan (IMP): 16 March 2020;

● SCS IMP: 10 March 2020

● Proof of submission of the Environmental Performance Assessment and EA audit

report for Impumelelo Mine dated 20 April 2020;

● Training records January to December 2019;

● Mine Water Balance (m3/d) for 01 January 2020 to 27 May 2020;

● External EMP Performance Assessment Report, 2019 compiled by Digby Wells

Environmental;

● External EA audit 2019, compiled by Digby Wells Environmental;

● Impumelelo Incident Register, 2020;

● Monitoring Reports;

● Integrated Water Monitoring and Reporting Programme: Brandspruit Colliery:

Impumelelo Mine (License No: 08/C12D/ABCEFGIJ/2160), dated 30 September 2020;

● Impumelelo Integrated Water Monitoring Report covering the period January 2020 to

June 2020;

● Integrated water use license (Licence No. 08/C12D/ABCEFGIJ/2160), Bi-annual

Report, dated August 2020;

● Biomonitoring Assessment: Impumelelo Coal Conveyor, Dry Season Survey 2019;

● Biomonitoring Assessment: Impumelelo Coal Conveyor and D714 road, Wet Season

Survey 2019;

● 2013 Annual External Audit to determine compliance with Water Use License issued

to Sasol Mining Impumelelo Mine, dated 30 September 2014;



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● Rehabilitation Strategy and Implementation Plan (RSIP) for Impumelelo Shaft (2020);

and

● Integrated Water and Waste Management Plan, 2019 to 2020.

6.5 Performance Assessment and Reporting

Table 6-3 summarises the scoring system the auditors used to measure compliance with the

conditions contained in the both the EA and EMPr.

Table 6-3: Evaluation Criteria

Not Compliant

(NC)

These areas were found non-compliant as observed during the site visit with the

commitments of EMPr conditions.

Compliant (C) These are areas of complete fulfilment of the stated commitment/ requirement.

Not Applicable

(N/A)

These areas which were found not to be relevant to the operations at this phase

of the activity, i.e. pre-construction, construction and decommissioning phase

commitments.

Compliance is evaluated by determining the total number of conditions to be complied with,

excluding those conditions deemed not applicable. Where conditions are identified as “not-

applicable” reasons for excluding the condition from the assessment are provided.

The overall compliance score is then calculated as a percentage of the total possible

compliance score.

7 Evaluation of the Relevance and Effectiveness of the EMPr

In the opinion of the auditor, the EMPr provides comprehensive requirements for achieving

environmental objectives and clear monitoring and reporting requirements. However,

duplication of conditions and commitments within the EA and EMPr have been noted.

Conditions pertaining to subsidence were found to not be applicable during the environmental

audit; however, they may be relevant at a later stage of the Operational Phase.

8 Assumptions, Uncertainties and Gaps in Knowledge

The following assumptions, uncertainties and gaps in knowledge are applicable to this environmental audit:

● The findings recorded in this Environmental Audit Report are limited to the

observations made at the mining areas inspected from 21 to 23 October 2020;

● Areas identified by the audit team in conjunction with the operation were visited and

are referred to in this report;

● The full extent of the conveyor route was not inspected due to the unavailability of

responsible people from SCS and time constraints; and

● This audit was undertaken in terms of the approved EMPr dated 15 September 2010.



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9 Audit Findings

9.1 Detailed Audit Findings

Table 9-1 below presents the detailed audit findings against compliance against the EA;

whereas Table 9-2 contains detailed audit findings against each condition of the Operational

Phase of the EMPr.



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Table 9-1: Assessment of Compliance to the Operational Requirements of the EA

Condition Compliance

Rating Audit Comments Proof of Compliance

3.1 Authorization of the activity is subject to the conditions contained in

this authorization that are part of the environmental authorization and

are legally binding on the holder of the authorization.

C

This condition is noted. N/A

3.2 The holder of the authorization must ensure compliance with the

conditions by any person acting on his or her behalf, an agent, sub-

contractor, employee or person rending a service to the holder of the

authorization.

C


3.3 The activities that are authorized may only be carried out at the

property indicated in the Environmental Authorization. C


3.5 Any changes to, or deviations from, the project description set out in

this authorization must be approved, in writing, by the Department

before such changes or deviation may be affected. In assessing whether

to grant such approval or not, the Department may request such

information as it deems necessary to evaluate the significance and

impacts of such changes or deviations and it may be necessary for the

holder of the authorization to apply for further authorization in terms of

the regulations.

C


3.6 These activities must commence within a period of (2) years from

the date of issue. If commencement of the activity does not occur within

that period, the authorization lapses and a new application for

environmental authorization must be made in order for the activity to be

undertaken.

C


3.7 The authorization does not negate the holder of the authorization,

responsibility to comply with any other statutory requirements that may

be applicable to the undertaking of the activities.

C


3.8 The holder of the authorization is responsible for the compliance

with the provisions for Duty of Care and Remediation of Environmental

Damage contained in Section 28 of the National Environmental

Management Act, 1998 (Act 107 of 1998).

C


3.9 The holder of the authorization must notify every registered

interested and affected party, in writing and within seven (7) calendar

days, of receiving notice from the Department's decision to authorize the

activities.

C


3.10 a) The notification referred to above must:

a) Specify the date on which the authorization was issued;C


3.10 b) Inform the interested and affected parties of the appeal

procedure provided for in chapter 7 of the regulations; and C






3.10 c) Advise the interested and affected parties that a copy of the

authorization and reasons for the decision will be furnished on request. C


3.11 The EMPr in the EIA Report must be implemented and strictly

adhered to throughout the life cycle of these activities. C

The EMP and its conditions are implemented and audited against by

way of the audit conducted on site. An audit was previously

conducted by Digby Wells in November 2017 and November 2019.

External EMP Performance Assessment Report, 2019 compiled

by Digby Wells Environmental.

3.12 The applicant must appoint an independent Environmental Control

Officer (ECO) that will have the responsibility of implementing the EMPr

and ensuring compliance with the conditions of this environmental

authorization. C

Emile Blaauw (SHE Professional Services) was appointed as ECO at

the commencement of the construction phase. Digby Wells was

provided with proof of appointment of Themko Mavuso in October

2014 and Mirie Grant who replaced Themko Mavuso in February

2015 as the ECO at the operation.

Currently the responsibility of implementing the EMP lies with the

Impumelelo Environmental Practitioner as the project is in its

Operational Phase.

Letter dated 22 September 2020. Appointment letter of an ECO.

3.12.1 The ECO must be appointed before the commencement of

construction and the Department must be notified of such an

appointment for communication purposes.

C

Letters communicating the appointment of Themko Mavuso, Mirie

Grant and Emile Blaauw were submitted to the Department.

Letter dated 22 September 2020. Appointment letter of an ECO.

3.12.2 The ECO must submit quarterly compliance reports to the

Department in writing and copy the applicant with such reports. The

reports must include a description of all activities on site, problems

identified, transgressions noted and remedial action implemented. All

reports must reflect the Department's reference number of the project on

the cover page.

C

The ECO submits the quarterly compliance report to the Department

biannually. Proof of submission to the department was available at

the time of audit.

Proof of submissions.

3.12.3 The ECO must be available on site during the evaluation,

monitoring and implementation of the Environmental Plan and; C

The appointed ECOs and now Impumelelo Environmental

Practitioner is available on site to evaluate, monitor and implement

the conditions of the EA and EMP.

Site observations.

3.12.4 Act as a guide, advisor and consultant to the contractor and client

on environmental issues during construction. C

The appointed ECOs discussed environmental issues during weekly

operations meetings with contractors and Sasol Mining personnel.

This is now the responsibility of the Impumelelo Environmental

Practitioner.

Site observations.

3.13 Ground water monitoring boreholes must be monitored bi-annually

at least once in summer and once in winter to avert any potential danger

to the livestock farming activities down slope of the activities.

C

Groundwater monitoring boreholes are monitored bi-annually. A

biannual report is compiled and this is then submitted to the

Department of Water and Sanitation (DWS).

Impumelelo Integrated Water Monitoring Report covering the

period of January 2020 to June 2020.

3.14 Monitoring site for soil sampling must be established to monitor any

chemical changes in the soil profile- such sampling sites must be

established downstream of the neighbouring farms.

N/A

This condition is only applicable to the construction phase, which has

been completed.

N/A

3.15 Monitoring of dust, baskets must be in placed in various strategic

positions around the site.

C

Dust fallout monitoring is undertaken on a regular basis and no

exceedances of the non-residential dust fallout limit have been noted.

In addition, the ROM stockpile is visually monitored on a daily basis

to detect wind dispersion of dust. Dust suppression will only be done

when needed.

Dust fallout monitoring results, 2020. Interview with the ECO.



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3.16 The monitoring of the fuel tanks must take place on a continuous

basis and should any product be encountered the oil company must be

informed immediately to undertake integrity tests and/or remedial action. C

The ECO indicated that fuel tanks are being monitored by visual

inspections. The fuel bay is built according to Sasol best practice.

Bund walls will contain more than 110%, the current legal

requirement.

Site observations, interview with ECO.

3.17 The holder of the authorization must submit an environmental

compliance audit report to the Department within 30 days of completion

of construction. The environmental Audit report must be compiled by an

independent auditor, and must indicate the date of the audit, the name

of the auditor and the outcome of the audit in terms of compliance with

the conditions of this authorization.

N/A


been completed.

N/A

3.18 The Department retains the right to monitor and/ or inspect the

proposed project during both construction and operational phases. N/A


3.19 Fourteen (14) days written notice must be given to the Department

that the activity will commence. Commencement for the purposes of this

condition includes site preparation. The notice must include a date on

which it is anticipated that the activity will commence.

N/A

The DEDET was informed of the commencement of the authorised

activities for the Impumelelo Mine on 17/02/2019.

Letter to DEDET dated 17/02/2019.

3.20 In the event of any runnels or erosion channels developed during

the construction period, they must be backfilled and compacted, and the

areas restored to an acceptable condition.

N/A

Erosion was noticed at various areas on the mine (STP at the outlet

of the stormwater and at the reservoirs) due to the lack of vegetation.

Site observations.

3.21 The water quality monitoring must be conducted biannually, at least

once after the summer and once after the winter to avert any potential

danger to the livestock farming activities down slope of the activities. C

Monthly surface water quality monitoring and biannual groundwater

monitoring is undertaken. The results of the monitoring are compiled

in the bi-annual reports in January and July of each year and then

submitted to the DWS.

Surface water monitoring reports, 2020.

3.22 Groundwater monitoring program must be developed. This must

include the monitoring boreholes for effluent up-gradient and down-

gradient of the activities.

C

Sasol Mining conduct a monthly surface water quality monitoring and

biannual groundwater monitoring , this was done in August 2020 and

thus, submitted to the department.

Integrated Water Monitoring and Reporting Programme:

Brandspruit Colliery: Impumelelo Mine (License No:

08/C12D/ABCEFGIJ/2160): 30 September 2020.

Impumelelo Integrated Water Monitoring Report covering the

period January 2020 to June 2020.

Integrated water use license (08/C12D/ABCEFGIJ/2160) - Bi-

annual report: August 2020.

3.23 Monitoring site for soil sampling must be established to monitor any

chemical changes in soil profile. Such sampling sites must be

established downstream of the neighbouring farms.

C

Hydrocarbon monitoring and biomonitoring of watercourses around

the mine is undertaken to determine operational impacts.

Biomonitoring Assessment: Impumelelo Coal Conveyor and -

Adherence to and Applicability of Stipulations contained in the

Water Use Licence; (Licence No. 08/C12D/ABCEFGIJ/2160 and

10/C12D/C1/4899): Dry Season Survey 2019.

Biomonitoring Assessment: Impumelelo Coal Conveyor and

D714 road - Adherence to and Applicability of Stipulations

contained in the Water Use Licence: (Licence No.

08/C12D/ABCEFGIJ/2160 and 10/C12D/C1/4899) Wet Season

Survey 2019.



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3.24 Dust and air quality monitoring programme must be set up to

assess ambient dust levels and the amount of dust generated by the

construction activities. C


exceedances of the non-residential dust fallout limit have been noted.

In addition, the ROM stockpile is visually monitored on a daily basis

to detect wind dispersion of dust. Dust suppression will only be done

when needed.


3.25 A noise monitoring programme must be set up to determine if noise

levels from certain equipment are not exceeding usual noise levels,

determine mitigation, management or servicing of the equipment if

required.

C

Noise monitoring results from 2019 showed that there were no

exceedances of the daytime or night-time acceptable noise ratings as

per SANS1013:2008 at the perimeter of the mine.

Impumelelo Colliery: Environmental / Perimeter Noise

Monitoring Assessment, 2019.

3.26 Monitoring of turbidity must occur upstream and not downstream of

the nearby streams during construction. N/A


been completed.

N/A

3.27 The Department retains the right to monitor and/ or inspect the

proposed project during both construction and operational phases. C


3.28 Fourteen (14) days written notice must be given to the Department

that the activity will commence. Commencement for the purposes of this

condition includes site preparation. The notice must include a date on

which it is anticipated that the activity will commence.

C

The DEDET was informed of the commencement of the authorised

activities for the Impumelelo Mine on 17/02/2019.

Letter to DEDET dated 17/02/2019.

3.29 The measures taken to control runoff water must take into account

the gradient. The flow must be deducted towards mid-slope and be

spread out into the lower lying area in order to encourage natural

seepage of water into the soil thus protecting areas susceptible to

erosion.

C

Erosion control berms have been placed throughout the mine to

prevent erosion in large cleared areas. These areas have been

allowed to be vegetated through natural succession.

Site observations.

3.30 The applicant must assign the development with the conditions of

the Environmental Officers/scientists who will ensure among other: C

Currently the responsibility of implementing the EMP lies with the

Impumelelo Environmental Practitioner as the project is in its

Operational Phase.

N/A

3.30.a) Ensure strict compliance of the development of the development

with the conditions of the Environmental Authorization as well as the

measures contained in the Environmental Management Plan;

C

Audits and inspections are undertaken against the EA and EMP.

Digby Wells has been appointed to conduct the external EA and

EMP audits for 2020 to assess the level of compliance on site.



3.30.b) Discuss and advise contractor on site about the environmental

matters before construction take place;

N/A

The Impumelelo Environmental Practitioner is responsible for

communicating environmental issues during weekly operations

meetings with contractors and Sasol Mining personnel. Inductions

were also undertaken before construction which covered

environmental matters.

Site observations.

3.30.c) Monitor compliance during construction and operation phases of

the activities; C

Audits and inspections are undertaken against the EA and EMP.

Digby Wells has been appointed to conduct the external EA and

EMP audits for 2020 to assess the level of compliance on site.



3.30.d) Keep records of all the environmental audits; C

Records of all the environmental audits previously undertaken are

kept safe and were available during the site visit.





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3.30.e) Ensure that contingency plans are developed and implemented

in the event of the occurrence of unforeseen circumstances. C

An Emergency and Preparedness Plan is in place at the Impumelelo

Colliery.

Emergency Response Plan for the Impumelelo Colliery.

3.31 All domestic waste generate on site during construction must be

stored in containers and later be disposed of at a registered landfill site N/A


been completed.

N/A

3.32 All heavy vehicles operators and truck drivers must be restricted to

designated areas, such as construction sites and roads. C

Mine vehicles are using dedicated roads that were constructed

around the mine.

Site observations.

3.33 Soil stockpiles must be managed in the manner that they do not

cause any environmental harm. C

Topsoil stockpiles were vegetated through natural succession.

Topsoil stockpiles are demarcated with limited access to prevent

vehicles driving over.

Site observations.

3.34 The coal stockpile areas must be lined and connect to effective

drainage systems that will channel effluent from the stockpile area into

silt traps and pollution control dams.

C

The coal stockpile areas are lined and water drains to the PCD. Site observations.

3.35 Accidental spillages must have sawdust applied immediately. The

affected soil must be dug out and removed and disposed of with

hydrocarbon waste by a reputable company.

NC

At the time of the audit, various minor oil spills were noticed on the

paved area, as well as on soil where vehicles are parked. It was also

noticed that refuelling is done to the point of overflow, as evident

from hydrocarbon spills at the refuelling area and at the decline shaft.

After a repeat of various incidents, a Management Site Inspection

was held in August 2019. This was used to highlight the issues and

appoint responsible people to address these concerns. However, it

was found that these issues have not yet successfully been

addressed.

Site observations.

3.36 Fuels, lubricants and hydrocarbons must be stored in bunded

facilities. C

All fuels, lubricants and hydrocarbon are stored within a bunded area

which complies with the necessary SANS standards.

Site observations.

3.37 The road surfaces, in particular those used by heavy vehicles must

be treated with dust binding agent. The form of the dust-binding agent

will determine the type of watering to be used. C

Dust fallout monitoring is undertaken by Sasol Mining (Pty) Ltd and

the results indicate that there have been no exceedances of the non-

residential dust fallout limit. Dust suppression can be undertaken

when necessary.


3.38 Regularly spaced low level speed humps must be constructed

across the width of the service road at the approach and departure

slopes to valley bottom wetlands to intercept surface runoff and to

deflect it to the surrounding grasslands

NC

No low level speed humps were constructed on site; however, the

vehicles are driven at a very low speed within the mine area.

Site observations.

3.39 Construction of the conveyor gantries across streams must be

planned to occur during dry seasons. N/A


been completed.

N/A

3.40 Erosion control measures such as contour banks and down drains

must be constructed and vegetated in rehabilitated areas NC

The erosion control measures are not implemented along the

conveyor crossing, this issue was raised in the previous year (2019)

during the site inspection by Digby Wells.

Site observations.

3.41 Erosion control berms must be placed reversely, at regular

intervals, across the terrestrial section of the conveyor servitude after

vegetation and topsoil stripping.

C

Erosion control berms were put in place to prevent the blockage of

water by the sediments and erosion.

Site observations.



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3.42 Gantries must be constructed over wetland area to contain coal

spillage. Such construction works must target the dry season to alleviate

negative impacts on the wetlands.

N/A


been completed.

N/A

3.43 The relevant water use license must be obtained from the

Department of water affairs. C

The Water Use Licence is in place. An amendment application for the

licence has been submitted but has not been issued to date.

WUL for Impumelelo Colliery (Licence no:

16/2/7/C121/ABCEFGIJ/2160).

3.44 The storage and handling of coal must comply with the precepts of

the NEM: AQA (Act 39 of 2004). N/A

There is no permanent storage of coal on site. Site observations.

3.45 No power line pylons must be located in wetlands. N/A No inspection was done along the powerline pylons. N/A

3.46 All road crossings over streams or wetlands must not impede the

flow of the water. C

Due to the nature of the culverts, it impedes the flow of the water.

The necessary WUL has been issued.

WUL for Impumelelo Colliery (Licence no:

16/2/7/C121/ABCEFGIJ/2160).

3.47 No surface runoff from the construction sites must enter the stream

area. N/A


been completed.

N/A

3.48 The PCDs must be lined to prevent any potential of grounds water

pollution. The lining must comply strictly with the requirements as set out

by the Department of Water Affairs.

C

The PCDs are lined with an HDPE liner to prevent infiltration of water

into the soil and groundwater. The seepage water downstream from

PCD shows no contamination and therefore the assumption is made

that the liner is still intact. An anomaly was noticed during the

evaluation of the biannual reports of 2019. A surface water dam

downstream of the PCD is showing signs of contamination. The

surface water dam is now being monitored.

Site observations.

3.49 The design and capacity of the evaporation ponds must take into

account the impact of the additional inflow due to runoff during rainy

season. These ponds must be constructed to sufficient capacity to

minimize overflowing during rainy seasons as this might result in serious

pollution potential to surface water.

C

The Pollution Control Dams (evaporation dams) are designed to

cater for 1:50 year flood event. Furthermore, Sasol Mining aims to

maintain the dams at a maximum of 30% of their full capacity which

further reduces risk of overflowing.

Site observation

3.50 The evaporation dam must be often de-sludge. The silt and sludge

from the dam must be disposed of in an environmentally friendly manner

considering their pollution potential. C

The silt trap just before the PCDs are maintained and are weekly

monitored. Once it is noticed that there is a silt build-up, the

necessary arrangements are made to desilt the silt trap and the

material is removed to an appropriate licenced facility.

SCS Job Card inspection of the silt traps and trenches, dated 19

October 2019.

3.51 The silt and sludge must be removed off the site and be disposed

of at the appropriate facility. The silt traps must be cleaned regularly. C

The silt trap just before the PCDs are maintained and are weekly

monitored. Once it is noticed that there is a silt build-up, the

necessary arrangements are made to desilt the silt trap and the

material is removed to an appropriate licenced facility.

SCS Job Card inspection of the silt traps and trenches, dated 19

October 2019.

3.52 Chemical toilets or any other approved sanitary facilities must be

made available to workers during construction. The toilets must have

lockable doors to prevent them from blowing over.

N/A


been completed.

Site observation

3.53 A comprehensive Storm Water Management Plan which outlines

the storm water drainage lines and discharge thereof must be compiled

in accordance with the requirements of the Department of Water Affairs.

C

Stormwater management measures have been implemented on site

in the form of trenches and berms throughout the area. Clean water

is diverted away from the dirty water areas and is discharged to the

IWWMP 2019 – 2020 and a schematic diagram.



SAS6652





clean water system. Dirty water is diverted to the PCDs from where it

is re-used underground.

3.54 Any complaints received from the public during the construction

and operational phases of the activity must be attended to as soon as

possible and addressed to the satisfaction of all concerned. C

A complaint register is in place. Complaints received from the public

will be manged by the Sasol Mining Rights Department (SMRD). Any

complaints raised are discussed during a monthly meeting with the

mine.

N/A

3.55 General waste that is generated during all phases of the activity

must be disposed of at a permitted disposal facility. C

All general waste generated on the mine is collected by Interwaste

Environmental Solutions and disposed of to a permitted landfill site.

Certificates of Safe Disposal (Interwaste Environmental

Solution);

3.56 Hazardous waste must be segregated and stored in appropriate

containers and be disposed of at a permitted waste disposal site by the

registered company/contractor. C

A SOP for waste management is available. The separation of waste

is implemented throughout the mine. Hazardous waste is segregated

and stored in appropriate containers and is later collected by

Interwaste and is disposed of at a permitted waste disposal site.

Site observations, SOP for waste management.

3.57 Hazardous waste must be disposed of at a licensed facility (class

H:H disposal site) by a registered waste management company. C






3.58 Waste chemicals, solvents and paints must be collected into

approved containers for storage and disposal. C






3.59 Records of the mass hazardous waste produced and disposed

must be kept, as well as disposal certificates.

C

The records of mass hazardous waste produced and disposed of to

the appropriate landfill site is monitored on a monthly basis. The

volumes EW made available by Interwaste who is responsible for the

removal of the waste. This data is then provided to Sasol Mining who

in turn populates the SD data and send it to the Sasol Head Office.

Interwaste Environmental Solutions, 22 October 2020

3.60 Records of all safe disposal certificates from a class H:H disposal

site must be kept by the applicant. C

The safe disposal certificates were made available at the time of the

audit.

Interwaste Environmental Solutions, 22 October 2021

3.61 All equipment must be subjected to a noise specification that will

reduce the overall noise in the plant. Where noise levels cannot be

reduced to the acceptable levels (85 dB-ambient) the staff must wear

ear protection equipment.

C

Noise monitoring results from 2019 showed that there were no

exceedances of the daytime or night-time acceptable noise ratings as

per SANS1013:2008 at the perimeter of the mine.

Impumelelo Colliery: Environmental / Perimeter Noise

Monitoring Assessment, 2019.

3.62 The facilities must be operated in accordance with the relevant

provision of Occupational Health and Safety Act (Act No 85 of 1993). N/A

The mine must comply against the requirements of the Mine Health

and Safety Act, 1996.

N/A

3.63 No activity such as construction camps, temporary housing,

temporary ablution, stockpiling of topsoil, storing of equipment and

disturbance of natural habitat, temporary access or haul roads or any

other use, may take place within any watercourse.

N/A


been completed.

N/A

3.64 The graveyards must be conserved in situ by means of a brick wall

or a fence. A buffer zone of at least 20 m must be maintained between

the graveyards and the conveyor.

C

The auditors were provided with GIS information to indicate the

location of graves, as identified by the heritage specialist study

conducted during the EIA process. Furthermore, the Survey

Interview with the Survey Manager.



SAS6652





Department completed a Section 17 Plan in terms of the Mineral and

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

(MPRDA) to indicate all sensitive areas on surface, including the

locations of buildings and graves. It was confirmed that no graves

were damaged during the construction of the mine and no graves

were relocated during the construction of the mine site.

3.65 Construction personnel must be sensitized to the requirements of

the South African Heritage Resources Act (SAHRA). Should any

material of cultural or archaeological significance be encountered during

construction, all activities must be cease immediately and the South

African Heritage Resources Agency must be informed accordingly.

N/A


been completed.

N/A

3.66 Should the use of the facilities ever cease or become redundant,

the applicant must undertake the required actions as prescribed by

legislation at the time and comply with all relevant legal requirements

administered by any relevant and competent authority at that time.

N/A


3.67 A rehabilitation plan must be submitted to this Department for

approval at least 6 months prior to the decommissioning phase. N/A


3.68 Potential geo-hydrological impacts during post closure,

decommissioning and closure phase must be assessed during the

ground water monitoring and modelling by a qualified and accredited

independent geo-hydrologists.

C

Groundwater monitoring boreholes are monitored bi-annually. A

biannual report is compiled and this is then submitted to the

Department of Water and Sanitation (DWS). Groundwater monitoring reports.

3.70 A copy of this authorization must be kept at the property where the

activities will be undertaken. The authorization must be produced to any

authorized official of the Department who request to see it and must be

available for inspection by any employee or agent of the holder of the

authorization who works or undertakes work at the property.

C

A copy of the EA and the EMP was made available at the time of the

audit.

DEDET Environmental Authorisation approval dated 15

September 2010;

DEDET Environmental approval of amendments dated 12

December 2011;

DEDET Environmental Management Programme amendment

dated 06 July 2010;

3.71 Where any of the applicant's contact details change, including the

name of the responsible person, the physical or postal address and/or

telephonic details; the applicant must notify the Department as soon as

the new details become known to the applicant.

N/A


3.72 The holder of the authorization must notify the Department, in

writing and within 24 (twenty-four) hours, if conditions of this

authorization are not adhered to. Any notification in terms of this

condition must be accompanied by reasons for the non-comply

N/A


3.73 Non-compliance with a condition of this authorization may result in

criminal prosecution or other actions provided for in the National

Environmental Management Act, 1998 and the regulations.

N/A


3.74 National government, provincial government, local authorities or

committees appointed in terms of the conditions of this authorization or

any other public authority shall not be held responsible for any damages

N/A




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or losses suffered by the applicant or his successor in title in any

instance where construction of operation subsequent to construction be

temporarily or permanently stopped for reasons of non-compliance by

the applicant with the conditions of authorization as set out in this

document or any other subsequent document emanating from these

conditions of authorization.

6. You are instructed in terms of regulation 10(2) of the Regulation to

notify all registered interested and affected parties in writing and within

12 days of the date of this letter, of the Departments decision to amend

this Environmental Authorization as well as the provisions regarding the

making of appeals that are provided for in the regulations

N/A


Table 9-2: Assessment of Compliance to the Operational Requirements of the EMPr

Activity Environmental

aspect Potential Impact Condition

Compliance

Rating Audit Comments

Transport of

coal

Noise Generation of noise 7.2.5.2.11 (c Maintain the conveyor belt regularly to

ensure that it is optimally functional. C

Weekly maintenance is undertaken by SCS according to a job card system.

Transport of

coal

Air quality Dust generation 7.2.5.2.10 (a Ensure that the conveyor belt is covered for

its full length.

C

The representatives from SCS indicated that it is not practical to fully

enclose the conveyor due to potential fire hazards and the impact on

prohibiting the cleaning of the conveyors. However, partial covering of the

conveyers were implemented. The conveyer is fully covered at the

Kaalspruit and the Waterval River crossings.

Transport of

coal

Noise Generation of noise 7.2.5.2.11 (b Ensure that the conveyor belt is covered for

its full length.

C






Transport of

coal

Visual aspects Visual impact of dust 7.2.5.2.14 (c Ensure that the conveyor belt is covered for

its full length.

C






Transport of

coal

I&APs Nuisance dust and noise 7.2.5.2.16 (c Ensure the conveyor is covered for its full

length to minimize dust generation.

C






Transport of

coal

I&APs Nuisance dust and noise 7.2.5.2.16 (e Ensure that the conveyor belt is covered for

its full length. C






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Compliance




Underground

mining of coal

Socio- economic

structure

Retaining of current

Brandspruit Staff

7.2.3.2.15 (a Employees can be further uplifted by being

provided with opportunities to take part in courses to

further their existing career at the proposed mine.

C

Impumelelo has a dedicated Training Department that manages and

provides various training courses to employees. The auditors met with the

Training Manager to discuss the types of courses provided.

Construction of

infrastructure

I&APs Increase in crime 7.2.2.2.16 (a Security measures should be implemented at

the surface land use area. C

The shaft area and mining area is fenced off and this is patrolled by Security

throughout the day.

Construction of

infrastructure

I&APs Increase in crime 7.2.2.2.16 (b Restrict access to the surface land use area

to authorized and on- duty personnel. C


throughout the day.

Mining related

activities

Animal life Loss of life 7.2.4.2.7 (l Restrict access to the surface land use area to

authorized and on- duty personnel. C


throughout the day.

Mining related

activities

Surface water Decrease in surface water

quality

7.2.4.2.8 (d Ensure that the dam wall has grass cover to

minimize erosion. C

The PCDs do not have dam walls, but the areas around the dams have

been grassed to minimise erosion.

Underground

mining of coal

Ground water Decrease in groundwater

quality

7.2.3.2.9 (e The pollution control dam should be lined so

as to limit seepage. C

The PCDs are lined with HDPE.

Construction of

infrastructure

Visual aspects Visual impact of

infrastructure

7.2.2.2.14 (a Construct the conveyor belt close to the

ground (not elevated) wherever possible. C

The overland conveyor belt is constructed close to the ground.

Mining related

activities

Surface water Increase in catchment yield 7.2.4.2.8 (j Ensure that all the relevant permissions are

obtained for the release of water into the catchment. C

The necessary WUL is in place which authorise the discharge of treated

sewage effluent.

Underground

mining of coal

I&APs Irritation of I&AP’s by dust

and noise

7.2.3.2.16 (h Conduct noisy activities during day time.

C

Noise is generated from the ventilation shaft, incline shaft, bunker area, as

well as the conveyor belt, which are all operational 24 hours a day.

Noise monitoring results from 2019 showed that there were no exceedances

of the daytime or night-time acceptable noise ratings as per

SANS1013:2008 at the perimeter of the mine.

Mining related

activities

Noise Noise generation 7.2.4.2.11 (a Conduct noisy activities during daytime.

C






Mining related

activities

I&APs Nuisance dust and noise 7.2.4.2.16 (d Conduct noisy activities during the day time.

C






Underground

mining of coal

Noise generation of noise 7.2.3.2.11 (d Conduct noisy activities during the day time.

C








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Compliance


Construction of

infrastructure


infrastructure

7.2.2.2.14 (c Construct shafts and other tall infrastructure

with materials that blend into surroundings. C

The materials used to construct infrastructure was observed to blend in with

the environment as much as possible.

Transport of

coal

Animal life Frightening of fauna 7.2.5.2.7 (a Any fencing should allow an opportunity for

smaller animals to pass through the fence to escape the

conveyor servitude, but prevent re- entry.

C

The fencing along the conveyor servitude will allow smaller animals to pass

through the fence.

Transport of

coal

Animal life Loss of life 7.2.5.2.7 (b Any fencing should allow an opportunity for


construction activates, but prevent re-entry.

C

The fencing along the conveyor servitude will allow smaller animals to pass

through the fence.

Clearing of land Vegetation Establishment of invader

species

7.2.2.1.17.6 (a Check all revegetated and surrounding

areas for any invader plant species on a regular basis. C

The ECO indicated that Impumelelo has appointed Libra Landscaping to

undertake an alien invasive plant assessment. An alien invasive plant

eradication plan is being implemented on site.


species

7.2.2.1.17.6 (b Remove any invader plant species.

C




Clearing of land Soil Soil erosion 7.2.2.1.17.3 (b Ensure that the gradient of stockpiles is 1:3

or less (shallower) so as to allow for the establishment of

vegetation on all stockpiles.

C

The ECO did confirm that the slopes of the overburden stockpile were less

than 1:3. The topsoil stockpiles were also found to be naturally vegetated.

Underground

mining of coal

Soil Degradation of soil quality 7.2.3.2.3 (a The dirty water management area should be

kept as small as possible. C

All clean water is diverted around the mine in clean water drains. Water from

roofs and clean areas is discharged through clean water drains to the

watercourse. Dirty water areas drain towards a 7 ML PCD.

Underground

mining of coal

Land capability Degradation of land

capability

7.2.3.2.4 (a The dirty water management area should be





Underground

mining of coal


quality

7.2.3.2.8 (a The dirty water management area should be





Underground

mining of coal


quality

7.2.3.2.8 (b No dirty water should be allowed to leave the

dirty water management area (except during an

exceptional flood event, as per the National Water Act, Act

36 of 1998, and only under license conditions).

C




Underground

mining of coal


quality

7.2.3.2.9 (b The dirty water management area should be





Construction of

infrastructure

Vegetation Development of gardens 7.2.2.2.6 (b Plant only indigenous plants.

C

The Auditors were informed that only indigenous plants were planted in the

gardens. This was confirmed with an email from the Project Engineer, which

shows that the landscaping contractors were tasked to plant only indigenous

species.

Mining related

activities

Vegetation Establishment of invader

species

7.2.4.2.6 (b Ensure that only indigenous plants are planted

in garden areas. C

The Auditors were informed that only indigenous plants were planted in the

gardens. This was confirmed with an email from the Project Engineer, which



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Compliance


shows that the landscaping contractors were tasked to plant only indigenous

species.

Underground

mining of coal

Visual aspects Visual impact of ROM

stockpile

7.2.3.2.14 (a Ensure the height of the rock stockpile does

not interrupt the line of the horizon. C

Stockpile areas are in line with horizon and were not found to be a

significant visual obstruction.

Underground

mining of coal

Noise generation of noise 7.2.3.2.11 (f Provide protective gear for workers exposed

to high noise levels. C

Signs were displayed at areas where personal noise protection is required.

All personnel are issued with the necessary PPE.

Mining related

activities

Noise Noise generation 7.2.4.2.11 (b Provide workers with protective gear to

mitigate the impact of noise. C

Signs were displayed at areas where personal noise protection is required.

All personnel are issued with the necessary PPE.

Mining related

activities

Soil Enrichment of soils in

garden areas

7.2.4.2.3 (g Fertilize gardens when necessary. C

Service providers are appointed to do landscaping and to maintain gardens.

The fertilising of the gardens would take place as and when required.

Construction of

infrastructure

Vegetation Development of gardens 7.2.2.2.6 (d Maintain gardens regularly. C



Mining related

activities

Soil Enrichment of soils in

garden areas

7.2.4.2.3 (h Maintain gardens appropriately. C



Underground

mining of coal

Socio- economic

structure

Creation of additional jobs 7.2.3.2.15 (c The employment process should be fair and

transparent. C

Employment is undertaken in line with the Social Labour Plan (SLP) and

strict procedures apply to the recruitment and employment process.

Transport of

coal

Socio- economic

structure

upliftment of individuals /

organizations

7.2.5.2.15 (b Encourage BEE participation in the tender

process.

C

Procurement is undertaken in line with the SLP and strict procurement

procedures.

BEE is further promoted through the employee share scheme and that they

measure BEE in terms of opportunities within Impumelelo. They also

monitor and report on diversity stats (which includes AIC – African, Coloured

and Indian [target of 30%] and women in mining). Reporting is done to the

line managers who report to the GM monthly.

Transport of

coal

Socio- economic

structure

upliftment of individuals /

organizations

7.2.5.2.15 (c Ensure that the tender process is fair and

well documented.

C


procedures.






Mining related

activities

Ground water increase in groundwater

quantity

7.2.4.2.9 (e Pipelines should be regularly monitored for

leaks, and leaks patched so as to prevent spillage of

water.

C

Pipelines are monitored and inspected on a weekly basis to prevent leaks.

The water pipelines are also located within the servitude that runs from

Impumelelo to Brandspruit to allow for ease of access in the event of failure.

Mining related

activities


quality

7.2.4.2.8 (g Pipelines should be regularly monitored for

leaks, and leaks patched so as to prevent spillage of

water.

C

Pipelines are monitored and inspected on a weekly basis to prevent leaks.

The water pipelines are also located within the servitude that runs from

Impumelelo to Brandspruit to allow for ease of access in the event of failure.

Underground

mining of coal

Sites of

archaeological and

cultural interest

Degradation of sites of

archaeological and cultural

7.2.3.2.12 (a Avoid undermining of archaeological sites

with high extraction mining. C

Maps are available to indicate where heritage sites exist and a permitting

process is in place before high extraction mining can occur in an area.



SAS6652





Compliance


interest result of subsidence

and / or fracturing

Mining related

activities

Socio- economic

structure

Community projects 7.2.4.2.15 (a Monitor community projects to ensure that

they are effective. C

People, Organisation and Effectiveness (POE) Corporate Affairs

Department has quarterly and monthly meetings with the community. The

mine is not responsible for the implementation of community projects.

Mining related

activities

Socio- economic

structure

Community projects 7.2.4.2.15 (b Modify community projects if necessary to

increase effectiveness. C




Mining related

activities

Socio- economic

structure

Community projects 7.2.4.2.15 (c Give preference to local contractors.

C




Underground

mining of coal

Socio- economic

structure

Retaining of current

Brandspruit Staff

7.2.3.2.15 (b Sasol Mining can carry out community

projects in order to aid the upliftment of the surrounding

community.

C




Underground

mining of coal

Socio- economic

structure

Creation of additional jobs 7.2.3.2.15 (d Employees for any additional jobs created

should be sourced from the local area (Lekwa, Dipaliseng

and Govern Mbeki Local Municipalities).

C




Underground

mining of coal

Socio- economic

structure

Creation of additional jobs 7.2.3.2.15 (e Should any additional contract work become

available, preference should be given to local contractors. C




Underground

mining of coal

Socio- economic

structure

Community projects 7.2.3.2.15 (f Monitor community projects to ensure that

they are effective. C




Underground

mining of coal

Socio- economic

structure

Community projects 7.2.3.2.15 (g Modify community projects if necessary to

increase effectiveness. C




Transport of

coal


quality

7.2.5.2.9 (e The conveyor belt should be covered so as to

limit the chances of spillage. C

Partial covering of the conveyers were implemented, as it is impractical to

clean the conveyor if fully covered. The conveyer is fully covered at the


Transport of

coal


quality

7.2.5.2.8 (e The conveyor belt should be covered so as to

limit the chances of spillage. C

Partial covering of the conveyers were implemented, as it is impractical to

clean the conveyor if fully covered. The conveyer is fully covered at the



species

7.2.2.1.17.6 (c Ensure stockpiles are vegetated with flora

indigenous to the study area. C

Overburden and topsoil stockpiles were vegetated through natural

succession. No stockpiles were seeded during the time of the audit.

Mining related

activities

Soil Loss of soil structure and

function

7.2.4.2.3 (e Ensure stockpiles and berms remain

vegetated to prevent erosion. C



Mining related

activities


species

7.2.4.2.6 (c Ensure stockpiles are vegetated with flora

indigenous to the area. C





SAS6652





Compliance


Clearing of land Soil Soil erosion 7.2.2.1.17.3 (a Ensure stockpiles are vegetated. C


succession.

Clearing of land Visual aspects Visual impact of dust 7.2.2.1.17.14 (c Ensure stockpiles are vegetated to

minimize dust generation. C


succession.

Clearing of land I&APs Irritation caused by dust

generation

7.2.2.1.17.16 (c Ensure stockpiles are vegetated to

minimize dust generation. C


succession.

Mining related

activities

Visual aspects visual impact of dust 7.2.4.2.14 (c Ensure stockpiles are vegetated to minimize

dust generation. C


succession.

Mining related

activities

I&APs Nuisance dust and noise 7.2.4.2.16 (c Ensure stockpiles are vegetated to minimize

dust generation. C


succession.

Underground

mining of coal

Geology Geological strata will be

altered by subsidence

7.2.3.2.1 (c Plough and rip fractures at the surface. N/A

Only one area within the Mining Right area was subjected to stooping and

there have been no signs of surface subsidence.

Underground

mining of coal

Topography Hollows will be created

(subsidence)

7.2.3.2.2 (c Plough and rip fractures on the surface. N/A



Underground

mining of coal

Soil Degradation of soils caused

by subsidence and / or

fracturing

7.2.3.2.3 (k Fertilize and vegetate damaged subsided

areas to restore its pre- mining status if required. N/A



Underground

mining of coal

Land use Degradation of land use as a

result of subsidence and / or

fracturing

7.2.3.2.5 (b Plough and rip fractures at the surface.

N/A



Underground

mining of coal

Vegetation Degradation of vegetation as

a result of subsidence and /

or fracturing

7.2.3.2.6 (e Plough and rip fractures at the surface.

N/A



Underground

mining of coal



or fracturing

7.2.3.2.6 (g Fertilize and vegetate damaged subsided




Underground

mining of coal

Animal life Impact on animals as a


fracturing


N/A



Underground

mining of coal

Surface water Degradation of surface water

as a result of subsidence

and / or fracturing

7.2.3.2.8 (d Plough and rip fractures at the surface.

N/A



Underground

mining of coal

Ground water Alteration of groundwater

flow paths as a result of

subsidence and / or

fracturing

7.2.3.2.9 (i Plough and rip fractures at the surface.

N/A





SAS6652





Compliance


Underground

mining of coal

Sites of

archaeological and

cultural interest




and / or fracturing


N/A



Underground

mining of coal

Sensitive

landscapes

Degradation of sensitive

landscapes as a result of

subsidence and / or

fracturing


N/A



Underground

mining of coal

I&APs Degradation of land as a


fracturing

7.2.3.2.16 (k Plough and rip fractures at the surface.

N/A



Underground

mining of coal


(subsidence)

7.2.3.2.2 (e Fertilize and vegetate damaged subsided




Underground

mining of coal



fracturing

7.2.3.2.3 (i Plough and rip fractures at the surface.

N/A



Underground

mining of coal


capability

7.2.3.2.4 (d Limit the extent of surface disturbances. C



Underground

mining of coal


capability as a result of

subsidence and / or

fracturing


N/A



Underground

mining of coal



subsidence and / or

fracturing

7.2.3.2.4 (f Use cut and fill techniques to ensure that

subsided areas are free draining. N/A



Underground

mining of coal



subsidence and / or

fracturing





Underground

mining of coal



fracturing

7.2.3.2.5 (d Fertilize and vegetate damaged subsided




Underground

mining of coal



fracturing





Underground

mining of coal



fracturing







SAS6652





Compliance


Underground

mining of coal



and / or fracturing

7.2.3.2.8 (f Fertilize and vegetate damaged subsided




Underground

mining of coal

Sensitive

landscapes



subsidence and / or

fracturing

7.2.3.2.13 (d Fertilize and vegetate damaged subsided




Underground

mining of coal



fracturing

7.2.3.2.16 (j Prevent impacts on I&AP’s by excluding

sensitive landscapes (such as wetlands) and infrastructure

(such as farm houses) from areas to be mined by high

extraction mining methods.

N/A



Underground

mining of coal



fracturing

7.2.3.2.16 (l Use cut and fill techniques to ensure that




Underground

mining of coal



fracturing

7.2.3.2.16 (m Fertilize and vegetate damaged subsided




Underground

mining of coal



fracturing

7.2.3.2.16 (n Compensate landowners for any loss

incurred as a direct result of subsidence and / or

fracturing.

N/A



Underground

mining of coal


(subsidence)

7.2.3.2.2 (d Use cut and fill techniques to ensure that




Underground

mining of coal



fracturing

7.2.3.2.3 (j Use cut and fill techniques to ensure that




Underground

mining of coal



fracturing

7.2.3.2.5 (c Use cut and fill techniques to ensure that




Underground

mining of coal



or fracturing





Underground

mining of coal



and / or fracturing

7.2.3.2.8 (e Use cut and fill techniques to ensure that




Underground

mining of coal


flow paths as a result of

subsidence and / or

fracturing

7.2.3.2.9 (j Use cut and fill techniques to ensure that

subsided areas are free draining and to reduce infiltration

of clean water to underground. N/A





SAS6652





Compliance


Underground

mining of coal

Sites of

archaeological and

cultural interest




and / or fracturing





Underground

mining of coal

Sensitive

landscapes



subsidence and / or

fracturing


subsided areas are free draining, N/A



Underground

mining of coal


flow paths

7.2.3.2.9 (h Removal of only coal and rock required for the

continuation of the proposed mining, C

Extraction of material was limited to the removel of bedrock to establish the

incline, decline and ventilation shaft; and the current extraction of coal.

Clearing of land Animal life No anticipated impacts 7.2.2.1.17.7 N/A No anticipated impacts, N/A Noted.

Underground

mining of coal

Topography Mounds will be created 7.2.3.2.2 (a Ensure the height of the rock and ROM

stockpiles do not interrupt the line of the horizon. C

The ROM stockpiles were observed to be kept at a minimum height (lower

than the bunker) and therefore, are not considered to interrupt the line of the

horizon.

Mining related

activities


quality

7.2.4.2.8 (c Remove shrubs and trees from the dam wall, C

The area adjacent to the PCDs are kept grassed and shrubs and trees are

removed as and when required.

Underground

mining of coal



7.2.3.2.1 (d Use cut and fill techniques to ensure that

subsided areas are free draining, N/A



Underground

mining of coal



7.2.3.2.1 (e Fertilize and vegetate damaged subsided

areas to restore its pre- mining status if required, N/A



Transport of

coal

Visual aspects visual impact of haul trucks 7.2.5.2.14 (a Ensure haul trucks are clean and free of coal

dust, N/A

Not applicable, as no haul trucks are used to transport coal.

Underground

mining of coal

Noise generation of noise 7.2.3.2.11 (b Ensure blasting in suitably controlled, N/A

Not applicable. Blasting is only done underground and will therefore not

generate noise on surface.

Transport of

coal

Noise generation of noise 7.2.5.2.11 (a Fit the conveyor belt with noise reduction

idlers, and ensure that they remain efficiently functional, C




Transport of

coal

I&APs Nuisance dust and noise 7.2.5.2.16 (d Fit the conveyor belt with noise reduction

idlers, and ensure that they remain efficiently functional, C




Mining related

activities


quality

7.2.4.2.8 (b Monitor the dam wall of the pollution control

dam for nature of vegetation cover, C

The area adjacent to the PCDs are kept grassed and shrubs and trees are

removed as and when required.

Underground

mining of coal

Visual aspects Visual impact of ROM

stockpile

7.2.3.2.14 (b Build visual barriers between the ROM

stockpile and sensitive viewpoints,

C

No trees have been planted as visual barriers. This has not been deemed

necessary, as the nearest receptors are more than 1 km away from the

operations. In addition to the above, Soweto Highveld Grasslands are found

in this area. This vegetation unit is typically devoid of trees. Impumelelo

have however planted Karee trees and Acacia trees along the road entrance

for beatification.



SAS6652





Compliance


Construction of

infrastructure


infrastructure

7.2.2.2.14 (b Plant trees to create a visual barrier,

C

No trees have been planted as visual barriers. This has not been deemed

necessary, as the nearest receptors are more than 1 km away from the

operations. In addition to the above, Soweto Highveld Grasslands are found

in this area. This vegetation unit is typically devoid of trees. Impumelelo

have however planted Karee trees and Acacia trees along the road entrance

for beatification.

Underground

mining of coal

Sensitive

landscapes



subsidence and / or

fracturing

7.2.3.2.13 (a Appoint a qualified specialist to design

appropriate mitigation measures should this impact occur,

C

Biomonitoring specialists, hydrologists, ecologists, wetland specialists and

Environmental Assessment Practitioners (EAPs) are and have been

employed at various stages throughout the mine's life cycle to assess

environmental impacts on sensitive landscapes. Information is provided and

if impacts occur, these are communicated to Impumelelo and appropriate

action plans are developed.

Mining related

activities

Soil Pollution of soils by spillage 7.2.4.2.3 (c One the spillage has been cleaned up the soils

should be tested and fertilized if necessary, NC

No soil results were available at the time of the audit to indicate that areas

that have been cleaned and rehabilitated have been tested.

Transport of

coal

Sensitive

landscapes

Alteration of structure and

function of sensitive

landscapes

7.2.5.2.13 (c One the spillage has been cleaned up the

soils should be tested and fertilized if necessary, NC



Transport of

coal


species

7.2.5.2.6 (e Monitor surface area within the conveyor

servitude to check whether any invader plant species can

be found there,

NC

No proof was available at the time of the audit that the conveyor servitude is

checked for invader plant species and that the alien invasive species were

removed.

Transport of

coal


species

7.2.5.2.6 (f Remove any invader plant species as soon as

they are identified. NC

No proof was available at the time of the audit that the conveyor servitude is

checked for invader plant species and that the alien invasive species were

removed.

Underground

mining of coal

Noise generation of noise 7.2.3.2.11 (a Only allow noise generation when necessary

(i.e. switch off inactive machinery), C

No machines were observed to be left on when inactive.

Underground

mining of coal

Noise generation of noise 7.2.3.2.11 (e Only allow noise generation when necessary



Underground

mining of coal


and noise

7.2.3.2.16 (f Only allow noise generation when necessary



Underground

mining of coal


and noise

7.2.3.2.16 (i Only allow noise generation when necessary



Mining related

activities

Air quality Decrease in air quality as a

result of additional vehicle

movement

7.2.4.2.10 (b Switch off machinery and vehicles when not

in use, C


Mining related

activities

I&APs Nuisance dust and noise 7.2.4.2.16 (e Only allow noise generation when necessary

(i.e. switch off inactive machinery) C


Construction of

infrastructure

I&APs Increase in crime 7.2.2.2.16 (c Implement penalties and fines for poaching, N/A

No incidents of poaching have been reported to the mine thus far.



SAS6652





Compliance


Mining related

activities

Animal life Loss of life 7.2.4.2.7 (m Implement penalties and fines for poaching, N/A

No incidents of poaching have been reported to the mine thus far.

Underground

mining of coal

Sites of

archaeological and

cultural interest




and / or fracturing

7.2.3.2.12 (d Reconstruct graves if they have been

damaged,

C

The auditors were provided with GIS information to indicate the location of

graves, as identified by the heritage specialist study conducted during the

EIA process. Furthermore, the Survey Department completed a Section 17

Plan in terms of the Mineral and Petroleum Resources Development Act,

2002 (Act No. 28 of 2002) (MPRDA) to indicate all sensitive areas on

surface, including the locations of buildings and graves. It was confirmed

that no graves were damaged during the construction of the mine and no

graves were relocated during the construction of the mine site.

Mining related

activities

Animal life increase in faunal diversity 7.2.4.2.7 (f Monitor the surface land use area and note

changes in faunal diversity, NC

No evidence was available at the time of the audit that the surface land use

area is monitored in terms of its faunal diversity.

Underground

mining of coal


and noise

7.2.3.2.16 (g Ensure blasting is suitably controlled, N/A

Not applicable. Blasting is only done underground and will therefore not

generate noise on surface.

Underground

mining of coal


and noise

7.2.3.2.16 (c Suppress dust on the ROM stockpile when

required, C


exceedances of the non-residential dust fallout limit have been noted. In

addition, the ROM stockpile is visually monitored on a daily basis to detect

wind dispersion of dust. Dust suppression will only be done when needed.

Transport of

coal

Soil Pollution of soils by spillage 7.2.5.2.3 (a Monitor conveyor route in order to identify

spillages, C

The conveyor belt route is monitored on a daily basis by SCS.

Transport of

coal

Soil Pollution of soils by spillage 7.2.5.2.3 (b Spillages should be cleaned up immediately, C

No coal spillages were observed on site at the time of site visit.

Transport of

coal

Soil Pollution of soils by spillage 7.2.5.2.3 (d One the spillage has been cleaned up the




Transport of

coal

Soil Pollution of soils by spillage 7.2.5.2.3 (c Spillages should be neutralized if necessary

(i.e. if too basic or too acidic), NC



Transport of

coal

Vegetation Pollution of soils by spillage 7.2.5.2.6 (a Spillages should be cleaned up immediately, C

No coal spillages were observed on site at the time of site visit.

Transport of

coal

Vegetation Pollution of soils by spillage 7.2.5.2.6 (b Spillages should be neutralized if necessary

(i.e. if too basic or too acidic), C

No coal spillages were observed on site at the time of audit.

Transport of

coal

Vegetation Pollution of soils by spillage 7.2.5.2.6 (c One the spillage has been cleaned up the soils




Transport of

coal


quality

7.2.5.2.8 (a Spillages should be cleaned up immediately, C


Transport of

coal


quality

7.2.5.2.8 (b Spillages should be neutralized if necessary




Transport of

coal


quality

7.2.5.2.8 (c One the spillage has been cleaned up the soils






SAS6652





Compliance


Transport of

coal


quality

7.2.5.2.9 (a Spillages should be cleaned up immediately, C


Transport of

coal


quality


(i.e. if too basic or too acidic) NC



Transport of

coal


quality

7.2.5.2.9 (c One the spillage has been cleaned up the soils




Transport of

coal

Sensitive

landscapes



landscapes

7.2.5.2.13 (a Spillages should be cleaned up immediately,

C


Transport of

coal

Sensitive

landscapes



landscapes


(i.e. if too basic or too acidic), C


Transport of

coal

Visual aspects Visual impact of dust 7.2.5.2.14 (d Ensure that spillages are timeously cleaned

up, C


Rehabilitation

activities

Topography Alteration of topography to

close to its pre-mining status

7.2.6.2.2 (a Ensure that all rehabilitated surfaces are free-

draining, N/A

No areas have been rehabilitated during the operational phase.

Rehabilitation

activities

Topography Alteration of topography to

close to its pre-mining status

7.2.6.2.2 (b Monitor rehabilitated areas to ensure that

altered topography is stable. N/A


Rehabilitation

activities

Soil Compaction of soil 7.2.6.2.3 (a Limit vehicle movement to designated

pathways, N/A


Rehabilitation

activities

Soil Rehabilitation of soil 7.2.6.2.3 (b Soils will be monitored, and if necessary

corrected or maintained on a regular basis to ensure that

the structure and function of the soil are becoming self-

sustaining,

N/A


Rehabilitation

activities

Soil Soil erosion 7.2.6.2.3 (c Ensure barren areas are vegetated, N/A


Rehabilitation

activities

Soil Soil erosion 7.2.6.2.3 (d Limit vehicle movement on rehabilitated areas, N/A


Rehabilitation

activities

Soil Pollution of soils by spillage 7.2.6.2.3 (e Spillages should be cleaned up immediately, N/A


Rehabilitation

activities

Soil Pollution of soils by spillage 7.2.6.2.3 (f Spillages should be neutralized if necessary

(i.e. if too basic or too acidic), N/A


Rehabilitation

activities

Soil Pollution of soils by spillage 7.2.6.2.3 (g Once the spillage has been cleaned up the

soils should be tested and fertilized if necessary, N/A


Rehabilitation

activities

Surface water quality 7.2.6.2.8 (c Water quality will be sampled and monitored

regularly, N/A




SAS6652





Compliance


Rehabilitation

activities

Surface water Increase in infiltration 7.2.6.2.8 (d Water quantity will be monitored regularly, N/A


Rehabilitation

activities

Surface water Increase in infiltration 7.2.6.2.8 (e Backfill the incline shaft and seal other shafts

to minimize surface water ingress, N/A


Mining related

activities

Animal life Loss of life 7.2.4.2.7 (k Provide animal safe ladders on sloped areas

into the pollution control dam to prevent accidental

drowning,

C

There are yellow safety nets around the PCDs which serve as ladders for

animals to escape, if needed. To date no animals have fallen into the PCDs.

Rehabilitation

activities

Soil Pollution of soils by spillage 7.2.6.2.3 (h Natural vegetation should be established,

C

Natural vegetation have established in some of the cleared areas. The areas

were vegetated through natural succession. The ECO has also allocated

biodiversity areas which represent the natural vegetated areas in this

catchment.

Transport of

coal

Soil Pollution of soils by spillage 7.2.5.2.3 (e Natural vegetation should be established,

C

Natural vegetation has been established through natural succession.

However, in the section between Crossing 1 and Crossing 6, some of the

side slopes are bare and this has resulted in soil erosion.

Transport of

coal

Vegetation Pollution of soils by spillage 7.2.5.2.6 (d Natural vegetation should be established,

C




Transport of

coal


quality

7.2.5.2.8 (d Natural vegetation should be established,

C




Transport of

coal


quality


C




Transport of

coal

Sensitive

landscapes



landscapes


C




Mining related

activities

Soil Pollution of soils by spillage 7.2.4.2.3 (d Natural vegetation should be established,

C




catchment.

Underground

mining of coal

Soil Pollution of soils by spillage 7.2.3.2.3 (h Natural vegetation should be established,

C




catchment.

Construction of

infrastructure

Visual aspects Visual impact of lights 7.2.2.2.14 (e Turn of lights not required for the operation

continuation of activities, C

Motion sensitive sensors were implemented in all offices to ensure that

lights are turned off when nobody is in the office.

Mining related

activities

Visual aspects Visual impact of lights 7.2.4.2.14 (e Turn off lights not required for the

continuation of mining related activities, C





SAS6652





Compliance


Mining related

activities

I&APs Irritation of I&AP’s as a result

of visual disturbance

7.2.4.2.16 (g Turn off lights not required for the

continuation of mining related activities, C



Underground

mining of coal


altered by mining

7.2.3.2.1 (a Restrict the removal of rock to the mining area

only, C

Extraction of material was limited to the removal of bedrock to establish the

incline, decline and ventilation shaft; and the current extraction of coal.

Clearing of land Soil Compaction of soil 7.2.2.1.17.3 (g Ensure designated pathways are allocated

for vehicle movement, C

Mine vehicles are using dedicated roads that were constructed around the

mine.

Underground

mining of coal

Topography Mounds will be created 7.2.3.2.2 (b Ensure that the gradient of stockpiles is 1:3 or

less (shallower) so as to allow for the establishment of

vegetation on all stockpiles,

C

It was confirmed with the Engineer that the slopes of the overburden

stockpile were less than 1:3.

Underground

mining of coal

Noise generation of noise 7.2.3.2.11 (c Ensure designs of ventilation shafts take the

minimization of noise into consideration, C




Construction of

infrastructure

Vegetation Development of gardens 7.2.2.2.6 (c Check regularly for alien invader plant species

and remove any found, C




Underground

mining of coal


species

7.2.3.2.6 (a Check all surface land use areas for any

invader plant species on a regular basis, C




Underground

mining of coal


species

7.2.3.2.6 (b Remove any invader plant species.

C




Underground

mining of coal



or fracturing

7.2.3.2.6 (h Remove any invader plant species as soon as

they are identified. C




Underground

mining of coal

Sensitive

landscapes



subsidence and / or

fracturing

7.2.3.2.13 (e Remove any invader plant species as soon

as they are identified. C




Mining related

activities


species

7.2.4.2.6 (a Remove any invader plant species as soon as

they are identified. C




Rehabilitation

activities


species

7.2.6.2.6 (a Check all revegetated and surrounding areas

for any invader plant species on a regular basis, C




Rehabilitation

activities


species

7.2.6.2.6 (b Remove any invader plant species,

C






SAS6652





Compliance


Mining related

activities

Soil Loss of soil structure and

function

7.2.4.2.3 (f Remove alien invasive vegetation from the site,

C




Mining related

activities

Socio- economic

structure

Community projects 7.2.4.2.15 (d Encourage BEE participation in the tender

process, C

HR Department presents diversity statistics to the line managers who

present to the GM on a monthly basis. Sasol has also implemented a Sasol

Share Scheme under BEE.

Underground

mining of coal

Land use Alteration of land use as a

result of dewatering

7.2.3.2.5 (a Monitor the actual development of the cone of

depression (monitor water levels in boreholes) and provide

land owners with alternative water if required,

C

Groundwater monitoring boreholes are monitored bi-annually. A biannual

report is compiled and this is then submitted to the Department of Water and

Sanitation (DWS).

Underground

mining of coal


quantity as a result of the

formation of a depression

cone

7.2.3.2.9 (a Monitor the actual development of the cone of

depression (monitor water levels in boreholes) and provide

land owners with alternative water if required, C



Sanitation (DWS).

Underground

mining of coal

I&APs Decrease in groundwater

quantity as a result of the

formation of a depression

cone

7.2.3.2.16 (a Monitor the actual development of the cone

of depression (monitor water levels in boreholes) and

provide land owners with alternative water when it has

been proven that the impact resulted from the mining

activities associated with the proposed mine.

C



Sanitation (DWS).

Underground

mining of coal


and noise

7.2.3.2.16 (d Prevent erosion of loose particles by

vegetating cleared land / stockpiles when possible,

NC

Erosion is prevented through various measures, specifically by backfilling,

sloping and vegetating disturbed areas. Erosion is also monitored through

visual site inspections. Erosion was however noticed at various areas on the

mine (STP at the outlet of the stormwater drains; and between Crossing 1

and Crossing 6), due to the lack of vegetation. Erosion control is on-going

and various rehabilitation activities were implemented between 2018 and

2020 to reduce the areas susceptible and showing signs of erosion.

Mining related

activities

Air quality Dust generation 7.2.4.2.10 (d Prevent erosion of loose particles by

vegetating cleared land / stockpiles as soon as possible,

NC








Rehabilitation

activities

Surface water Quality 7.2.6.2.8 (b Vegetate barren land with natural vegetation

to prevent erosion,

NC








Rehabilitation

activities

Air quality Dust generation 7.2.6.2.10 (b Prevent erosion of loose particles by

vegetating barren land as soon as possible, NC





SAS6652





Compliance







Clearing of land Surface water Decrease in water quality 7.2.2.1.17.8 (b Prevent erosion of loose particles by

vegetating cleared land / stockpiles when no longer

utilized,

NC








Clearing of land Air quality Dust generation 7.2.2.1.17.10 (b Prevent erosion of loose particles by

vegetating cleared land / stockpiles as soon as possible,

NC








Transport of

coal

Visual aspects Visual impact of dust 7.2.5.2.14 (b Suppress dust on cleared land (transfer

station), C

Dust suppression is implemented at the coal transfer stations on the

conveyor belt. Dust fallout monitoring is undertaken by Sasol Mining (Pty)

Ltd and the results indicate that there have been no exceedances of the

non-residential dust fallout limit.

Transport of

coal

I&APs Nuisance dust and noise 7.2.5.2.16 (a Suppress dust on cleared land,

C

Dust suppression is implemented at the coal transfer stations on the

conveyor belt. Dust fallout monitoring is undertaken by Sasol Mining (Pty)

Ltd and the results indicate that there have been no exceedances of the

non-residential dust fallout limit.

Transport of

coal

Vegetation Minimization of physiological

processes

7.2.5.2.6 (g Implement a dust suppression programme on

all disturbed soil areas where dust can be generated due

to vehicle movement or the conveyor belt or wind.

C

Dust fallout monitoring is undertaken by Sasol Mining (Pty) Ltd and the

results indicate that there have been no exceedances of the non-residential

dust fallout limit. Dust suppression can be undertaken when necessary.

Clearing of land Surface water Decrease in water quality 7.2.2.1.17.8 (a Suppress dust on cleared land,

C




Clearing of land Air quality Dust generation 7.2.2.1.17.10 (a Suppress dust on cleared land,

C




Clearing of land Visual aspects Visual impact of dust 7.2.2.1.17.14 (a Suppress dust on cleared land,

C






SAS6652





Compliance



generation

7.2.2.1.17.16 (a Suppress dust on cleared land,

C




Construction of

infrastructure

Vegetation Minimisation of physiological

processes

7.2.2.2.6 (a Suppress dust on cleared land,

C




Underground

mining of coal

Animal life Frightening of fauna 7.2.3.2.7 (a Suppress dust on cleared land,

C




Underground

mining of coal


and noise

7.2.3.2.16 (b Suppress dust on cleared land,

C




Mining related

activities


processes

7.2.4.2.6 (d Suppress dust on cleared land,

C




Mining related

activities


C




Mining related

activities


quality

7.2.4.2.9 (a Ensure that the water used for dust

suppression is of an appropriate quality, C



dust fallout limit. Dust suppression can be undertaken when necessary. Only

clean water would be used for dust suppression on surface.

Mining related

activities

Ground water Increase in groundwater

quantity

7.2.4.2.9 (c the amount of water used for dust suppression

should be enough to keep dust suppressed but not

enough to cause ponding or increased infiltration.

C




Mining related

activities

Air quality Dust generation 7.2.4.2.10 (c Suppress dust on cleared land,

C




Mining related

activities

Visual aspects Visual impact of dust 7.2.4.2.14 (a Suppress dust on cleared land,

C




Mining related

activities

I&APs Nuisance dust and noise 7.2.4.2.16 (a Suppress dust on cleared land,

C




Mining related

activities



7.2.4.2.16 (i Suppress dust on cleared land,

C






SAS6652





Compliance


Rehabilitation

activities


C




Rehabilitation

activities

Surface water Decrease in surface water 7.2.6.2.8 (a Suppress dust on cleared land,

C




Rehabilitation

activities

Air quality Dust generation 7.2.6.2.10 (a Suppress dust on cleared land,

C




Clearing of land Vegetation Minimisation of physiological

processes

7.2.2.1.17.6 (d Implement a dust suppression programme

on all disturbed soil areas where dust can be generated

due to vehicle movement or wind within the surface land

use area,

C




Mining related

activities

Visual aspects Visual impact of lights 7.2.4.2.14 (d Use directional lighting where possible, C

Directional lighting was installed where practically possible throughout the

shaft area.

Mining related

activities



7.2.4.2.16 (f Use directional lighting where possible, C


shaft area.

Construction of

infrastructure

Visual aspects Visual impact of lights 7.2.2.2.14 (d Use directional lighting where possible, C


shaft area.

Transport of

coal

Animal life Loss of life 7.2.5.2.7 (c Monitor fencing of the conveyor route to

ensure that there are no holes. C

Daily security patrols are undertaken and should any concerns be identified;

this would be communicated to the responsible person.

SCS undertakes weekly proactive site inspections along the conveyor belt

route.

Underground

mining of coal

Soil Degradation of soil quality 7.2.3.2.3 (c Only clean or suitably treated water should be

released into the environment (depending on the

catchment objectives and license conditions),

NC

Currently, the treated effluent discharged from the Sewage Treatment Plant

(STP) does not comply with the qualities set out in the Water Use Licence

(WUL). The STP was designed and constructed to treat sewage to the

standards provided for in the General Authorisation regulations. However,

the water qualities specified in the WUL are more stringent and therefore,

the STP effluent qualities do not comply with the necessary limits. An

amendment application to the WUL was prepared and submitted in 2017.

No authorisation has been issued to date.

Underground

mining of coal


capability

7.2.3.2.4 (c Only clean or suitably treated water should be

released into the environment (depending on the

catchment objectives and license conditions),

NC











SAS6652





Compliance


Underground

mining of coal


quality

7.2.3.2.8 (c Only clean or suitably treated water should be

released into the environment,

NC









Mining related

activities

Surface water Increase in catchment yield 7.2.4.2.8 (i Monitor water and only release water if the

quality is good (as per license conditions),

NC









Mining related

activities

Sensitive

landscapes

Alteration in structure and

functioning of sensitive

landscapes

7.2.4.2.13 (a Only discharge water that is clean,

NC









Mining related

activities

Sensitive

landscapes



landscapes

7.2.4.2.13 (b Only discharge water according to Integrated

Water Use License conditions,

NC









Mining related

activities

Sensitive

landscapes



landscapes

7.2.4.2.13 (c If water is discharged not under license

conditions, appoint a qualified specialist to determine and

assist in implementing additional mitigation measures, C

A qualified Environmental Assessment Practitioner (EAP) was contracted to

prepare a WUL amendment application to request more appropriate limits

for effluent discharge qualities, as the qualities are currently in line with the

limits of the General Authorisation Regulations.

Underground

mining of coal

Soil Degradation of soil quality 7.2.3.2.3 (b No dirty water should be allowed to leave the


exceptional flood event),

NC

Contaminated water (oily water) was observed in clean water areas on site,

which discharge into the environment.

Underground

mining of coal


capability

7.2.3.2.4 (b No dirty water should be allowed to leave the


exceptional flood event),

NC





SAS6652





Compliance


Underground

mining of coal


quality

7.2.3.2.9 (c No dirty water should be allowed to leave the


exceptional flood event, as per the National Water Act, Act

36 of 1998, and only under license conditions),

NC



Transport of

coal


quality

7.2.5.2.8 (f The conveyor belt should be monitored in order

to determine if any spillages have occurred so that they

can be timeously cleaned up,

C

Coal spillages forms part of the weekly proactive maintenance checklist that

is filled in by the SCS artisans responsible for the inspections.

Transport of

coal


quality

7.2.5.2.9 (f The conveyor belt should be monitored in order

to determine if any spillages have occurred so that they

can be timeously cleaned up,

C

Coal spillages forms part of the weekly proactive maintenance checklist that

is filled in by the SCS artisans responsible for the inspections.

Mining related

activities


quality

7.2.4.2.8 (e Berms and trenches must be monitored

regularly to ensure they are not blocked, C

Berms and trenches are monitored regularly to ensure no dirty material is

present that could result in blockages.

Underground

mining of coal

Soil Pollution of soils by spillage 7.2.3.2.3 (e Spillages should be cleaned up immediately,

NC

At the time of the audit, various minor oil spills were noticed on the paved

area, as well as on soil where vehicles are parked. It was also noticed that

refuelling is done to the point of overflow, as evident from hydrocarbon spills

at the refuelling area and at the decline shaft. After a repeat of various

incidents, a Management Site Inspection was held in August 2019. This was

used to highlight the issues and appoint responsible people to address

these concerns. However, it was found that these issues have not yet

successfully been addressed.

Underground

mining of coal

Soil Pollution of soils by spillage 7.2.3.2.3 (f Spillages should be neutralized if necessary




Underground

mining of coal

Soil Pollution of soils by spillage 7.2.3.2.3 (g One the spillage has been cleaned up the




Underground

mining of coal



7.2.3.2.1 (b No high extraction mining should take place

underneath watercourses and sensitive landscapes, C

At the time of the audit, the ECO indicated that no high extraction mining

has occurred within the 500 m buffer zones around water courses and

sensitive landscapes.

Transport of

coal


processes

7.2.5.2.6 (h Ensure that the hauls trucks and / or conveyor

belt are covered so as to minimize dust generation, C

At the time of the audit, no trucks transporting coal were noted. During

discussion with the Environmental Practitioner from SCS, it was confirmed

that when trucks are used (breakdown of conveyor), the trucks are covered

to minimise dust generation.

Underground

mining of coal


quality

7.2.3.2.9 (g Spillages should be timeously and effectively

cleaned up so as to prevent infiltration of pollutants,

NC











SAS6652





Compliance


Mining related

activities

Soil Pollution of soils by spillage 7.2.4.2.3 (a Spillages should be cleaned up immediately,

NC









Mining related

activities

Soil Pollution of soils by spillage 7.2.4.2.3 (b Spillages should be neutralized if necessary




Rehabilitation

activities

Surface water Pollution of surface water by

spillage

7.2.6.2.8 (f Spillages should be cleaned up immediately,

NC









Rehabilitation

activities

Surface water Pollution of surface water by

spillage

7.2.6.2.8 (g Spillages should be neutralized if necessary




Rehabilitation

activities

Ground water Pollution of groundwater by

spillage

7.2.6.2.9 (a Spillages should be cleaned up immediately,

NC









Rehabilitation

activities

Ground water Pollution of groundwater by

spillage





Mining related

activities


quality

7.2.4.2.8 (a Monitor water levels in the pollution control

dam to ensure that they comply with GN704, C

At the time of the audit the PCDs were operated below the 800 mm

freeboard. The levels of the dams are monitored on a continuous basis on

SCADA.

Transport of

coal

Air quality Dust generation 7.2.5.2.10 (b Ensure that haul trucks are covered with

tarpaulins, C

At the time of the audit, no trucks transporting coal were noted. During

discussion with the Environmental Practitioner from SCS, it was confirmed

that when trucks are used (breakdown of conveyor), the trucks are covered

to minimise dust generation.

Underground

mining of coal

Air quality Decrease in air quality due

to dust

7.2.3.2.10 (a Fit all vehicles that will operate underground

with custom exhaust systems which filter exhaust fumes. C

Occupational health monitoring is undertaken to determine exposure of

employees to exhaust fumes. In addition, the Ventilation Team continuously

monitors underground air quality. Maintenance is undertaken on any



SAS6652





Compliance


equipment that is seen to result in an unacceptable level of exhaust fume

emissions.

Underground

mining of coal

Air quality Decrease in air quality

underground

7.2.3.2.10 (b Fit all vehicles that will operate underground

with custom exhaust systems which filter exhaust fumes.

C

Occupational health monitoring is undertaken to determine exposure of

employees to exhaust fumes. In addition, the Ventilation Team continuously

monitors underground air quality. Maintenance is undertaken on any

equipment that is seen to result in an unacceptable level of exhaust fume

emissions.

Transport of

coal

Socio- economic

structure

Upliftment of individuals /

organizations

7.2.5.2.15 (a Give preference to local contractors, NC

At the time of the audit, no evidence was available to indicate that local

contractors are provided preference when contractors are appointed.

Underground

mining of coal

Animal life Frightening of fauna 7.2.3.2.7 (b Any fencing should allow an opportunity for


construction activates, but prevent re-entry,

C

At the time of the audit, it was confirmed that smaller animals can pass

through the fence. These include mongooses and servals.

Mining related

activities



construction activities, but prevent re-entry,

C



Mining related

activities

Animal life Loss of life 7.2.4.2.7 (g Any fencing should allow an opportunity for


construction activates, but prevent re-entry,

C



Rehabilitation

activities



rehabilitation activities, but prevent re-entry.

C



Mining related

activities

Surface water Increase in catchment yield 7.2.4.2.8 (k Maintain sewage treatment works to ensure

that it operates optimally,

C

Although the treated effluent does not comply with the water qualities

indicated in the WUL, a number of actions have been taken to increase the

optimum performance of the Plant. More effective equipment maintenance

and replacement has been done. This includes optimisation of the efficiency

of the aeration tank and this will be done by implementing level indicators on

the basin.

Underground

mining of coal


quality

7.2.3.2.9 (f Ensure that the ROM stockpiling is only

conducted within the designated area, and that the ROM

stockpile area is lined to limit infiltration,

C

The ROM stockpiles are kept within the boundaries of the dirty water

catchment, which flows via a silt trap to the PCD.

Underground

mining of coal

Vegetation Impact on surrounding

vegetation as a result of the

use of the ROM stockpile

7.2.3.2.6 (d Ensure that the ROM stockpile remains within

its designated area. C



Underground

mining of coal

Soil Degradation of soil quality 7.2.3.2.3 (d Ensure that stockpiling of ROM coal is only

undertaken within the designated and purposefully

constructed area,

C



Mining related

activities

Visual aspects Visual impact of lights 7.2.4.2.14 (f Draw blinds at night to limit the light emitted

from inside buildings, C

Although all offices have been fitted with blinds, motion sensitive sensors

were implemented to ensure that lights are turned off.



SAS6652





Compliance


Mining related

activities



7.2.4.2.16 (h Draw blinds at night to limit the light emitted

from inside buildings, C

Although all offices have been fitted with blinds, motion sensitive sensors

were implemented to ensure that lights are turned off.

Mining related

activities


quality

7.2.4.2.8 (f Pumps should be regularly checked to ensure

that they are functioning optimally, C

All pumps are put onto a planned maintenance schedule; and a job card is

then issued to ensure that the work is undertaken. The pumps are also on

SCADA and continuously monitored by the control room.

Mining related

activities

Ground water Increase in groundwater

quantity

7.2.4.2.9 (d Pumps should be regularly checked to ensure

that they are functioning optimally, C

All pumps are put onto a planned maintenance schedule; and a job card is

then issued to ensure that the work is undertaken. The pumps are also on

SCADA and continuously monitored by the control room.

Mining related

activities

Air quality Decrease in air quality as a

result of additional vehicle

movement

7.2.4.2.10 (a Maintain and service all machinery and

vehicle on a regular basis as per the requirements of the

specific machinery and vehicles,

C

All machinery and vehicles are maintained and serviced according to a

preventative maintenance schedule.

Mining related

activities

Animal life Loss of life 7.2.4.2.7 (j Ensure that all dirty water containment facilities

are sufficiently fenced to prevent animals from entering the

area,

C

All dirty water containment facilities are sufficiently fenced to prevent

unauthorised access to the PCDs.

Clearing of land Visual aspects Visual impact of dust 7.2.2.1.17.14 (b Limit vehicle movement to designated

roads wherever possible, C

Access roads have been constructed for vehicle movement. No vehicles

were noticed to move in undesignated roads or areas.

Underground

mining of coal

Animal life Frightening of fauna 7.2.3.2.7 (c Restrict vehicle movement to designated

pathways. C



Underground

mining of coal


and noise

7.2.3.2.16 (e Limit vehicle movement to designated roads

wherever possible, C



Mining related

activities

Visual aspects Visual impact of dust 7.2.4.2.14 (b Limit vehicle movement to designated roads




Transport of

coal

I&APs Nuisance dust and noise 7.2.5.2.16 (b Limit vehicle movement to designated roads




Mining related

activities

I&APs Nuisance dust and noise 7.2.4.2.16 (b Limit vehicle movement to designated roads


Access roads have been constructed for vehicle movement. No vehicle

movement were noticed to move in undesignated roads or areas.

Rehabilitation

activities

Air quality Dust generation 7.2.6.2.10 (c Limit vehicle movement to designated roads





generation

7.2.2.1.17.16 (b Limit vehicle movement to designated


Access have been constructed for vehicle movement. No vehicles were

noticed to move in undesignated roads or areas.

Clearing of land Soil Compaction of soil 7.2.2.1.17.3 (f Restrict vehicle access to stockpiles, C

Access control is implemented at the stockpiles. No vehicles were observed

at the stockpile area at the time of site visit.

Clearing of land Soil Soil erosion 7.2.2.1.17.3 (c Limit vehicle movement on stockpiles to

prevent compaction of soils, C

Access control is implemented at the stockpiles. No road traverses the

topsoil stockpile.

Clearing of land Soil Compaction of soil 7.2.2.1.17.3 (e Limit vehicle movement on stockpiles to

prevent compaction of soils. C

Access control is implemented at the stockpiles. No road traverses the

topsoil stockpile.



SAS6652





Compliance


Clearing of land Ground water Decrease in groundwater

recharge

7.2.2.1.17.9 Prevent compaction of soils by limiting vehicle

movement to prescribed pathways. C

Access control is implemented at the stockpiles. No road traverses the one

topsoil stockpile

Clearing of land Air quality Dust generation 7.2.2.1.17.10 (c Limit vehicle movement to designated




Mining related

activities

Animal life Loss of life 7.2.4.2.7 (h Restrict vehicle movement to designated

pathways. C



Mining related

activities


pathways, C



Mining related

activities

Air quality Dust generation 7.2.4.2.10 (e Limit vehicle movement to designated roads




Rehabilitation

activities


pathways, C



Clearing of land Soil Soil erosion 7.2.2.1.17.3 (d Regularly inspect and maintain stockpiles

to ensure timeous rehabilitation of erosion from side

slopes,

C

A weekly inspection of the overburden stockpile and soil erosion is being

undertaken on site.

Transport of

coal

Air quality Decrease in air quality due

to gaseous emissions

7.2.5.2.10 (c Maintain and service coal trucks on a regular

basis as be the requirements of the vehicles, C

A Standard Operating Procedure (SOP) and task observation is in place

which requires that all tipper trucks be inspected on a daily basis.

Underground

mining of coal

Animal life Frightening of fauna 7.2.3.2.7 (d Restrict speed of vehicles at all times. C

A speed limit of 40km/hr is implemented on site.

Mining related

activities

Animal life Frightening of fauna 7.2.4.2.7 (d Restrict speed of vehicles at all times, C


Mining related

activities

Animal life Loss of life 7.2.4.2.7 (i Restrict speed of vehicles at all times. C


Mining related

activities


quality

7.2.4.2.8 (h Ensure waste is suitably disposed of in

labelled bins, C

A SOP for waste management is available. The separation of waste is

implemented throughout the mine. Hazardous waste is segregated and

stored in appropriate containers and is later collected by Interwaste and is

disposed of at a permitted waste disposal site.

Mining related

activities


quality

7.2.4.2.9 (b Ensure that waste is appropriately separated

and disposed of in marked containers, C

A SOP for waste management is available. The separation of waste is

implemented throughout the mine. Hazardous waste is segregated and

stored in appropriate containers and is later collected by Interwaste and is

disposed of at a permitted waste disposal site.

Mining related

activities

Animal life Increase in abundance of

pests (mice, rats, etc.)

7.2.4.2.7 (e Dispose of domestic waste regularly as per

waste management procedure, C

A SOP for waste management is available. At the time of the audit the

general waste was removed by Interwaste and then disposed of to the

Secunda landfill site.

Construction of

infrastructure

Animal life Increase in abundance of

pests (mice, rats, etc.)

7.2.2.2.7 Dispose of domestic waste regularly as per

waste management procedure, C

A SOP for waste management is available. At the time of the audit the

general waste was removed by Interwaste and then disposed of to the

Secunda landfill site.



SAS6652





Compliance


Rehabilitation

activities

Animal life Frightening of fauna 7.2.6.2.7 (d Restrict speed of vehicles at all times, C


Underground

mining of coal

Vegetation Impact on surrounding

vegetation as a result of the

use of the ROM stockpile

7.2.3.2.6 (c Implement a dust suppression programme on

all disturbed areas as well as the ROM stockpile, C

A dust suppression programme is implemented at the coal transfer stations

and at the product stockpiles at the throw out area.

Underground

mining of coal


quality

7.2.3.2.9 (d Only clean or suitably treated water should be

released into the environment,

NC









Mining related

activities

Socio- economic

structure

Community projects 77.2.4.2.15 (e Ensure that the tender process is fair and

well documented,

C


procedures.








SAS6652



SAS6652



9.2 Summary of Level of Compliance

A summary of the compliance to operational phase conditions of the EA and EMPr is provided

on Table 9-3 below.

Table 9-3: Compliance Rating: EA and EMPr

Total

Number of

Conditions

Total

Compliance

Total Non-

Compliances

Total Not

Applicable

Total

possible

score

Score

EA 84 57 3 24 60 95%

EMPr 328 196 39 93 235 83.4%

10 Conclusion and Findings

The main findings and areas of non-compliance included the following:

● Erosion was noticed at various areas, including at the STP, the outlet of the stormwater

drain and at the reservoirs. This is due to the lack of vegetation. Erosion was also noted

along the SCS conveyor as a result of steep slopes and lack of stability measures;

● Contaminated water (oily water) was observed in clean water areas on site;

● Various oil spills were noticed on the paved areas where vehicles are parked;

● The general housekeeping around the site was found to be insufficient. Stormwater

drains were clogged with mixed mine waste, thus preventing the flow of water through

the system. Clean and dirty water drains were not separated; and

● Dirty oily rags were found in clean water trenches. Sediment and coal dust was also

observed in clean water trenches during the time of audit.

external environmental audits of the impumelelo colliery · 2020. 12. 15. · external...

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