sigma colliery: mooikraal and 3 shaft environmental audit

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

Sigma Colliery: Mooikraal and 3 Shaft Environmental Audit,

2020

Audit Report

Prepared for:

Sasol Mining (Pty) Ltd: Sigma Mooikraal Colliery

Project Number:

SAS6651

February 2021

mailto:[email protected]

DIGBY WELLS ENVIRONMENTAL

www.digbywells.com ii

This document has been prepared by Digby Wells Environmental.

Report Type: Audit Report

Project Name: Sigma Colliery: Mooikraal and 3 Shaft Environmental Audit,

2020

Project Code: SAS6651

Name Responsibility Signature Date

Puleng Chabeli Auditor & Report

Compiler

November/December

2020

Mia Smith 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.

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EXECUTIVE SUMMARY

Introduction

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

(hereinafter Sasol Mining) to undertake an Environmental Audit for the Sigma Colliery:

Mooikraal and the 3 Shaft Operations (hereinafter Mooikraal) near Sasolburg, Free State

Province. The audit was undertaken against the conditions and commitments of the

Environmental Authorisation (EA) and Environmental Management Programme (EMPr) for

Mooikraal.

The audit was done in fulfilment of the environmental auditing requirements specified in

Regulation 34 of the Environmental Impact Assessment (EIA) 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).

Methodology

The following methodology was used to undertake an environmental audit:

● An *.xsl format checklist of the EA conditions was reviewed and EMPr commitments

was prepared;

● Documentation provided by Sasol Mining was reviewed;

● A Microsoft Teams (MS Teams) meeting was held with Ms Lisa Grobler on

Wednesday, 16 September 2020 to verify findings of the documentation review phase;

● A physical site inspection was undertaken on 12 November 2020 with Ms Lisa Grobler;

and

● The audit report was compiled in accordance with Appendix 7 of the EIA Regulations,

2014 and compliance scoring was done in accordance with the evaluation criteria in

Table 1 below.

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

evaluation criteria described in Table 1.

Table 1: Evaluation Criteria

Non-Compliance

(NC)

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

to stated commitments of the EA and EMPr.

Compliance (C)

These are areas which were found compliant as observed during the site

visit, and evidence provided, to the stated EA conditions and commitments

of the EMPr.

Not Applicable

(N/A)

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

phase of the activity, i.e. construction, decommissioning phase

commitments.

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Compliance Scores

The compliance scores against the EA and EMPr are shown in Table 2 below. Mooikraal

scored 94% compliance against the EA conditions and 89% against the EMPr commitments.

Table 2: Compliance Scores

Criteria EA Conditions % EMPr Commitments %

Compliance 49 94 76 89

Non-Compliance 3 6 9 11

Not Applicable 30 - 32 -

Total Applicable 52 100 85 100

Summary of EA Non-Compliances

Three non-compliances were found in relation to soil contamination as a result of the coal

contaminated stormwater runoff at 3 Shaft coal handling area into the Leeuspruit. Condition

2.26 of the EA Isometrix checklist states that “the waste storage site must have a firm,

impermeable, chemical resistant floors and a roof to prevent direct sunlight and rain water

from getting in contact with the waste.” The ISO yard is concreted, but does not have roofing.

It is recommended that Mooikraal either investigates an option to install roofing at the ISO yard

to comply to this condition or to apply for an amendment of this EA condition.

Summary of EMPr Non-Compliances

The non-compliances identified are related to the stormwater management measures at 3

Shaft of the coal contaminated surface / stormwater runoff from the 3 Shaft coal handling

facility. It is recommended that measures be taken to mitigate against the surface runoff,

especially now during the rainy season. The other non-compliance is related to ambient noise

monitoring not being undertaken at regular intervals.

A Regulation 31 Amendment Application was submitted to the DMRE and DWS and proof of

submission was received in November 2019. A decision from the DMRE and DWS is still

pending on this application. The application seeks authorisation and approval to undertake

the following additional activities within the Mooikraal Mining Right Area (MMRA) and 3 Shaft:

● Demolition activities at the 3 Shaft which includes the demolition of the existing

conveyor belting, crushing facility and coal bunker which is currently situated within a

wetland;

● Relocation of the primary crusher at 3 Shaft (outside of wetland area and to the existing

coal stockpile area) and reconfiguration of the associated conveyor belt series;

● Rehabilitation of affected wetland area at 3 Shaft; and

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● Drilling of exploration, monitoring, rescue and downcast boreholes within 500 m of a

wetland and associated access roads (some of which are located within the vicinity of

water resources).

An application for a WUL for Section 21 water uses associated with the proposed new

activities was submitted to the DWS and is pending approval as per NWA requirements,

namely:

● Relocation of the conveyor belt and crusher plant;

● Construction of stormwater management systems within 500 m of the wetlands; and

● The remediation of a wetland and a wetland crossing associated with a conveyor belt

series at 3 Shaft.

The current non-compliances against Mooikraal are as a result of the abovementioned

Regulation 31 Amendment Application and WUL Application not yet being approved. Approval

of these authorisations will allow Mooikraal to implement the measures related to the

contamination of the Leeuspruit from the stormwater runoff from the coal handling facility at 3

Shaft.

Financial Provisioning

Mooikraal is an underground operation therefore very limited concurrent rehabilitation is

undertaken during the operational phase of the mine. Once the shaft has reached its Life of

Mine (LoM), rehabilitation will be undertaken to remove all infrastructure from the site and seal

the boxcut/adit. After decommissioning, the box-cut and adit will be filled with the overburden

stockpiles material and concrete from demolition of infrastructure, i.e., building rubble.

An update of the Financial Provisioning for Mooikraal, 3 Shaft and the Old Sigma Coal

Handling was undertaken and finalised in March 2020. The Financial Provisioning is shown in

Table 2.

Table 2: Financial Provisioning

Operation Financial Provisioning

Mooikraal R 90 127 194.00

3 Shaft R 11 562 839.00

Old Sigma Coal Handling R 37 090 862.00

Grand Total (ZAR) R 138 780 895.00

Conclusion

Mooikraal was found 93% compliant with the EA conditions and 81% compliant with the EMPr

commitments. There has been an improvement in EA compliance with a 4% increase from the

2019 environmental audit. Compliance to the EMPr commitments is still 81% as found in the

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2019 audit. However, more conditions have been identified as not applicable, with less non-

compliance commitments.

When the Regulation 31 Application is approved by the competent authorities, the stormwater

measures at 3 Shaft coal handling facility can be implemented and effective management of

the stormwater can be implemented.

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TABLE OF CONTENTS

1 Introduction ....................................................................................................................... 1

1.1. Project Background ................................................................................................. 1

1.1.1. Current Mining Activities .................................................................................. 1

1.2. Objectives of the Audit............................................................................................. 2

1.3. Terms of Reference ................................................................................................. 3

2. Methodology...................................................................................................................... 4

3. Assumptions and Limitations ............................................................................................ 4

4. Auditor Details & Declaration ............................................................................................ 5

4.1. Auditor Details ......................................................................................................... 5

4.2. Declaration .............................................................................................................. 5

5. Site Observations .............................................................................................................. 6

5.1. Water Management ................................................................................................. 6

5.1.1. Sewage Treatment Plant ................................................................................. 6

5.1.2. Sumps ............................................................................................................. 7

5.1.3. Workshop Area ................................................................................................ 9

5.1.4. Pollution Control Dams .................................................................................. 10

5.1.5. Dust Suppression at 3 Shaft .......................................................................... 11

5.2. Stormwater Management ...................................................................................... 11

5.2.1. Coal Handling Facility at 3 Shaft .................................................................... 11

5.3. Overland Conveyors .............................................................................................. 13

5.4. Waste Management .............................................................................................. 13

6. Compliance Rating .......................................................................................................... 14

6.1. Summary of EA Non-Compliances ........................................................................ 14

6.2. Summary of EMPr Non-Compliances .................................................................... 14

7. Financial Provision and Rehabilitation ............................................................................ 15

8. Conclusion ...................................................................................................................... 15

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LIST OF FIGURES

Figure 5-1: Sewage Treatment Plant ..................................................................................... 7

Figure 5-2: Sumps ................................................................................................................ 8

Figure 5-3: Silt Trap near Wash Bay ..................................................................................... 9

Figure 5-4: Water Management at the Workshop Area ....................................................... 10

Figure 5-5: North Dam Pollution Control Dam Spillway ....................................................... 10

Figure 5-6: Fogger cannons (misty area behind the conveyor belt) ..................................... 11

Figure 5-7: Coal Silo and Surface Runoff Contamination .................................................... 13

Figure 5-8: Conveyor Belt ................................................................................................... 13

LIST OF TABLES

Table 1-1: Contents of this report in accordance with Appendix 7 of EIA Regulations, 2014 . 3

Table 2-1: Evaluation Criteria ................................................................................................ 4

Table 4-1: Auditor Details ...................................................................................................... 5

Table 6-1: Compliance against EA and EMPr ..................................................................... 14

Table 7-1: Financial Provisioning ........................................................................................ 15

LIST OF APPENDICES

Appendix A: EA Checklist

Appendix B: EMPr Checklist

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1 Introduction

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

(hereinafter Sasol Mining) to undertake an Environmental Audit for the Sigma Colliery:

Mooikraal and the 3 Shaft Operations (hereinafter Mooikraal) near Sasolburg, Free State

Province. The audit was undertaken against the conditions and commitments of the

Environmental Authorisation (EA) and Environmental Management Programme (EMPr) for

Mooikraal.

The audit was done in fulfilment of the environmental auditing requirements specified in

Regulation 34 of the Environmental Impact Assessment (EIA) 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).

1.1. Project Background

Sasol Mining commenced with its mining operations at Sasol Sigma Colliery in the 1950s with

the aim to supply coal to Sasol Chemical Industries, now referred to as Sasolburg Operations

(SO) from both its underground and strip-mining operations. The Wonderwater and Mohlolo

shafts ceased operations in 2006.

In 2005, Mooikraal became the operational shaft to supply coal to the SO. Mooikraal is located

approximately 17.7 km southwest of Sasolburg in the Fezile Dabi District Municipality, Free

State Province. Mooikraal is an underground coal mine operation and utilises the underground

board and pillar mining method and in some area’s high extraction mining (i.e. rib-pillar

extraction). Mooikraal has a Life of Mine (LoM) of 34 years and will be operational until 2039.

1.1.1. Current Mining Activities

Mooikraal is an underground mine that is currently mining five underground sections.

Underground workings are accessed via an incline shaft which was constructed utilising a box

cut method. The soil extracted from the incline shaft was stockpiled along the outside of the

incline shaft and allowed to vegetate naturally. This soil will be utilised once LoM is reached

and rehabilitation commences.

Vehicles, machinery and personnel both enter and exit the underground workings via the

incline shaft. Coal is extracted through the underground bord and pillar mining method,

however in some areas high extraction mining is taking place. The coal is then transported via

conveyor belt underground and brought to surface via the same incline shaft which is used to

enter the mine. The coal is brought to surface and stored in a silo that has capacity to store

one day’s volume of coal, should supply issues be identified such as the need to undertake

maintenance activities. The coal is then conveyed from Mooikraal to 3 Shaft via an overland

conveyer belt, where it is crushed and screened prior to being sent to SO for further use.

The following infrastructure is present at Mooikraal:

● Incline Shaft;

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● Pollution Control Dams (PCDs);

● Three sumps (Wash bay, fuel storage, shaft complex);

● Clean water channels;

● Soil stockpiles;

● Material laydown areas;

● One waste rock dump;

● Sewage Treatment Plant (STP);

● One waste storage area;

● Workshops;

● Bulk fuel and oil storage area;

● Conveyor belt;

● 10 ML Pipeline from Sigma Colliery: Mooikraal to SO;

● 7 ML Pipeline from Kleinvlei Shaft to SO; and

● Office Blocks.

The following infrastructure is present at 3 Shaft:

● Primary processing plant;

● Run of Mine (RoM) stockpile area;

● Stacker/ reclaimer;

● Chutes;

● Workshops;

● Waste storage area;

● Cement water transfer dam;

● Old Dams currently not in use and proposed to be demolished;

● Water reservoir for the fogger cannons;

● Conveyor belts; and

● Material storage yard.

1.2. Objectives of the Audit

The objectives of the environmental audit are:

● To determine Mooikraal’ s level of compliance with the commitments contained in the

EA and approved EMPr; and

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● To assess the appropriateness and suitability of the EA and EMPr to provide for the

mitigation of impacts associated with activities and future developments at Mooikraal.

1.3. Terms of Reference

The Environmental Audit of the EMPr and EA is a systematic, periodic, objective and

documented evaluation of Driefontein’s compliance to the audit conditions.

The audit is dictated by EIA Regulations, 2014, which sets out the requirements for auditing

compliance with the EMPr and EA.

Compliance of this report with Appendix 7 of the EIA Regulations, 2014 is summarised in

Table 1-1.

Table 1-1: Contents of this report in accordance with Appendix 7 of 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;

Section 4

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

a form as may be specified by the competent authority;

Section 4

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

environmental audit report was prepared;

Section 1.2

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


Section 2

3 (1) (e) an indication of the ability of the EMPr, 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, EMPr,

and where applicable, the closure plan;

Section 6

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

uncertainties or gaps in knowledge;

Section 3

3 (1) (g) a description of any consultation process that was

undertaken during the course of carrying out the


N/A

3 (1) (j) a summary and copies of any comments that were received

during any consultation process; and

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No Requirement Section of this Report

3 (1) (k) any other information requested by the competent authority. N/A

2. Methodology

The following methodology was used to undertake an environmental audit:

● An *.xsl format checklist of the EA conditions was reviewed and EMPr commitments

was prepared;

● Documentation provided by Sasol Mining was reviewed;

● A Microsoft Teams (MS Teams) meeting was held with Ms Lisa Grobler on

Wednesday, 16 September 2020 to verify findings of the documentation review phase;

● A physical site inspection was undertaken on 12 November 2020 with Ms Lisa Grobler;

and

● The audit report was compiled in accordance with Appendix 7 of the EIA Regulations,

2014 and compliance scoring was done in accordance with the evaluation criteria in

Table 2-1 below.

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

evaluation criteria described in Table 2-1.

Table 2-1: Evaluation Criteria

Non-Compliance

(NC)

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

to stated commitments of the EA and EMPr.

Compliance (C)

These are areas which were found compliant as observed during the site

visit, and evidence provided, to the stated EA conditions and commitments

of the EMPr.

Not Applicable

(N/A)

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

phase of the activity, i.e., construction, decommissioning phase

commitments.

3. Assumptions and Limitations

This report is subject to the following assumptions and limitations:

● The findings recorded in this report are limited to the day and time the site pictures

were taken during the physical inspection of the site;

● The site observations are also limited to the areas visited with Ms Lisa Grobler on

12 November 2020;

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● The scope of work specifically excludes an audit referred to in the Regulations on Use

of Water for Mining and Related Activities aimed at the Protection of Water Resources

(GN R704 of 4 June 1999) (GN R704)1; and

● Although care was taken to audit as comprehensively as possible, auditing is done on

a sample basis and based on the conditions as they were found on the day Ms Lisa

Grobler took the site pictures.

4. Auditor Details & Declaration

4.1. Auditor Details

Table 4-1 sets out the auditor details, qualifications and experience.

Table 4-1: Auditor Details

Details Description

Auditor: Puleng Chabeli

Qualification: BSc (Environmental Science & Legal Theory) & LLB

Experience: 4 years

Profile:

Puleng is an Environmental and Legal Services Consultant with a Bachelor of

Science and a Bachelor of Laws degree from Rhodes University. She has 3 years’

experience with environmental audits, legal compliance audits and ISO14001:2015

audits, EIAs and IWWMPs. She has undertaken the Environmental Management

System ISO14001:2015 and ISO19011:2011 training and a certified internal auditor

of these standards.

She has experience working with national policies on climate change; research and

writing opinions on issues under the United Nations Framework Convention on

Climate Change (UNFCCC) and bilateral and multinational agreements on

environmental matters at the National Department of Environmental Affairs.

4.2. Declaration

The auditor declares that they acted independently and compiled this audit report using the

information furnished by the client.

I, Puleng Chabeli, 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;

1 GN R704 in GG 20119 of 4 June 1999.

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● 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

standards, legislation 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;

and

● I declare that all the information furnished by me for this Audit is true and correct.

Signature of the Lead Auditor:

Date: February 2021

5. Site Observations

This section summarises the findings made from the documentation review, clarification

meeting via MS Teams and the physical inspection of the site undertaken on 12 November

2020.

5.1. Water Management

Mooikraal obtains potable water from the Metsimaholo Local Municipality for the office blocks

and for drinking water underground.

5.1.1. Sewage Treatment Plant

The STP shown in Figure 5-1 treats all sewage water collected from the office blocks and

change houses via a sewage network. The STP is managed by PROXA. The process at the

STP is as follows:

● Sewage water is pumped into the aeration tank where the sludge settles;

● The water then is transferred into a baffle tank;

● The water in the baffle tank is treated with chemicals, i.e. chlorine;

● The water after treatment is then discharged into the Kromelboogspruit, in accordance

with the approved Integrated Water Use Licence (IWUL);

● The settled sludge is then removed from the aeration tank and placed on the drying

beds; and

● The dried sludge is then collected in the waste skip and removed by the appointed

contractor.

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Sewage Treatment Plant (November 2020)

Aeration Tank and Drying Beds (November

2019)

Figure 5-1: Sewage Treatment Plant

5.1.2. Sumps

Three sumps are located at the Mooikraal operation to collect dirty and/or mine water

generated around the shaft complex and incline.

One sump is located near the wash bay, another near the fuel and oil storage area and the

third one is located at the incline shaft. These sumps serve as separators of hydrocarbons

and sediment from water. The dirty water then drains into the South Dam PCD which then

flows into the North Dam PCD.

The Environmental Practitioner informed that the sumps were cleaned and no overflow was

observed, as seen in Figure 5-2, on site compared to the overflow observed in November

2019 at the time of the 2019 environmental audit.

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The fenced and concreted sumps (November 2020)

Figure 5-2: Sumps

The silt trap near the wash bay shown in Figure 5-3 is full and needs to be cleaned out. The

Environmental Practitioner advised that the silt trap had been cleaned out and a Purchase

Order (PO) was provided as proof of the work that was commissioned.

Fenced sump Concreted sump

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Wash bay area and silt trap

Silted and full silt trap

Figure 5-3: Silt Trap near Wash Bay

5.1.3. Workshop Area

Ponding was observed at the entrance of the workshop area as indicated in Figure 5-4. This

is due to the heavy rains experienced during the rainy season.

There are containers at the entrance of the workshop area and some used/discarded material

that is not placed in the ISO yard or on wooden pallets. Some equipment is also placed directly

on the soil with some placed on concreted area or on steel bunds. Housekeeping in this area

should be improved.

Ponding and the containers at the entrance to

the workshop area

Equipment on soil and others on concreted

areas and steel bunds

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Ponding close to the fuel storage area and oil

skimmer

Oil contaminated water

Figure 5-4: Water Management at the Workshop Area

5.1.4. Pollution Control Dams

The spillway of the North Dam PCD was fixed in 2019. The PCDs are in good condition, they

are full of reeds and they are not overflowing as seen in Figure 5-5.

Figure 5-5: North Dam Pollution Control Dam Spillway

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5.1.5. Dust Suppression at 3 Shaft

Dust suppression is undertaken at 3 Shaft using fogger cannons installed along the haul road.

Access to the 3 Shaft was not possible due to wet conditions. The fogger cannons were

operational and could be seen from a distance via the fence in Figure 5-6.

Figure 5-6: Fogger cannons (misty area behind the conveyor belt)

5.2. Stormwater Management

Berms are used to prevent clean water from entering the incline shaft and divert the water

around the shaft area. All contaminated stormwater from the wash bay, parking areas and

bulk storage areas at the Mooikraal Shaft is contained in the dirty water system which

comprises a network of sumps and silt traps which overflows into the PCD. From the North

PCD this water is pumped to the 3 Shaft for dust suppression or the SO as part of their water

reticulation system.

5.2.1. Coal Handling Facility at 3 Shaft

Dirty stormwater at the coal handling facility is not contained to the dirty water area and is

resulting in the contamination of soil and coal contaminated surface runoff as shown in Figure

5-7.

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Coal silo

Coal runoff

Surface runoff

Coal residue

Contamination on the adjacent land to the coal

handling facility

Water contamination on the adjacent land to the

coal handling facility

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Figure 5-7: Coal Silo and Surface Runoff Contamination

5.3. Overland Conveyors

An 18 km overland conveyor is used to convey coal from Mooikraal to 3 Shaft. This conveyor

crosses wetlands and watercourses. Biomonitoring site visit was undertaken in October 2020.

The conveyor from Mooikraal to 3 Shaft

The culverts are silted

Signs of erosion underneath conveyor belt

Sedimentation

Figure 5-8: Conveyor Belt

5.4. Waste Management

Waste is stored at the ISO yard and separated into the various waste streams at Mooikraal,

namely wood, scrap metal and hazardous waste. However, all waste at Mooikraal is

considered to be hazardous as all waste obtained from underground working is considered to

be contaminated by hydrocarbons. The waste is removed by the appointed Service Provider

to a registered landfill.

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6. Compliance Rating

The compliance scores against the EA and EMPr are shown in Table 6-1 below. Mooikraal

scored 94% compliance against the EA conditions and 89% against the EMPR commitments.

Table 6-1: Compliance against EA and EMPr

Criteria EA Conditions % EMPr Commitments %

Compliance 49 94 76 89

Non-Compliance 3 6 9 11

Not Applicable 30 - 32 -

Total Applicable 52 100 85 100

6.1. Summary of EA Non-Compliances

Three non-compliances were found in relation to soil contamination as a result of the coal

contaminated stormwater runoff at 3 Shaft coal handling area into the Leeuspruit. Condition

2.26 of the EA Isometrix checklist states that “the waste storage site must have a firm,

impermeable, chemical resistant floors and a roof to prevent direct sunlight and rain water

from getting in contact with the waste.” The ISO yard is concreted, but does not have roofing.

It is recommended that Mooikraal either investigates an option to install roofing at the ISO yard

to comply to this condition or to apply for an amendment of this EA condition.

6.2. Summary of EMPr Non-Compliances

The non-compliances identified are related to the stormwater management measures at 3

Shaft of the coal contaminated surface / stormwater runoff from the 3 Shaft coal handling

facility. It is recommended that measures be taken to mitigate against the surface runoff,

especially now during the rainy season. The other non-compliance is related to ambient noise

monitoring not being undertaken at regular intervals.

A Regulation 31 Amendment Application was submitted to the DMRE and DWS and proof of

submission was received in November 2019. A decision from the DMRE and DWS is still

pending on this application. The application seeks authorisation and approval to undertake

the following additional activities within the Mooikraal Mining Right Area (MMRA) and 3 Shaft:

● Demolition activities at the 3 Shaft which includes the demolition of the existing

conveyor belting, crushing facility and coal bunker which is currently situated within a

wetland;

● Relocation of the primary crusher at 3 Shaft (outside of wetland area and to the existing

coal stockpile area) and reconfiguration of the associated conveyor belt series;

● Rehabilitation of affected wetland area at 3 Shaft; and

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● Drilling of exploration, monitoring, rescue and downcast boreholes within 500 m of a

wetland and associated access roads (some of which are located within the vicinity of

water resources).

An application for a WUL for Section 21 water uses associated with the proposed new

activities was submitted to the DWS and is pending approval as per NWA requirements,

namely:

● Relocation of the conveyor belt and crusher plant;

● Construction of stormwater management systems within 500 m of the wetlands; and

● The remediation of a wetland and a wetland crossing associated with a conveyor belt

series at 3 Shaft.

The current non-compliances against Mooikraal are as a result of the abovementioned

Regulation 31 Amendment Application and WUL Application not yet being approved. Approval

of these authorisations will allow Mooikraal to implement the measures related to the

contamination of the Leeuspruit from the stormwater runoff from the coal handling facility at 3

Shaft.

7. Financial Provision and Rehabilitation

Mooikraal is an underground operation therefore very limited concurrent rehabilitation is

undertaken during the operational phase of the mine. Once the shaft has reached its Life of

Mine (LoM), rehabilitation will be undertaken to remove all infrastructure from the site and seal

the boxcut/adit. After decommissioning, the box-cut and adit will be filled with the overburden

stockpiles material and concrete from demolition of infrastructure, i.e., building rubble.

An update of the Financial Provisioning for Mooikraal, 3 Shaft and the Old Sigma Coal

Handling was undertaken and finalised in March 2020. The Financial Provision is shown in

Table 7-1.

Table 7-1: Financial Provisioning

Operation Financial Provision

Mooikraal R 90 127 194.00

3 Shaft R 11 562 839.00

Old Sigma Coal Handling R 37 090 862.00

Grand Total (ZAR) R 138 780 895.00

8. Conclusion

Mooikraal scored 94% compliance against the EA conditions and 89% against the EMPR

commitments as shown in Table 6-1 above.

Audit Report


SAS6651



When the Regulation 31 Application and WUL is approved by the competent authorities, the

stormwater measures at 3 Shaft coal handling facility can be implemented and effective

management of the stormwater can be implemented.

Appendix A: EA Checklist

The condition of the obligations.

Please indicate the

status: Compliant,

Non-compliant or

Not applicable from

the auditor in this

ConditionsAudit compliance

status / Answer

1.1 Sasol Mining (Pty) Ltd (herein referred to as the holder) shall

be responsible for ensuring compliance with the conditions of this

approval letter and the environmental management

commitments/measures contained in the EMPr. This includes any

person acting on the holder's behalf, including but not limited to

an agent, servant, contractor, subcontractor, employee,

consultant or any person rendering a service to the mining area in

which this EMPr relates to.

C

1.2 All mining activities must adhere to the provisions of

regulations 56, 64, 66, 68, 69, 70, 71 and 73 of the Regulations of

the MPRDAN/A

1.3 The principles set out in section 2 of the National

Environmental Management Act, 1998 (Act 107 of 1998) (NEMA)

applies to your mining operation as stipulated In section 37(1)(a)

of the MPRDA.

C

1.4 The holder must at all times give effect to the general

objectives of the integrated environmental management laid

down in Chapter 5 of NEMA as stipulated in section 38(1)(a) of

the MPRDAC

1.5 Any changes to, or deviation from the mining project

description set out in the EMPR and the mining right must be

approved in writing by the Department before such changes or

deviation may be effected. In assessing whether to grant such

approval or not, the Department may request any information as

is deems necessary to evaluate the significance and impacts of

such changes or deviation and it may be necessary for the holder

to apply for further authorization in terms of the applicable

legislation of the time.

C

1.6 Mining activities may only be carried out at the properties

covered by the mining right indicate in which this EMPr is

approved for.C

1.7 Where any of the holder's contact details change; including

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

telephonic details, the holder must notify the Department as soon

as the new details become known to the holder.

C

1.8 This approval and the approved EMPr do not negate the

responsibility of the holder to comply with any other statutory

requirements that may be applicable to the undertaking of mining

and any mining related activities. C

1.9 The holder must ensure that all areas where the authorized

mining activities occur have controlled access to ensure safety of

people and animalsC

1.10 Mine waste will be not allowed to be deposited in natural

drainage lines or erosion gulliesC

1.11 Dump structures must not be left on the surface, this

includes topsoil stockpiles, overburden stockpiles, waste rock

stockpiles, tailing dumps and slimes dams.N/A

1.12 All excavations must be backfilled to the natural surface

level; if a bulk factor exists it must be accommodated on the total

area of disturbance.N/A

1.13 A surveyed plan must be submitted every year to the

Regional Manager that indicates:C

1.13 (a A surveyed plan must be submitted every year to the

Regional Manager that indicates:

a) The positions, footprints and volumes of all topsoil stockpiles,

overburden dumps, waste rock dumps and slimes dams (Any

structure that is above the natural surface).

C

1.13 (b A surveyed plan must be submitted every year to the


b) The positions, surface areas and depths of all open pits.N/A

1.13 (c A surveyed plan must be submitted every year to the


c) The positions and surface areas of all rehabilitated areas

(please indicate the status of rehabilitation-backfilled,

profiled/landscaped, top soiled, vegetated or monitoring and

managing.

N/A

2.1 In order to ensure safety, all employees must be given the

necessary personnel protective equipment (PPE).C

2.2 This approval letter and the approved EMPr must be provided

to the site operator(s) and the requirements thereof must be

made fully known to him or her.C

2.3 Hauling routes for construction vehicles and machinery must

be clearly marked and appropriate signalling must be posted to

that effect. Furthermore, movement of construction vehicles and

machinery must be restricted to areas outside of the drainage line

or wet areas.N/A

2.4 Appropriate notification sign must be erected at the

construction site, warning the public (residents, visitors etc.)

about the hazard around the mining area and presence of heavy

vehicles and machinery.N/A

2.5 Construction must include design measures that allow surface

and subsurface movement of water along the drainage lines so as

not to impede natural surface and subsurface water flow, and

drainage measures must promote the dissipation of storm water

runoff.

N/A

2.6 Vegetation clearance must be limited on areas where the

individual activities will occur, and mitigation measures must be

implemented to reduce the risk of erosion and alien species

invasion.

C

2.7 The holder must note that in terms of the National Forest Act,

1998 (Act No.84 of 1998) protected plant species, also listed in

must not be cut, disturbed, damaged, destroyed and their

products must not be possessed, collected, removed,

transported, exported, donated, purchased or sold unless

permission is granted by the Department of Agriculture, Forestry

and fisheries.

N/A

2.8 Construction areas (e.g. material lay down areas), topsoil and

subsoil must be protected from contamination or pollution.

Stockpiling must not take place in drainage lines or areas where it

will impede surface water runoff.

N/A

2.9 If any soil contamination is noted at any phase of mining, the

contaminated soil must be removed to a licensed waste disposal

facility and the site must be rehabilitated to the satisfaction of

this Department and the Department of Water and Sanitation.

The opportunity for the onsite remediation and re-use of

contaminated soil must be investigated prior to the disposal and

this Department must be informed in this regard.NC

2.10 An integrated waste management approach must be

implemented that is based on waste minimization and must

incorporate avoidance, reduction, recycling, treatment, reuse and

disposal where appropriate. Uncontaminated rubble generated

on the premises can be re-used as backfilling material on any

relevant site (if this requirement exist). Ensure that no refuse or

rubble generated on the premises is placed, dumped or deposited

on the adjacent properties or public places and open space.

C

2.11 In terms of sections 28 and 30 of NEMA, and sections 19 and

20 of the National Water Act, 1998 (Act 36 of 1998) as amended

(NWA), any costs incurred to remedy environmental damage

must be borne by the person responsible for the damage. It is

therefore imperative that the holder reads through and

understand the legislative requirements pertaining to mining. It is

the holder's responsibility to take reasonable measures which

include informing and educating contractors and employees

about environmental risks of their work and training them to

operate in an environmentally acceptable manner.

C

2.12 Construction vehicle must be serviced and maintained in the

manner whereby no excessive smokes are produced and noise

production is reduced to acceptable levels, and to prevent oil

leaks. Contaminated soil must be remediated on site or removed

to an authorised landfill site. NC

2.13 Residents (if any) on the property (is) and surrounding the

mining areas must be informed if any unusual noisy activities are

planned.

C

2.14 Dust suppression measures must be implemented on all

exposed surface to minimize and control airborne dust.C

2.15 Should any heritage remains be exposed during operation or

any actions on the site, these must immediately be reported to

South African Heritage Resources Agency (SAHRA) and in

accordance with the applicable legislation. Heritage remains

uncovered or disturbed during earthworks must not be further

disturbed until the necessary approval has been obtained from

SAHRA. This Department must also be informed about such

exposure in writing.

N/A

2.16 Care must be taken to ensure that the material and

excavated soil required for backfilling are free of contamination

from hydrocarbons.N/A

2.17 Hydraulic fluid or chemicals required during construction

must be stored in a concrete lined surface with bund walls and

shall be designed in such a manner that any spillage can be

contained and reclaimed without any impact on the surrounding

environment. Should any spills occur it should be cleaned

immediately by removing spillage together with the polluted

solids and dispose it in the authorised disposal site permitted of

such waste. The relevant regional office of the Department of

Water and Sanitation must be notified within 24 hours of an

incident that may pollute surface and underground water

resources.

C

2.18 Chemical sanitation facilities or system such as toilets that do

not rely on the seepage of liquids must be provided with a ratio of

1 for every 15 workers. These must be placed such that they

prevent spills or leaks to the environment and must be

maintained according to the operating instructions and the

content thereof must be disposed of at an authorised waste

water treatment works. C

2.19 The holder must ensure that any water uses listed in terms

of section 21 of NWA must get authorization from Department of

Water and Sanitation prior to the commencement of such activity

(is).

C

2.20 This approval letter does not purport to absolve the holder

from its common law obligations towards the owner of the

surface of land affected.C

2.21 The holder must ensure that rehabilitation of the disturbed

areas caused by mining and mining related activities at all times

comply with the approved EMPrN/A

2.22 This approval letter may be amended or withdrawn at any

stage for non compliance and provides no relief from the

provisions of any other relevant statutory or contractual

obligations.

N/A

2.23 The holder must note that residue deposit and residue

deposit must be deposited and managed in a prescribed manner

on any site demarcated for that purpose in the EMPr. No person

may temporary or permanently deposits residue stockpile or

residue deposit on any area or site other than on site indicated on

the EMPr.

C

2.24 The holder must note that no person may commence,

undertake or conduct a waste management activity, except in

accordance, with the requirements of norms and standards

determined for that activity or a waste management licence is

issued in respect of that activity if licence is required.

C

2.25 The Department reserves the right to audit and/or inspect

the activity (is) without prior notification at any reasonable time

and at such frequency as may be determined by the Regional

Manager.

N/A

2.26 The waste storage site must have a firm, impermeable,

chemical resistant floors and a roof to prevent direct sunlight and

rain water from getting in contact with the waste.NC

2.27 The storage of hydrocarbons must have bund walls with

adequate capacity to contain the maximum volume that is stored

in the area. Uncontaminated storm water must be prevented

from coming into contact with the waste and must be diverted

away from the storage site. C

2.28 Should there be any conflicting conditions between this

approval letter and other approval granted by other authorities, it

is upon the holder to bring it to the attention of this Department

for resolution.

N/A

3.1 A copy of this approval letter and EMPr must be kept at the

property or on site office where the mining activities will be

undertaken/are being conducted. This approval letter and EMPr

must be produced to any authorised officials of the Department

who request to see it and must be made available for inspection

by any employee or agent of the holder who works or undertakes

work at the mining area.

C

3.2 The content of the EMPr and its objectives must be made

known to all contractors, subcontractors, agent and any other

people working on the site, and any updates or amendments to

the EMPr must be submitted to the Department for approval.

C

3.3 Regular monitoring and maintenance of storm water drainage

facilities must be conducted at all times, if damaged as directed

by the Department or any other relevant authority.

C

3.4 A buffer zone of 100 metres between the activity (is) and the

residential areas, cemeteries or burial grounds, Eskom power

lines and the fuel pipe line must be clearly demarcated and

maintained.

C

3.5 The holder must prevent nuisance conditions or health

hazards, or the potential creation of nuisance conditions or health

hazards.C

3.6 Mining activities must be managed and operated in

accordance with the Environmental Management Systems (EMS)

that inter alia identifies and minimises risks of pollution, including

those arising from operations, maintenance, accidents, incidents

and non-conformances and those drawn to the attention of the

holder as a result of complaintsC

3.7 The holder must ensure that all non-recyclable waste are

disposed of at waste management facilities licenced to handle

such wastes and all recyclable waste are collected by licenced

waste management facilities for recycling, reuse or treatment.

C

3.8 The holder must ensure that all liquid wastes, whose

emissions to water or land could cause pollution are diverted to

sewer, after testing water quality and receiving written approval

from the relevant local authority.

C

3.9 Non-compliance with any condition of this approval letter or

EMPr may result in the issuing of statutory orders or instruction

as per section 93 and 47 of the MPRDA.N/A

3.10 Only mining activities that are expressly specified in the

EMPr that forms part of this approval letter may be conducted,

and additional or new activities not specified herein must be

applied for by the holder and authorised in the form of an

amendment to the aforesaid EMPr before such activities may be

commenced with. This condition is also applicable in the case of

the amendment, addition, substitution, correction, and removal

or updating of any detail in the aforesaid EMPr.

N/A

3.11 Rehabilitation of the disturbed surface caused by mining

operation at all times must comply with the approved EMPr.N/A

3.12 The holder must ensure that the name and contact details

person responsible for environmental management is made

available to the Regional Manager within

30 days from the date of this approval (consolidation of mining

rights and approved EMPrs).The holder must also ensure that a

person responsible for environmental management is always

available on site to ensure that mining activities at all times

comply with the conditions of approval letter and approved EMPr

(consolidated).

C

3.13 (a The person responsible for environmental management

must:

a) Keep and maintain a detailed incidents register (including any

spillages of fuels, chemicals or any other material.

C

3.13 (b The person responsible for environmental management

must:

b) Keep a complaint register on site indicating the complaint and

how the issues were addressed, what measures were taken and

what the preventative measures were implemented to avoid re-

C

3.13 (c The person responsible for environmental management

must:

c) Keep records relating to monitoring and auditing on site and

avail them for inspection to any relevant authorised officials.

C

3.13 (d The person responsible for environmental management

must:

d) Keep copies of all environmental reports submitted to the

Department.

C

3.13 (e The person responsible for environmental management

must:

e) Keep the records of all permits, licences and authorisations

required by the operation.

C

3.13 (f The person responsible for environmental management

must:

f) Compile a monthly monitoring report and make it available to

the Department if requested.

C

3.14 The duties and responsibility of the person responsible of

environmental management should not be seen as exempting the

holder from the legal obligations in terms of the MPRDA and it

subordinate Regulations.

N/A

3.15 The footprint of the mining activities must be limited on the

areas authorised for the actual construction works and

operational activities and all areas outside of the footprint must

be regarded as a "no go" areas.

C

3.16. Erosion and soil loss must be prevented by minimizing the

construction site exposed to surface water run-off. Where

necessary erosion stabilizing action such as gabions or re-

vegetation must be implemented to prevent further habitat

deterioration.

N/A

3.17. The holder must ensure that all personnel who work with

hazardous waste are trained to deal with these potential

hazardous situations so as to minimise the risk involved. Records

of training and verification of competence must be kept by the

holder.

C

3.18. In order to prevent nuisance conditions, the holder must

ensure that all storage skips and bins are not overfilled.C

4.1 The holder must submit an Environmental Performance

Assessment Report to this Department annually as per regulation

55 of the MPRDA Regulations. The report should be submitted

manually in a form of two (2) copies which specify whether the

conditions of this approval letter and an approved EMPr are

adhered to. This Environmental Performance Assessment Report

must include the information referred to in condition 4.2 below.

C

4.2 The holder must annually assess the environmental liabilities

of the operation as contemplated in the Financial Provisioning

Regulations, 2015 and address the shortfall on the financial

provision submitted in terms of section 24P of NEMA.

C

4.3 The holder must, within 24 hours of incidents occurring, notify

this department any other relevant department of the occurrence

or detection of any incident on the site, or incidental to the

operation of the site, which has the potential to cause, or has

caused pollution of the environment, health risks, nuisance

conditions or water pollution.

N/A

5.1 The holder must ensure effective access control on the site to

reasonably prevent unauthorised entry. Signs indicating the risks

involved in unauthorised entry must be displayed at each

entrance.

C

5.2 Weather proof, durable and legible notices in at least three

official languages applicable in the area must be displayed at each

entrance to the Site. These notices must prohibit unauthorised

entry and state the hours of operation, the name, address and

telephone number of the holder and the person responsible for

the operation of the site.

C

6.1 The holder must maintain and implement an emergency

preparedness plan and review it biennially when conducting

environmental monitoring and assessment or audit and after

each emergency and or major accident. The plan must, amongst

others, include:

1. Site fire

ii. Spillage

iii. Natural disasters such as floods

iv. Industrial action

v. Contact details of police, ambulances and any emergency

centre closer to the site

C

6.2 The holder must ensure that an up to date emergency register

is kept during all phases of the mining operation. This register

must be made available upon request by the department.C

7.1 If, in the opinion of this department, nuisances or health risks

may be or is occurring on the site, the holder must initiate an

investigation into the cause of the problem or suspected problem.N/A

7.2 If, in the opinion of this department, pollution may be or is

occurring, the holder must initiate an investigation into the cause

of the problem or suspected problem. Such investigation must

include the monitoring of the water quality variables, at those

monitoring points and such frequency as may be specified by the

Department of Water and Sanitation.

N/A

7.3 Investigations carried out in terms of conditions 7.1 and 7.2

above must include the monitoring of the relevant environmental

pollution, nuisance and health risk variables, at those monitoring

points and such frequency to be determined in consultation with

the relevant Departments.

N/A

7.4 Should the investigation carried out as per conditions 7.1 and

7.2 above reveal any unacceptable levels of pollution, the holder

must submit mitigation measures to the satisfaction of this and

any other relevant Department.

N/A

8.1 The holder must apply for a closure certificate as prescribed in

the MPRDA and any other applicable legislation.N/A

8.2 The application for closure indicated above must be

submitted together with all relevant documents as prescribed in

the MPRDA and any other applicable legislation.N/A

8.3 The holder remains responsible for any environmental

liability, pollution or ecological degradation, the pumping and

treatment of extraneous water, compliance with the conditions of

this approval letter, the approved EMPr, management and

sustainable closure thereof until the Minister has issued a closure

certificate in terms of section 43 of the MPRDA. Where necessary

the Minister may retain certain portion of financial provision for

residual, health or environmental impacts that might be known in

future.

N/A

8.4 The Department, in terms of the conditions of this approval

letter shall not be responsible for any damages or losses suffered

by the holder, developer or his/her successor in any instance

where construction or operation subsequent to construction is

temporarily or permanently stopped for reasons of non-

compliance with the conditions as set out herein or any other

subsequent document or legal action emanating from this

decision.

N/A

Please indicate the comment from the auditor

Audit comments

Sasol Mining: Mooikraal is responsible for the implementation and compliance to the

EMPr.

Regulations 64, 66, 68, 69, 70 and 71 have been repealed by GN R420 of 23 March

2020. Regulation 56 sets out the principles of mine closure. Mooikraal is currently still

operational with a LoM to 2039. Therefore, this commitment is not applicable to

Mooikraal at this moment.

This commitment is noted and Mooikraal is operating taking into consideration the

legal obligations of the MPRDA and NEMA.

Section 38 of the MPRDA was repealed on 7 June 2013 by section 31 of the MPRDA.

Chapter 5 of NEMA is however still applicable and Mooikraal operates in fulfilment to

Chapter 5 and all subsequent amendments thereof.

The Mine Works Programme for Mooikraal has not been changed and Mooikraal is

still mining as specified in the EMPR. Applications for implementing surface measures

for mitigate negative environmental impacts and these have been submitted to the

competent authorities for consideration.

Mooikraal is an underground mine and is mining within the mining boundary as per

the Mining Right.

Sasol Mining: Mooikraal Colliery is still the Licencee; details have not changed.

Sasol Mooikraal undertakes Water Use Licence (WUL) audits in terms of the legal

requirement of the WUL issued in terms of the National Water Act, 1998 (Act No. 36

of 1998). They also undertake alien invasive plant species management in terms of the

National Environmental Management: Biodoversity Act, 2004 (Act No. 10 of 2004).

An Environmental LeGal Compilance Audit was undertaken in 2019 by Digby Wells.

Mooikraal and 3 Shaft are fenced off to control access to the mine site. The site has

signage boards warning against unathorised entry.

Mooikraal has an ISO yard where all waste streams are separated and stored. Waste is

then removed and disposed of by EnviroServ (the appointed service provider) and safe

disposal certificates are provided. Waste is not disposed of into the natural

environment or into erosion gullies. There were no signs of erosion gullies on site at

the time of the audit. Mooikraal is still in operation and has an overburden stockpile on the surface which

will be used to rehabilitate/backfill when Mooikraal goes into its closure and

rehabilitation phase. Therefore, for the operational phase, the overburden stockpile is

still on the surface and this condition is not yet applicable.

A borrow pit was dug at Mooikraal. The borrow pit has since naturally revegetated

and is free draining. Mooikraal is an underground mine and will only use excavations

(i.e. overburden stockpile) to backfill at the end of the mine's LoM. Therefore, this

condition is not yet applicable.

December 2020 the plan was submitted the Principal Inspector of the DMRE of

Welkom.

Mooikraal only has an overburden stockpile on surface.

Mooikraal is an underground mine and no opencast mining is taking place.

Mooikraal is an underground mine and rehabilitation will only take place at closure.

The borrow pit is the only surface area that was dug and has since revegetated and is

free draining.

Mine personnel use the necessary PPE to work underground and on the surface.

Auditors are required to have safety boots and reflective vests as a minimum

requirement to get onto the mine site.

Contractual management of service providers takes EMPR commitments and ensures

that the contractors work in accordance with the EMPR.

No construction activities took place during this audit period. For the Regulation 31

Amendment Application for constructing stormwater measures at 3 Shaft, these

measures will be put in place. However, this commitment is not applicable yet as the

application has not been approved yet.

No construction activities took place during this audit period. There are no heavy

machinery or vehicles as the coal is transported via a conveyor belt from Mooikraal to

3 Shaft. For the Regulation 31 Amendment Application for constructing stormwater

measures at 3 Shaft, these measures will be put in place. However, this commitment is

not applicable yet as the application has not been approved yet.









An alien invasive mappiung was undertaken and demarcation of Category 2 plant

species National Environmental Management: Biodiversity Act of 2004, and the Alien

and Invasive Species Regulations of 2014 (as amended).

There are no protected trees on Mooikraal or 3 Shaft.

There is no topsoil and subsoil stockpiles at Mooikraal or 3 Shaft. There is an

overburden stockpile which is not impeding the movement of surface water. No

construction activities took place during this audit period.

Dirty stormwater at the coal handling facility is not contained to the dirty water area

and is resulting in the contamination of soil and coal contaminated surface runoff into

the Leeuspruit. The Regulation 31 Amendment Application for constructing

stormwater measures at 3 Shaft is to mitigate this contamination. Until the

application is approved, very little can be done to contain the coal contamination at 3

Shaft. However, measures should be undertaken to minimise contamination of soil.

Contaminated soil may have to be removed once the storm water infrastructure has

been installed.

Mooikraal has an integrated waste and water management plan (IWWMP) and all

waste from Mooikraal is considered hazardous waste because all waste coming from

underground is assumed to be contaminated by hydrocarbons. Therefore, the waste is

diposed of as hazardous by EnviroServ. All waste is placed at the ISO yard where the

waste is collected. There are no signs of littering on site and no waste is being dumped

on adjacent properties.

There were no emergency incidents reported during this audit period. The PCDs did

overflow in previous years and that was handled by reporting the incident to the

competent authority. Mooikraal is aware of the procedure to follow in instances that

trigger an emergency incident in accordance with legislation.

No construction activities took place during this audit period, therefore no vehicles

needing servicing or maintenance. For the Regulation 31 Amendment Application for

constructing stormwater measures at 3 Shaft, these measures will be put in place.

However, measures should be undertaken to minimise contamination of soil.

Contaminated soil may have to be removed once the storm water infrastructure has

been installed. Soil contamination was identified at 3 Shaft from the runoff.

The Zamdela community is adjacent to 3 Shaft and Sasol has a complaints register for

the community to register their grievances from the mining activities. When the

construction activities commence for the Regulation 31 stormwater measures, the

community will be informed if the noise will be elevated and cause a nuisance.

However, as measures need to be implemented while awaiting the approval of the

Regulation 31 Amendment; noise generating activities must be communicated to the

surrounding community accordingly. Therefore, it is recommended that this noise

condition be made more applicable to the current activities.

Mooikraal is an underground mine, therefore the dust suppression takes place

underground. Dust suppression at 3 Shaft is undertaken using fogger cannons

installed along the haul road.

No burial grounds, grave sites and heritage resources were discovered on Mooikraal

and 3 Shaft during this audit.

There is no topsoil and subsoil stockpiles at Mooikraal or 3 Shaft. There is an

overburden stockpile which will be used for backfilling at the end of the LoM.

Therefore, this condition is note applicable.

No hydrocarbons spills were observed on site during the site visit. The hydraulic oil

and diesel storage tanks are bunded areas and there are spill kits.

The Sewage Treatment Plant (STP) treats all sewage water collected from the office

blocks and change houses via a sewage network. The STP is managed by PROXA. The

process at the STP is as follows:

1. Sewage water is pumped into the aeration tank where the sludge settles;

2. The water then is transferred into a baffle tank;

3. The water in the baffle tank is treated with chemicals, i.e. chlorine;

4. The water after treatment is then discharged into the Kromelboogspruit, in

accordance with the approved IWUL;

5. The settled sludge is then removed from the aeration tank and placed on the drying

beds; and

6. The dried sludge is then collected in the waste skip and removed by the appointed

contractor.

Sasol Mining: Mooikraal has an Integrated Water Use Licence (IWUL) (Licence No.:

08/C22K/CIGJFAE/6981) issued by the Department of Water and Sanitation (DWS) in

terms of the National Water Act, 1998 (Act No. 36 of 1998) (NWA) on 16 January

2018.

The following water uses were authorised in terms of the IWUL:

Section 21 (a): Taking water from a water resource;

Section 21 (c): Impeding or diverting the flow of water in a watercourse;

Section 21 (e): Engaging in a controlled activity;

Section 21 (f): Discharging waste or water containing waste into a water resource;

Section 21 (g): Disposing of waste in a manner which may detrimentally impact on a

water resource;

Section 21 (i): Altering the bed, banks or characteristics of a water course; and

Section 21 (j): Removing, discharging or disposing of water found underground if it is

necessary for the efficient continuation of an activity.

Sasol Mooikraal will perform all duties in terms of common law to landowners

affected by the mining.

Mooikraal will undertake rehabilitation at the end of LoM and there is financial

provisioning undertaken on an annual basis for closure. However, rehabilitation is not

taking place currently thus is condition is not applicable yet.

This condition is noted.

Mooikraal does not have residue deposits. The overburden stockpile is the only thing

that can satisfy the definition of residue stockpile. The stockpile is placed on the

surface and has not been moved.

Mooikraal does not operate with a waste management licence (WML). It operates

with the IWWMP and waste procedures in place. There is an ISO yard where waste is

managed and a service provider appointed dipose the waste.


The ISO yard is concreted and waste is organised into skips. The ISO yard is not roofed

and therefore the waste is exposed to weather conditions. It is recommended that

Mooikraal investigates roofing the ISO yard to comply to this condition.

No hydrocarbons spills were observed on site during the site visit. The hydraulic oil

and diesel storage tanks are bunded areas and there are spill kits. Three sumps are

located at the Mooikraal operation to collect water generated around the shaft

complex. One sump is located near the wash bay, another near the fuel and oil

storage area and the third one is located at the incline shaft. These sumps serve as

separators of hydrocarbons and sediment from water. The water then drains into the

South Dam PCD which then flows into the North Dam PCD.


There is a copy of the EMPR at Mooikraal.

Contractual management of service providers takes EMPR commitments and ensures

that the contractors work in accordance with the EMPR.

Stormwater measures around Mooikraal are working efficiently; 3 Shaft is still

awaiting approval from the competent authority. The departments are aware of the

lack of effective stormwater measures at 3 Shaft by virtue of the application.

Therefore, Mooikraal is found compliant with this condition with monitoring and

informing the department.

This is shown in the survey plan submited to the Principal Inspector.

Dust suppression measures have been implemented at 3 Shaft to mitigate the dust

that was being generated from the coal handling facility and causing a nuisance and

health hazard for the adjacent Zamdela community.

Mooikraal inputs monitoring data and audit findings into the Environmental

Management System via Isometrix. This assists in managing the site more effectively

and efficiently. There is a complaints and incidents register that is handled by Sasol

Mining Rights Department (SMRD).

A complaint was lodged on 22 May 2020 about water and it was agreed that the

landowner would be supplied water by Sasol Mining drilling two boreholes for him.

Purchase Order for the borehole drillings were supplied.

Mooikraal has an integrated waste and water management plan (IWWMP) and all

waste from Mooikraal is considered hazardous waste because all waste coming from

underground is assumed to be contaminated by hydrocarbons. Therefore, the waste is

diposed of as hazardous by EnviroServ.

No liquid waste is discharged to the municipality, but remain in the PCD. Treated

domestic sewage effluent is discharged as per the conditions of the WUL.



Mooikraal is an underground mine and rehabilitation will only take place at closure.

The borrow pit is the only surface area that was dug and has since revegetated and is

free draining.

The details of the Environmental Practitioner at Mooikraal was communicated to the

competent authority.

An incident register is managed by SMRD for all Sasol mines.

An compliants register is available and also managed by SMRD.

Monitoring reports and audit reports for Mooikraal is kept and made available for

inspections and were made available for this audit.

Monitoring reports and audit reports for Mooikraal is kept and made available for

inspections.

All authorisations and permits for Mooikraal are kept on record and they are audited

on an annual basis.

Annual environmental audits and WUL audits are undertaken and all monitoring data

related to the audits is included in the audit reports and submitted to the competent

authorities.


Mooikraal is mining within the mining rights boundary. Survey plan shows the mining

right area boundary clearly.

Mooikraal did not undertake construction activities during this audit period.

Mooikraal appoints EnviroServ to handle hazardous waste. EnviroServ is a registered

waste management company.

The ISO yard has waste skips to collect the different waste streams and EnviroServ

collects the waste on a PO basis.

Mooikraal undertakes Regulation 34 audits in accordances with NEMA EIA

Regulations, 2014 (as amended). Regulation 55 of the MPRDA Regulations has been

repealed by GN R420 of 23 March 2020.

The financial provisioning for Mooikraal was updated for 2020 in March 2020 for

Mooikraal, Old Sigma and 3 Shaft.

No emergency incidents were reported during this audit period.

The mine is fenced all around and there are signage boards at the entrance of

Mooikraal and 3 Shaft that restricts unathorised persons on site.

The signage boards at the mine written in English, Afrikaans and Sesotho.

Mooikraal has an emergency prepardness plan in accordance with SIO14001:2015.

Emergency Incident Register that is handled internally.





This condition is noted. Mooikraal will only go into closure towards 2039.



Appendix B: EMPr Checklist

Activity Aspect Objective Proposed Mitigation Measure Audit Comments Compliance (2020)

C /NC/NA

EMPr for the Operation of Sigma Mooikraal Operations

1 Geology ■ To ensure that the resource is mined optimally.

The comprehensive monitoring of surface subsidence is and will be done in accordance with the requirements of Regulation 5.3.6 and Regulation 12.7.1 of the GN992 of 26/06/1970.

The Mooikraal Colliery undertakes both bord and pillar and high extraction mining method to extract the coal from the coal seam. It was communicated that no high extraction mining is undertaken beneath watercourses in accordance with GN R704 (Regulations on Use of Water for Mining and Related Activities Aimed at the Protection of Water Resources, 1999). To date no subsidence has occurred within the Mooikraal mining right area. However a visual surface inspection is undertaken on a biannual basis of the elevation of the land where high extraction has occurred.

C

■ To monitor surface subsidence so as to determine and plan for the long-term land use and to timeously prevent or control a dangerous situation which may occur from such a subsidence.

Where the probability of an occurrence of subsidence has been determined and it poses a danger, the void area underground, in that specific area will be stabilised as far as is practicably possible in terms of Regulation 5.3.3 of the GN992 of 26/06/1970, after consultation with the relevant authorities and affected parties. The fill material used to date consists of fine ash due to its pozzalenic properties or fine ash and cement mixtures.

No evidence of subsidence has occurred within the Mooikraal mining right areaVisual observations during the site visit did not show any subsidence had occured within the Mooikraal mining boundary. Quarterly susbidence monitoring undertaken by the Sasol Survey Team. Annual Lidar photos taken.

C


Surface water permeability in the subsidence areas will be controlled from entering the underground working by means of :

No subsidence has occurred, therefore this is not applicable until such a time this risk is realised.

N/A

■ Rehabilitating the surface of the soils as discussed in paragraph 5.3.2,

N/A

■ By making the area as far as is practically possible to be free draining, and

N/A

■ Where the soil type does not allow for natural drainage the area may have to be shaped to emulate more or less the natural contours so as to provide for surface run-off.

N/A

2 Soils ■ To ensure that no soils in new areas are disturbed.

Soils in areas not allocated to the building of infrastructures will not be disturbed unnecessarily.

During the construction of the mine soils would have been disturbed for the establishment of the surface infrastructure as well as the incline shaft. Rehabilitation will only take place at the end of LoM for Mooikraal. The borrow pit that dug has since naturally revegetated and is free draining. Therefore, it will be rehabilitated and leveled at the end of Mooikraal's LoM.

N/A

■ To prevent soil erosion.

Topsoil stockpiles will be vegetated and the vegetation maintained to prevent erosion throughout the life of the mine.

Topsoil is used for the construction of berms around the mine site. The berms are well vegetated and well maintained. There were no signs of soil erosion observed during the site visit.

C

■ To ensure that topsoil stockpiles are managed in such a way that they can be used for rehabilitation of the disturbed areas.

Topsoil is used for the construction of berms around the mine site. The berms are well vegetated and well maintained. There were no signs of soil erosion observed during the site visit.

C

Soil amelioration will be undertaken to enhance the arable capability of the soils and to sustain the ability of the soil to retain oxygen and thus sustain vegetative material during the storage period.

Topsoil is used for the construction of berms around the mine site. The berms are well vegetated and well maintained. There were no signs of soil erosion observed during the site visit. Soil amelioration will only be required after all topsoil has been replaced as part of rehabilitation; and only if required.

N/A


The area undergoing rehabilitation will be fenced and all animals prevented from entering the area until vegetation is sustainable.

Mooikraal being an underground mine means that the mine will undertake rehabilitation at the end of the LoM. Therefore, rehabilitation will be within the mining right boundary and the mine's footprint. This condition is therefore not applicable yet.

N/A

Newly seeded/planted areas will be protected against compaction and erosion.

There are no newly seeded or planted areas at Mooikraal. The site is well vegetated and no signs of erosion were identified during the site visit.

N/A

Traffic shall be limited where possible while the vegetation is establishing itself.

Vehicles are kept to designated roads and not allowed to drive over grassed areas.

C

A monitoring programme will be initiated to monitor the rehabilitation of disturbed areas.

Mooikraal is updating the Integrated Waste and Water Management Plan (IWWMP) which includes the update of the Rehabilitation Strategy and Implementation Plan (RSIP) for Mooikraal. Therefore, rehabilitation of the site will follow that monitoring plan. The RSIP serves as a strategy for rehabilitation measures and aims to provide implementation guidelines for ensuring that rehabilitation requirements are met during operation and at closure. Rehabilitation of the site will follow the Rehabilitation Plan.

C

3 Topography

■ To remove all “scars” and emulate within ±2 m the “pre-mining“ topography so as to, as far as is practicably possible restore the land forms and surface drainage paths.

To reconcile the expected and actual material swells of the overburden removal and placement and do the necessary adjustment to the long term plan in order to meet the overall objective.

This condition is considered to be not applicable at this stage. The bulking factor will be taken into consideration once the boxcut is rehabilitated and backfilled.

N/A

4 Rehabilitation

The main objective of the reclamation of the surface of the land to be impacted upon by the operations of Sigma: Mooikraal Operation is to restore the area to its original potential for rain fed arable production i.e. a COM Class II, land capability and to establish a natural grassland to:

The procedure for rehabilitation of subsided areas is as follows:

No evidence of subsidence has occurred within the Mooikraal mining right area. However, should there be such instances of subsidence, the areas will be rehabilitated to make the area free draining as far as practicably possible, as per the Rehabilitation of Damage to the Surface Due to Underground Mining Operations at Sigma Colliery (SIG IM (EM) 4.4.6 021).

N/A


■ Provide a satisfactory cover that will stabilise the area, reduce the potential for wind and water erosion and thus reduce the potential for contamination of the surrounding

■ The area is to be fenced off in terms of Regulation 5.2 of the GN992 of 26/06/1970, if necessary,

N/A

■ environment,

■ Coarse and fine ash due to there pozzalenic properties is then worked into the cracks up to a level of ± 1m from surface (Harmse, 1991-1993) and where necessary this is sealed by means of ±1m of clay,

N/A

■ Reduce the visual impact of the mining area and restore or improve on the pre-mining appearance of the area,

■ A topsoil layer of at least 0.5m is placed over the ash-filling or clay-layer,

N/A

■ Create a more continuous plant community across the area, and

■ The affected area is fertilised and revegetated during the first rainfall period after “repair work” has been done,

N/A

■ Remove undesirable stands of weedy species (exotics) and replace them with a more productive and acceptable grassland community.

■ The fencing will be removed once the area has been rehabilitated and the vegetation has established to a minimum of 15% basal cover (Chamber of Mines South Africa, 1979), and

N/A

■ The subsided areas are inspected on a regular basis to determine whether further subsidence has occurred and if necessary the process is repeated until the area has stabilised.

N/A

Soils removal placement and land preparation:

The topsoil and sub-soil horizons are stripped separately since the physical, biological and chemical characteristics of topsoil are generally more suitable for the germination, survival and growth of the vegetation.

The topsoil stockpiles are located around the incline shaft, PCD and utilised for stormwater berms. No sub-soil is located onsite. These soil stockpiles are well managed as they are vegetated, no significant compaction was found and no erosion was identified.

C

Soil stockpiles are avoided as far as is practicably possible since soil stripped at the workings is utilised directly for rehabilitation. Vegetation cover is mulched into the topsoil during removal providing additional organic nutrients to the soil.

Soil stockpiles are utilised as bunds and have been vegetated. Vegetation cover will only be mulched into the topsoil during removal providing additional organic nutrients to the soil during rehabilitation. Remaining soil stockpiles will be for final rehabilitation.

C


Vegetation cover is mulched into the topsoil during removal providing additional organic nutrients to the soil.

No soils are currently being removed. Soil stockpiles are utilised as bunds and have been vegetated. Vegetation cover will only be mulched into the topsoil during removal providing additional organic nutrients to the soil during rehabilitation. Therefore this condition is considered to be not applicable.

N/A

A veld-burning programme will be followed to remove moribund/unacceptable grass material, to contain/prevent encroachment of undesirable plants.

No veld burning programme has been implemented however, measures have been undertaken to ensure fire breaks are still established such as the continued maintains of the areas and ensuring that the grass is cut to a height of 50 mm through a maintenance subcontractor specifically during the summer and winter seasons within the Mooikraal Colliery. Communication between farmers and the mine is also undertaken to ensure firebreaks are constructed on adjacent farms.

C

In order to limit erosion of soils, prior to the establishment of vegetation, erosion control contours are placed at intervals over the rehabilitated land. This limits the effect of uncontrolled run-off and excessive erosion.

As the Mooikraal Mine is an underground coal mine, limited rehabilitation is undertaken on areas where mining or related activities have been undertaken. It was reported that to date only minimal rehabilitation activities had been undertaken.

C

Vegetation establishment:

Grasses - Revegetation (seeding) is programmed for the season and time of year, which will yield the optimum germination and growth (late spring/early summer). Successful germination should be achieved within six weeks.

As the Mooikraal Mine is an underground coal mine, limited rehabilitation is undertaken on areas where mining or related activities have been undertaken. It was reported that to date only minimal rehabilitation activities had been undertaken. Within the reporting period no rehabilitation activities had been undertaken. It was observed that vegetation has been established on soil stockpiles and around the mining infrastructure area.

C

Maintenance of all planted revegetated areas - The following maintenance is required:

■ Newly seeded/planted areas must be protected against all undue traffic and/or other disturbances throughout the establishment period,

No areas have been disturbed recently and therefore, no areas have been recently planted requiring these specific management measures.

N/A

■ Plants should be watered and weeded regularly,

N/A


■ A check for pests and diseases at least once every two weeks and treatment, (if necessary), for six months,

N/A

■ Replace unhealthy or moribund specimens,

N/A

■ Fertilize the grassed areas with 150 kg/ha LAN (28), 4-6 weeks after germination under

N/A

■ Favorable growing conditions, N/A

■ Control alien invasive plants, and N/A

■ Continually repair any damage caused by erosion.

N/A

Irrigation - In the establishment of vegetation during the rehabilitation procedure irrigation will be necessary where rainfall is insufficient.

Mooikraal has been granted permission to use waste water for irrigation purposes in accordance with the Integrated Water Use Licence (IWUL) (Licence No. 08/C22K/CIGJFAE/6981). However, no irrigation is being undertaken during operational phase. If it is required during the decommissioning phase, it will be implemented.

N/A

The rehabilitated areas must be well managed when post-mining utilisation commences to prevent deterioration of the grazing and degradation of the environment.

The rehabilitation monitoring plan will include post closure monitoring activities that Mooikraal needs to implement. This condition is not yet applicable.

N/A

Environmental awareness training should form part of the annual induction training.

Environmental awareness training is undertaken on a monthly basis through the use of meetings/ posters/ annual induction and environmental monthly topics and events.

C

5 Flora

To maintain the status quo after construction is completed and to conserve and protect the structure of the vegetation community and prevent further loss of species diversity.

In order to mitigate the impact on the loss of habitats, and the change in habitat composition, the following measures will be implemented:Any areas that are rehabilitated during operation, as well as sensitive areas shall be monitored for alien species invasion. This will be performed at least once per season and more frequently during very wet seasons. All alien species found will be removed according to the alien plant control programme (Appendix 3).

Alien invasive species management and eradication is being undertaken. Alien invasive mapping was undertaken and eradication measures have been implemented. Mooikraal has an Alien Invasive Plant Management Plan (2018) and has recently demarcated AIPs at 3 Shaft (August 2020) for a permit application to begin eradication of the AIPs.

C


Areas, which have been disturbed by the mining operations and are no longer used will to be revegetated with vegetation indigenous to the area (refer to paragraph 5.3.4).

The borrow pit has since naturally revegetated and is free draining. The mine is an underground mine and therefore limited rehabilitation is undertaken.

C

Vegetation used for rehabilitation will be selected for its self-sustaining properties. If natural re-vegetation does not occur, the vegetation will be replaced.

A rehabilitation management plan will be implemented at the end of LoM and indigenous vegetation will be used for reseeding.

N/A

Off-road driving by mine vehicles through the surrounding veld will be prohibited.

Main roads, farm roads and maintenance roads are used when moving around the site. Caution is taken when accessing areas that is far from a road network.

C

In order to limit habitat disturbance and fragmentation, the following programmes shall be established■ A rehabilitation programme for the areas disturbed during the construction phase■ Alien plant control programme (Appendix 3)■ A fire management programme■ Education/awareness programme for all staff regarding the management and protection of biodiversity■ Collection of firewood will be prohibited.

* During the construction of the mine soils would have been disturbed for the establishment of the surface infrastructure as well as the incline shaft. Rehabilitation will only take place at the end of LoM for Mooikraal. The borrow pit that dug has since naturally revegetated and is free draining. Therefore, it will be rehabilitated and leveled at the end of Mooikraal's LoM. Rehabilitation will follow a rehbailitation plan. * Alien invasive species management and eradication is being undertaken. Alien invasive mapping was undertaken and eradication measures have been implemented. * No veld burning programme has been implemented however, measures have been undertaken to ensure fire breaks are still established such as the continued maintains of the areas and ensuring that the grass is cut to a height of 50 mm through a maintenance subcontractor specifically during the summer and winter seasons within the Mooikraal Colliery. * Environmental awareness training is undertaken on a monthly basis through the use of meetings/ posters/ annual induction and environmental monthly topics and events.* Collection of wood is not being undertaken at Mooikraal or 3 Shaft.

C

6 Fauna

To minimise the impact of the mine on animal life and re-establish and enhance animal populations that existed pre-mining.

Any form of hunting, poaching, snaring or trapping will be prohibited within the mining area.

No form of hunting is permitted at the Mooikraal Colliery or Sigma 3 Shaft. This is communicated through the induction that must be undertaken by each individual working onsite. Security guards regularly patrol the mine to ensure no unauthorised entry to the mine and ensure no hunting is taking place. It was noted that should an animal be identified onsite the individual is required to alert the Environmental Practitioner. Depending of the species that is

C

Birds C


In order to further improve bird habitat the following measures will be taken:

identified efforts will be undertaken to relocate the species away from the mine; no killing of any animal is permitted. C

■ The active planting of the tree screens and the revegetation of the badly disturbed areas will definitely improve the bird habitats.

C

Mammals C

In order to minimise the impacts on mammals the following actions will be taken:

C

■ Relocate specimens. C

Reptiles and amphibians C

In order to minimise the impacts on reptiles and amphibians the following actions will be undertaken:

C

■ Relocate specimens which may be trapped in trenches, adits and other mine related structures, and

C

■ Where practical, slope the walls of permanent trenches to enable trapped animals to escape.

C

■ Killing of snakes prohibited - they will be relocated

C

Surface water (Aquatic Systems)

The objectives of surface water management will be:■ To manage the operation in such a way as to prevent surface water contamination that will impact on the aquatic environment;■ To operate within the law as stated in the MPRDA, 2002 (Act 28 of 2002) and the National Water Act, 1998 (Act 36 of 1998) and to ensure that all the applicable requirements of the National Water Act, are complied with, in particular Government Notice 704;■ To affect catchment yield as little as is practically possible; and■ To keep 1:50 and regional maximum floods out of the mine.

Surface water will be monitored monthly to check for deterioration of water quality and to identify potential seepage pathways.

A water monitoring report compiled by IGS by April 2020 was provided and monitoring was undertaken upstream and downstream Kromelmboogspruit. There were exceedances of E.Coli and Faecal Coliform in the surface water dams. There were exceedances in the four deep boreholes in EC, pH, Cl, NO3, F and Na. There were exceedances in one shallow borehole in SO4. Exceedance in EC, F and NA was found in one mine borehole and an exceedance in one intermediate borehole in EC, Mg and SO4.

C


■ To restrict the impacts of polluted water to the mining area ■ To operate within the standards and operational procedures, ■ To as far as is practicably possible have a free draining topography over rehabilitated areas,

A water monitoring report compiled by IGS by April 2020 was provided and monitoring was undertaken upstream and downstream Kromelmboogspruit. Coal contaminated surface runoff was observed at 3 Shaft. The water discharges into the Leeuspruit. The borrow pit is free draining and has revegetated.

C

The necessary control measures will be maintained to ensure containment of spillages at the plant and shaft areas, e.g. pollution control dams, the clearing of channels, etc.

The PCDs were not overflowing at the time of the audit. The 7ML and 10ML pipelines have since been contructed and are used to transport water to the Sasol Operations (SO). The silt traps had been cleaned and and a Purchase Order (PO) was provided as proof of the work that was commissioned.

C

Prevent areas of high infiltration from developing on mined areas and ensure free drainage

There was no evidence of subsidence having occurred within the Mooikraal mining right area. However, should there be such instances of subsidence, the areas will be rehabilitated in order to make the area free draining as far as practicably possible, as per the Procedure for Rehabilitation of Damage to the Surface Due to Underground Mining Operations at Sigma Colliery (SIG IM (EM) 4.4.6 021). Additionally should subsidence occur the area will be rehabilitated and will be made free draining. The borrow pit is free draining and has revegetated.

C

Limit containment of uncontaminated stormwater limit interference with natural surface water drainage system

A Standard Operating Procedure (SOP) for stormwater management and the maintenance of Sigma Colliery: 3 Shaft has been put together and due for review in 2021. It is however noted that stormwater management measures are proposed to be implemented at 3 Shaft as part of the Regulation 31 Amendment process that proposes to demolish the existing infrastructure of the primary plant area, and establish a new crushing facility on the stockpile area to improve the clean and dirty water management at 3 Shaft. Coal contaminated surface runoff was observed at 3 Shaft. The water discharges into the Leeuspruit.

NC

7 Surface water (Hydrology)

To ensure that the impact from the mining infrastructure will not increase from that of the construction phase.

Stormwater control measures will be maintained around the shaft and plant area (at 3 Shaft) to ensure the maximum return of clean water to the natural drainage systems.

A Standard Operating Procedure (SOP) for stormwater management and the maintenance of Sigma Colliery: 3 Shaft has been put together and due for review in 2021. It is however noted that stormwater management measures are proposed to be implemented at 3 Shaft as part of the Regulation 31 Amendment process that proposes to demolish the existing infrastructure of the primary plant area, and establish a new crushing facility on the stockpile area to improve the clean and dirty water management at 3 Shaft. Coal contaminated surface runoff was observed at 3 Shaft. The water discharges into the Leeuspruit.

NC


Surface water (Water Quality)

■ To prevent the deterioration of the surface water quality during the operational phase as a result of sedimentation, seepage from the stockpiles, overburden dump and spillages.

Soil erosion measures will be maintained at the topsoil stockpiles, overburden dumps and shaft area, including the vegetation of these deposits and construction of paddocks where applicable.

The topsoil stockpiles are located around the incline shaft, PCD and utilised for stormwater berms. No sub-soil is located onsite. These soil stockpiles are well managed as they are vegetated, no significant compaction was found and no erosion was identified.

C

■ To maintain all the water pollution control measures so that they will be able to handle a 1:50 year flood event.

Contaminated runoff water from the dirty areas (shaft and plant at 3 Shaft) will be contained in water pollution control dams (North and South dams) that will be able to retain a 1:50 year flood event. From these dams it will be recycled back into the process for reuse in the mine or pumped to SII.

Mooikraal: The 7ML and 10ML pipelines pump water to the SO and there is no overflow of the PCDs for this audit period. 3 Shaft: Water at 3 Shaft is received from Mooikraal and utilised for dust suppression using fogger cannons. It is however noted that there is currently no water containment at 3 Shaft which is resulting in contamination of soil and surface runoff to the Leeuspruit. Mooikraal reuses mine affected water for dust suppression at 3 Shaft and the rest is supplied to SO.

NC

Measures implemented to separate clean and dirty stormwater at the shaft (Figure 8) and plant (at 3 Shaft) (Figure 9) will be maintained and upgraded where necessary to prevent spillages to the natural environment .

Stormwater management measures are constructed and operational throughout Mooikraal. 3 Shaft is still awaiting approval from the DMRE to implement the measures to improve the stormwater practices in the area. The DMRE has since sent clarification questions and undertook a site visit in relation to the Regulation 31 Amendment/Basic Assessment that was submitted in 2018 that proposes to demolish the existing infrastructure of the primary plant area, and establish a new crushing facility on the stockpile area to improve the clean and dirty water management at 3 Shaft. Dirty stormwater at the coal handling facility is not contained to the dirty water area and is resulting in the contamination of soil and coal contaminated surface runoff.

NC

The mine will implement measures to minimise its dirty water make that need to be handled in the water balance e.g. dirty areas at the plant will be kept to the minimum.

Dirty stormwater at the coal handling facility is not contained to the dirty water area and is resulting in the contamination of soil and coal contaminated surface runoff. Measures need to be implemented to contain the dirty water while the application is still being considered by the competent authorities.

NC


Contaminated water will be pumped to the dirty water system for reuse in the plant and service water underground.

Mooikraal: The 7ML and 10ML pipelines pump water to the SO and there is no overflow of the PCDs for this audit period. 3 Shaft: Water at 3 Shaft is received from Mooikraal and utilised for dust suppression using fogger cannons. It is however noted that there is currently no water containment at 3 Shaft which is resulting in contamination of soil and surface runoff to the Leeuspruit. Mooikraal reuses mine affected water for dust suppression at 3 Shaft and the rest is supplied to SO.

NC

Machinery to be brought up from underground for repairs or maintenance will first be washed in a demarcated area underground. This equipment will then be cleaned, serviced and repaired in a dedicated workshop with the necessary pollution control measures in place such as dedicated wash bays with oil separators and a facility to contain the recycled oil.

Machinery is continuously being repaired as part of preventative maintenance. It was noted that machinery is washed in a demarcated washbay prior to it being transferred to the workshop area for maintenance. There are containers at the entrance of the workshop area and some used/discarded material that is not placed in the ISO yard or on wooden pallets. Some equipment is also placed directly on the soil with some placed on concreted area or on steel bunds. There is a need for improved housekeeping in the area.

C

Clean stormwater and run-off will be diverted around the shaft, overburden stockpile, plant and waste storage areas. Contaminated water will be contained and put back into the process water system, for reuse.

Clean stormwater channels have been constructed around Mooikraal Colliery to divert clean water around the shaft. Berms are constructed around the WRD to contain any runoff containing silt and prevent the contamination of the surface water. No clean and dirty stormwater management measures are in place at the Sigma 3 Shaft area.

NC

A spill response plan will be implemented and employees trained accordingly to react efficiently to address any spillage. Large spillages of hazardous substances such as oil will initially be controlled by on-site emergency response personnel, who will be aided by professional contractors.

Any oil spills that occur on site are contained and dealt with on a weekly basis in accordance with the Procedure for the Handling of Oil Spills and Oil Recycling (Ref No. SIG (EM) IMS SOP/ 008). It was noted that all oil spillage that occur are recorded in an incident register (Ref No. Ref No. SIGIMS/NCREG/1) which is retained at the mine. The silt traps being cleaned resulted in some spillages on the soil around the workshop area/ washbay. It is recommended that these spills be cleaned up.

C


Hazardous waste will be disposed by an approved waste contractor to ensure the safe disposal of the waste. The associated safe disposal certificates will be kept in a secure

Waste is stored at the ISO yard and separated into the various waste streams at Mooikraal, namely wood, scrap metal and hazardous waste. However, all waste at Mooikraal is considered to be hazardous as all waste obtained from underground working is considered to be contaminated by hydrocarbons. The waste is removed by the appointed Service Provider to a registered landfill.

C

General waste will be separated in dedicated areas to facilitate the separation of waste from where it will be collected for disposal to a permitted landfill site or recycling.

Waste is stored at the ISO yard and separated into the various waste streams at Mooikraal, namely wood, scrap metal and hazardous waste. However, all waste at Mooikraal is considered to be hazardous as all waste obtained from underground working is considered to be contaminated by hydrocarbons. The waste is removed by the appointed Service Provider to a registered landfill.

C

Waste will be separated into the following categories which allow recycling: glass, steel, paper, batteries and woodchips as per waste procedure (SIGIMS 446002).

Waste is stored at the ISO yard and separated into the various waste streams at Mooikraal, namely wood, scrap metal and hazardous waste.

C

The waste areas will contain the necessary water pollution control features e.g. bunded, impermeable surfaces and sump, and separate demarcated areas for the different wastes.

The waste storage area is bunded and concreted. Each waste stream is separated by concrete wall on either side.

C

All bulk storage of substances such as fuel and oil must be bunded to contain 110% of the substance stored. These facilities must include a sump, an oil trap and an impermeable floor and walls.

The diesel and hydraulic oil storage areas are bunded and no leaks were observed from the tanks. The sump located near the workshop and the hydraulic oil storage area was cleaned out and the oil skimmer is being fixed for optimal functionality. The diesel storage area at 3 Shaft is still not in use and will be decommissioned.

C

All hazardous substances (such as paint, flammable substances) will be stored in a lockable cupboard at all times.

There are lockable storage areas for hazardous flammable substances such as Acetylene, Oxygen and LPG Gas.

C

A register with all the Material Safety Data Sheets (MSDs) of all the hazardous substances will be maintained on the mine at the point of use.

Material Safety Data Sheets (MSDS) were provided for the Oxygen, Acetylene and LPG Gas.

C


No activities will be allowed within 100m of watercourses.

Mooikraal received a GN 704 4 (b) exemption which permits Mooikraal to undermine the Kromelmboogspruit and feeder streams using bord and pillar methods. It is required that a safety factor of 2 is maintained as well as a width to height ratio of greater than 4. However, it was communicated that no high extraction mining is permitted within 100 m of a watercourse or wetlands. The wetlands around Mooikraal have been delineated in 2014 and a 100 m buffer has been placed around both wetlands and river on the mine plans. It is also noted that 3 Shaft is considered to be located within 100 m of a water course however the plant was constructed in 1950 before NWA was promulgated. It is also noted that it is proposed that the processing plant at 3 Shaft will be relocated away from the water course to reduce 3 Shaft impact on the river.

C

An annual weed eradication programme will be undertaken utilising a registered chemical herbicide contractor.

The Alien Invasive Mapping that was undertaken set out control strategies that include the use of mechanical removal, manual removal, biological control, herbicides and fire. These measures will be used where it is appropriate.

C

Surface water monitoring will be implemented to ensure that the water management systems perform adequately as discussed in this EMP.

A water monitoring report compiled by IGS by April 2020 was provided and monitoring was undertaken upstream and downstream Kromelmboogspruit. No exceedances were noted for all the analysed parameters for surface water monitoring.

C

The water balance at Sigma: Mooikraal operation will be managed by pumping to SII , from where it is discharged to the Vaal River as part of SII's final effluent.

The WC/WD plan finalised in April 2019 by Digby Wells updated the water balance. The water balance is being updated as part for the annual WC/WD Management Plan update. The pipelines have been constructed and are operational. The water is being transferred from Mooikraal to Sasol Operations.

C

No river diversions are planned for the operations. Undermining of the Kromelmboogspruit will be done in accordance with GN 704

No river or streams have been diverted during any phase of the Mooikraal operations. Mooikraal received a GN 704 4 (b) exemption which permits Mooikraal to undermine the Kromelmboogspruit and feeder streams using bord and pillar methods.

C

Mitigate against any impact on surface water users. Undermining of watercourses will however be conducted in accordance with GN 704 and the National Water Act, 1998 (Act 36 of 1998).

Mooikraal received a GN 704 4 (b) exemption which permits Mooikraal to undermine the Kromelmboogspruit and feeder streams using bord and pillar methods.

C

8 Groundwater

The objective of groundwater management will be to restrict the impact of polluted groundwater to the mining area and the adverse impacts on groundwater will be further reduced by implementing the mitigatory measures and management programme of the below listed.

Users of private boreholes affected by mining operations will be provided with an alternative supply of potable water the same or better quality after an investigation has been done by Sasol Mining.

A complaint was lodged on 22 May 2020 about water quality and it was agreed that the landowner would be supplied water by Sasol Mining drilling two boreholes for him. Purchase Order for the borehole drillings were supplied.

C


Excess mine water is pumped to surface and either recycled, re-used for dust suppression, etc. or abstracted for treatment

Water from underground is pumped into the South PCD which then flows into the North PCD. The water is then transferred to the SO via the 7ML and 10ML pipelines. Water is also pumped to 3 Shaft for dust suppression via fogger canons.

C

The groundwater boreholes should be monitored to ensure that seepage is detected before it becomes an issue.

A water monitoring report compiled by IGS by April 2020 was provided and monitoring was undertaken upstream and downstream Kromelmboogspruit. There were exceedances of E.Coli and Faecal Coliform in the surface water dams. There were exceedances in the four deep boreholes in EC, pH, Cl, NO3, F and Na. There were exceedances in one shallow borehole in SO4. Exceedance in EC, F and NA was found in one mine borehole and an exceedance in one intermediate borehole in EC, Mg and SO4.

C

9 Air Quality To ensure that the dust impacts do not exceed guideline levels as a result of the mining activities.

Applications of a chemical binder (ligno-sulphonate, calcium/magnesium chloride or bituminous products) to roads to develop a crust, coupled to watering and sweeping to eliminate dust mobilisation from this source.

Dust-A-Side is used for the roads underground and at 3 Shaft, there is Dust-A-Side used along the access road via fogger canons.

C

Constant watering (with water trucks) in areas where material removal, placement or manipulation is occurring

Dust suppression measures have been put into place at Sigma Colliery: 3 Shaft in the form of fogger cannons and water bowsers.

C

Rehabilitating areas as soon as practically possible,

Rehabilitation will take place at Mooikraal's end of LoM. N/A

Applying dust control measures to roads to achieve maximum dust control efficiency

At 3 Shaft, there is Dust-A-Side used along the access road via fogger canons. The fogger canons are operating well.

C

Ensuring that dust control measures at transfer points are in place and operate efficiently

At 3 Shaft, there is Dust-A-Side used along the access road via fogger canons. The fogger canons are operating well.

C

Where practically possible to construct berms, plant tree screens/windbreaks

Berms have been constructed around the incline shaft and PCD this assist in both screening and water management.

C


10 Noise To ensure that measures are implemented to reduce the disturbing noise.

Implement specific noise prevention measures such as disabling audible reverse warning devices and replacing these with visual warning devices on all and new equipment, the proper silencing of all diesel equipment, the regular and systematic maintenance of equipment and the continuous training of personnel in order to promote operational procedures

Sigma has complaints for structural damage and waste (rubble used to make a road). No noise complaints were placed on record about the machinery at the Sigma Coliery: 3 Shaft or Mooikraal.

C

Conduct noise measurements on all new equipment to establish a reference data-base and follow up with regular noise audits to ensure the early detection of deviations which could lead to complaints

Continuous maintenance on vehicles is undertaken to ensure the machines function optimally and do not produce excessive noise. Additionally it was communicated that when vehicles are brought onto site, the vehicles are monitored in terms of occupational health and safety to ensure the noise levels do not exceed noise standards.

C

Conduct ambient noise monitoring at regular intervals in order to detect possible deviations from predicted and accepted noise impact levels. Analyse and take corrective action

Noise Monitoring must be undertaken. NC

No “high noise” operations should take place on or above ground level at night

The mine operates as a 24 hour mine however it was noted that excessive noisy activities which is undertaken occasionally is limited to day light hours such as blasting.

C

If all management actions fail to address the impact, BATNEEC-engineering practices will have to put in place e.g. the construction of a noise barrier, etc.

Noise Monitoring must be undertaken. NC

11 Aesthetics To minimise the visual impact of mining operations as much as possible.

The shaft, conveyor, overburden dump and plant (at 3 Shaft) will be vegetated and rehabilitated.


The infrastructure will be demolished and removed in consultation with the authorities.


The lighting of the plant and shaft areas will be designed in such a way as to reduce illumination at night.

Lights are pointed towards the ground to ensure light is direct on the mine and not into the surrounding properties.

C


High mast lights will be designed in such a way that they shine on the plant and mine infrastructure only.

Lights are pointed towards the ground to ensure light is direct on the mine and not into the surrounding properties.

C

Rehabilitate all disturbed areas as soon as is practicably possible


Introduce flora to soften and screen buildings and structures

Limited flora is found onsite as it is currently a fully operational mine. Indigenous trees have been planted around the mine

C

Planting of indigenous trees around structures, buildings, etc; and maintaining of the area around infrastructure and keep it neat

Limited flora is found onsite as it is currently a fully operational mine. Indigenous trees have been planted around the mine

C

12 Interested and Affected Parties

To minimise the negative impacts of the closing down of the underground operations and resulted loss of employment.

Sasol Mining Rights and Property Department (SMRD) gives feedback to all I &APs on complaints received and the implementation of corrective actions taken as committed in the ISO14001 EMS

The complaints register with complaints from 2017 to 2020, out of 281 complaints, 243 have been resolved and 37 are still ongoing.

C

13

Maintenance of water pollution structures

The main structures requiring maintenance are:

Berms are used to prevent clean water from entering the incline shaft and divert the water around the shaft area. All contaminated stormwater from the wash bay, parking areas and bulk storage areas at the Mooikraal Shaft is contained to the dirty water system which comprises a network of sumps and silt traps which overflows into the PCD. From the North PCD this water is pumped to the 3 Shaft for dust suppression or the SO as part of their water system.

C

■ Stormwater diversion channels/berms

C

■ Stormwater conveyance channels C

■ Sumps C

■ Trenches C

■ Pollution control dams C

■ Surface dams C


All of the above facilities will be maintained according to general accepted engineering practices and in accordance with the requirements of the National Water Act, 1998 (Act 36 of 1998) and will be inspected visually at least once a week.

This condition is noted. C

14 Financial Provision

Estimations of the costs of measures to comply with statutory obligations will be determined by suitably qualified persons within ninety days before the end of each financial year.

The financial provisioning for the 2020 financial year was provided. The financial provisioning is for 3 Shaft, Mooikraal and the old Sigma coal handling.

C

Contribution towards the estimated costs of measures shall be made by Sasol Mining before the end of the financial year.

C

The shortfall between the estimated costs of measures and the credit of a beneficiaries account shall be made good by Sasol Mining.

C

The above shortfall could arise at termination of mining operations and/or liquidation before the required financial provision in terms of the above formula has been made

C

sigma colliery: mooikraal and 3 shaft environmental audit

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