11.   ENVIRONMENTAL MANAGEMENT

11.7.1  

Environmental and Social Management

Grootegeluk has a comprehensive Safety, Health, Environment and Quality (“SHEQ”) policy and a Certificate of Registration confirming that it operates an Environmental Management System that complies with the requirements of ISO 14001: 1996. The Mine has a comprehensive emergency response plan covering all aspects of the operation including environmental aspects.

The Mine has an environmental team consisting of a Head, Environmental Control, who assisted by a Project Leader Environmental Control and an ISO 14001 Co-ordinator. The Head Environmental Control reports to the Manager SHEQ who reports to the Mine Manager.

SRK is satisfied that the Mine’s operational environmental budget of ZAR1.5m is adequate. Rehabilitation of the dumps is part of the mining budget. Some twenty capital projects dealing with water and environmental issues have been identified for the next three years. These projects are budgeted for as part of the Engineering budget. SRK believes that this programme will probably adequately address all the outstanding operational environmental issues. No specific environmental department capital projects have been identified for the next few years.

Grootegeluk participates in the Lephalale Environmental forum, which meets every three months. A public participation process was conducted as part of the water use licence application process. The issues recorded are largely issues that are receiving attention and there were no issues of material concern identified. The Mine has a formalised system for recording and dealing with any environmentally related complaint from either the public or the authorities.

The Mine has a Corporate Citizenship Department with four members of staff focussing on social issues and the Mine’s relationship with the community. They are working together with the Municipality and other role players to identify and address community needs. The Department has a budget (excluding salaries) calculated as 1% of pre-tax profits based on rolling three-year results.

11.7.2  

Environmental Issues

Surface water: Polluted water is directed to a number of pollution control dams where it is stored for use in the various mining and process operations. A large new storage dam is being developed at the base of the pit (below the coal Seams), which will serve as the final storage dam in the system. A number of issues pertaining to surface water management have been identified as requiring attention and are being dealt with as part of the Mine’s ongoing programme. In this regard it should be noted that some significant improvements have been implemented over the last few years. Since 1998 water from clean water sources has reduced from 70% of all water used to 30%, with the remainder made up from pit water and re-cycled water. There are some 20 water projects scheduled for the next three years to further improve water management on site.

Ground water: Potential operational groundwater impacts appear to be adequately managed. However, there is uncertainty as to what the post-closure impacts will be and how these may need to be managed. The large quantities of discard, which will be placed in the pit could possibly give rise to a pollution problem that will need to be managed. It is also not known whether seepage from the surface discard dumps could be an issue that may require post-closure management. There is a risk that post-closure ground water management costs, which have not yet been budgeted for, could be significant. SRK proposes that an amount of ZAR0.5m be provided for a groundwater study to assess this risk.

Discard dumps rehabilitation: The Mine has a number of discard dumps (total surface area of 770Ha) containing different mixtures of material some of which is carbonaceous in nature and burning (see below). In pit disposal is now being practiced on a small scale. A significant amount of research was conducted to determine the best way of doing this to prevent spontaneous combustion. The waste is being disposed of in cells protected by material not susceptible to spontaneous combustion. It will however be several years before there is sufficient space in the pit for all the material to be disposed of in this way. A rehabilitation method has been devised for the surface dumps whereby they will be clad with non-combustible material. They will then be topsoiled and grassed. Trials are being conducted to find the most cost-effective method. There is a risk that the final cost of rehabilitation of the discard dumps could be significantly more costly than currently budgeted for.

Slimes dam rehabilitation: There is a slimes (fine coal discard) dam facility consisting of a number of different dams. Some of this material is currently being recovered and sold. An investigation is underway into the feasibility of recovering more material. At this stage it is not possible to determine how much of the material will ultimately be recovered and what the final status of the site will be. As a result it is not possible to confirm what the actual rehabilitation requirements of this site will be. There is a risk that the final cost of rehabilitation of the slimes dam facility may exceed the current estimate.

Spontaneous combustion: Burning waste dumps are a long standing problem at Grootegeluk and was identified in a recent public participation exercise as one of the main issues of concern. Grootegeluk has both short and long-term solutions for dealing with this problem. In the short term the dump is constructed in such a manner that surfaces remain exposed for as short a time as possible and then covered with a temporary sand cover. In the longer term a more permanent cover is planned. It would appear that the public complaints are primarily a result of inadequate maintenance of the short-term measures. These complaints can most probably be rectified at little cost provided sufficient cover material is available in the long-term plan.

Soil utilisation: A significant quantity (probably in excess of 1 million m³) of soil will ultimately be required for rehabilitation purposes. In addition, other cover and insulation materials will be required in large quantities. A recent soil survey has shown that there is only a limited supply of suitable material. The Mine does not have a comprehensive materials balance and it is not possible to determine whether there will be sufficient materials for all the proposed requirements. There is therefore a risk that significantly more costly measures may have to be employed.

Closure planning and costs: The Mine’s closure plan is incorporated in the EMPR. Mining is expected to continue for many years and hence no separate closure plan has yet been compiled. The Mine does not have a formal plan for dealing with social aspects on closure. However consideration will be given, among other things, to re-deployment to other Kumba mines and to re-training. Grootegeluk has a detailed and comprehensive closure cost assessment. The estimated closure cost is ZAR243.8m. SRK proposes that a sensitivity contingency of between ZAR30m and ZAR50m be allowed for various uncertainties regarding the actual closure requirements in respect of the waste dumps, slurry dams, groundwater and the adequacy of the supply of soil and other materials for rehabilitation.

11.8.1  

Environmental and Social Management

Leeuwpan has a comprehensive SHE policy, which aims at continual improvement. The Mine has recently applied for certification in terms of OHSAS 18001 and ISO 14001. The initial audit has been completed and once the Mine’s Action Plan has been submitted, the Mine expects expect to receive its certification.

Previously all environmental responsibilities rested with the Resource Manager. Recently a SHE Systems Co-ordinator, reporting to the SHE Manager, was appointed. This post is now responsible for most of the environmental duties. The environmental staff compliment therefore appears to be adequate. However, at this stage, the Resource Manager remains responsible for certain of the environmental activities. The Mines planned SHE budget for 2006 amounts to ZAR2m, which appears adequate. In addition to safety and health costs, this includes environmental monitoring, auditing and revegetation of rehabilitated areas. The actual earthworks costs for rehabilitation are included as a mining cost.

The Mine participates in the local Municipal Future Forum, as well as in the Delmas Development Forum. The Mine’s socio-economic commitment programme is aimed at education, skills training and general poverty alleviation.

11.8.2  

Environmental Issues

Surface water: Surface water management facilities are intended to recycle all contaminated water and contain it in a closed circuit. Significant fluctuations in volumes of water can occur, particularly during the rainy season and as the need to de-water various pits arises. Twice, Leeuwpan has had to obtain special permission to discharge water at the peak of the rainy season. Recently, Leeuwpan has improved its water management system with filter presses introduced to replace the slurry dams. Despite these improvements, it would appear that water management problems can still occur. During SRK’s visit at the peak of the dry season, the settling dams at the plant were overflowing despite the fact that there was spare capacity in the Witklip pollution control dam. There is a risk that additional operational phase water management facilities and/or improved management procedures may be required. SRK proposes that a sensitivity contingency of between ZAR0.1m and ZAR2m be allowed to cover this eventuality.

Ground water: Hydrogeological studies and the groundwater monitoring programme indicate there is presently no significant impact with respect to contamination and de-watering of the regional dolomitic aquifer. This may, however, change as mining progresses. The possible future hydrogeological impacts from the Mine relate to increased inflow, de-watering of the dolomitic aquifer, deterioration of the water quality and the possible contamination of the regional dolomitic aquifer on closure. However, it is considered unlikely that any long-term contamination of groundwater will be significant. There is a small risk that, post-closure, groundwater management could be a lot more costly than is currently provided for.

Waste disposal: Coarse waste is returned to the base of the pit at a level that will be below the future ground water level. Pockets of waste are isolated by clay barrier walls and covered with overburden. This practice will help reduce the potential for the formation of acid mine drainage, as well as limiting the potential movement of such contamination away from the pit.

Rehabilitation: It is planned to develop each of the final mining voids into large evaporation dams designed to draw in water from the adjacent aquifer and prevent flow of contaminated water away from the site. However, the Mine does not have a detailed plan showing how this will be achieved. This is considered a serious oversight, as it is necessary to conduct mining operations in a manner to ensure the material, which is currently being moved, is replaced in such a way that the final required shaping of the pit can be achieved. Lack of adequate planning, design, management and control during the mining stage is likely to lead to greatly increased final rehabilitation costs. If this issue is not addressed it could lead to a contravention of the MPRDA, which requires mines to consider closure issues during all phases of the mine development.

River diversion: The Mine has a permit to permanently alter the course of an unnamed tributary of the Bronkhorstspruit. From a visual inspection of this diversion two significant issues are apparent. The cross-sectional dimensions of the canal appear to be significantly less than those stipulated in the permit. Secondly, significant erosion has occurred, most probably as a result of the diversion not complying with a suitable design. Money has been budgeted in the closure cost assessment to rectify this.

Closure planning and costing: The Mine does not have a separate closure plan but has calculated costs on the basis of the closure plan stipulated in the EMPR. Leeuwpan has a detailed and comprehensive closure cost assessment. However, as noted above, there is a lack of a proper materials balance and the volume of material that will have to be moved could greatly exceed the estimate. Leeuwpan has estimated the cost of closure at ZAR51.3m. This includes a 10% allowance for P&Gs and contingency. In the light of the uncertainty surrounding the final rehabilitation plan and the potential for additional groundwater costs SRK proposes a sensitivity contingency of between ZAR5m and ZAR10m be applied.

11.9.1  

Compliance

Tshikondeni has an approved EMPR (23 December 1998), however, this EMPR only covers the old (now demolished) plant, the Nyala underground workings, the residential area and associated infrastructure. Subsequently an addendum of the EMPR (approved 15 August 2000) was compiled for the satellite blocks. During 2004, the Mine compiled an EMPR amendment for the new co-disposal waste dump however this has not yet been approved. The Mine has initiated the process of undertaking an EIA and compiling an EMP for the proposed new Goni shaft with a public meeting held in October 2004. None of the EMPRs, comprehensively address all of the Mine’s operations and none address the Unwa Dam or the Duiker and Makuya shafts. An amount of ZAR0.7m should be budgeted for this exercise. Tshikondeni has a mining licence No. 11/2002, reference No. 5/3/2/172, dated 2 July 2002, and a mining permit No. 19/2001, reference No. 5/3/2/460, dated 6 August 2001.

The Mine is in the process of compiling all the necessary documentation for MPRDA conversion. A draft SLP is being complied (due for completion in August 2005). However, as none of the EMPR documents cover all the operations, it is expected that a comprehensive EMP for all current and planned operations will be required before new order rights can be obtained. This would need to include closure commitments on those facilities no longer in operation.

There appears to be a potential dispute regarding the boundary between the Mine and the Makuya Park. In the vicinity of the proposed new Goni shaft workings, a section of the game park fence is reported to have been incorrectly erected to incorporate some of the Mine land within the park. A legal investigation will be required to determine what the implications of this are.

The Mine has all the necessary water registrations and is in the process of compiling an application for a water use licence for all the operations. The Unwa Dam has been registered as a Category 1 Dam with a safety risk (dated 23 October 1998). A water use licence application has been submitted for the new co-disposal site and the Mine has temporary authorisation to continue with the waste dump pending the approval of the licence. The Mine has a Permitted Class G domestic waste disposal site (Permit No. 16/2/7/A900/C6/Z1/P277, dated 17 October 1997). An ISO 14001 audit has recently been completed. The Mine undertakes periodic internal environmental audits, however, no independent EMPR performance assessment audit has been conducted in recent years.

11.9.2  

Environmental and Social Management

The Mine has an integrated Health, Safety and Environment Policy Statement and has a “Certificate of Registration” confirming that it operates an environmental management system that complies with the requirements of ISO 14001. Induction training includes environmental aspects. Daily “Toolbox Talks” are held and these regularly include environmental topics. The Mine has an emergency response plan that includes environmental aspects and there is a programme of scheduled emergency response practices.

Tshikondeni has recently appointed a SHE Manager reporting to the Mine Manager. The environmental responsibilities are therefore being re-structured and the Environmental Officer now reports directly to the SHE Manager. Tshikondeni has an annual environmental department budget for 2005 of ZAR0.5m, which caters largely for salaries and sundry related office costs. The costs of environmental monitoring and consulting, etc. are currently adequately catered for under the Technical Department budget. In future these will fall under the SHE budget.

Tshikondeni also has a Social Investment Manager who reports directly to the Mine Manager. The Mine has a community interaction programme and a formalised system for recording and dealing with any environmentally related complaints from either the public or the authorities. Annual interested and affected party meetings are held.

11.9.3  

Environmental Issues

Surface water management: Surface water from Tshikondeni drains into the Mutale River that confluences with the Levuvhu River, which flows into the Kruger National Park. The water management strategy is based on a closed circuit in which effluent is recycled. To maximise water re-use and reduce handling and pumping costs, the Mine has recently upgraded the water management system. However, this system is currently not being managed in accordance with its design and unless changes are made there is a risk of spillages, particularly during the rainy season. From water monitoring results it is clear that the Mine is having some effect on the quality in the Mutale River, although this impact does not seem to be measurable in the Levuvhu River. The source of this contamination has not been identified. Some costs may have to be incurred to rectify the current water management system, however, it is not possible to predict these costs without detailed further investigation. SRK proposes that an amount of ZAR0.1m be allowed for a study to define requirements.

Groundwater: A number of groundwater studies have been undertaken and a limited groundwater monitoring programme has been implemented. Groundwater issues are currently considered to be adequately managed. The latest EMPR estimates that the mining areas will in all likelihood not decant into the shallow aquifer or adversely affect surface waters of the area. It is, however, noted that the complex geology and aquifer structure at Tshikondeni combined with highly variable ambient groundwater quality makes it difficult to predict potential impacts. Further groundwater studies are planned. There is currently a risk that post-closure groundwater management measures could be significantly more costly than what has been allowed for. SRK proposes that ZAR0.4m be allowed for a groundwater study.

Waste residue disposal: Coarse waste is compacted and the sides of the dump are being covered with soil and will be revegetated. Because of the steep nature of the sides of the dump there is a risk of severe erosion. There is therefore a risk that additional measures may have to be implemented at significant cost.

Water management at the dump: Water management is adequately provided for at this site with a seepage collection trench around the dump. All seepage and rainfall runoff from the dump flows to a lined return water dam, from where it is recycled for use as industrial water.

Surface subsidence: Extensive areas of the Mine have been stooped and surface subsidence has occurred in a number of areas. Subsidence is monitored and cracks filled where necessary. The management of these areas is in hand and subsidence does not appear to present any significant problems.

Noise and visibility: Due to the presence of the adjoining Makuya and Kruger National Park game reserves, noise and visibility are considered to be significant environmental issues. However these issues appear to be adequately managed.

Closure planning and costing: A closure plan has been produced and Tshikondeni has estimated the closure cost of the mine at ZAR31.9m. SRK proposes a sensitivity contingency of between ZAR5m for evaporation and ZAR50m for desalination be allowed for treatment of possible decanting groundwater.

11.10.1  

Compliance

Environmental authorisations: Arnot Colliery has approved EMPRs for its operations, updated in 2000 (No. 8 Shaft) and 2004 (No. 10 Shaft). The Department of Minerals and Energy (“DME”) has recently confirmed its approval (2005) for Arnot to mine its Mooifontein mini-pit, although this has not yet started. Water management has been identified as the main environmental risk and has received detailed attention from consultants. On that basis, the Integrated Water Use Licence Application for the site was compiled and submitted to the Mpumalanga regional offices of the Department of Water Affairs and Forestry in September 2004, but to date no comment has been received from the regional authorities. Audits on compliance with the EMP have been carried out.

Conversion of mining rights: Arnot holds old order mining rights (Section 9 mining licences) which are in the process of undergoing conversion to new order rights (Section 22). The outlines of the social and labour plans required in terms of the MPRDA in support of conversion to new order rights are in preparation by the Eyesizwe Head Office, but aspects and details specific to Arnot will be included by the mine before submission. No date for submission has been advised. With regard to gender equity, Arnot had set a target of 10% of the workforce being women by 2008. This target was comfortably exceeded in 2005.

11.10.2  

Environmental Issues

Water: A recent assessment of environmental risks facing Arnot identified water management as the highest ranking risk. Three issues are identifiable:

There is a periodic/seasonal excess of water, spilling from the pollution control dam that is generally unsuitable in terms of quality for unrestricted discharge to the watercourse (Rietkruil Spruit). However, this water could theoretically be utilised selectively by the adjacent Eskom Power Station, but no agreement on this has yet been concluded. DWAF has on occasion permitted Arnot to discharge excess water to watercourse in terms of its Managed Release Scheme.

The pollution control dam spills on occasion, indicating that its capacity to contain dirty water does not comply with the requirements of Regulation 704, which requires that capacity is adequate and an 800 mm freeboard is maintained for the 1-in-50-year storm event. Compliance with Regulation 704 requirements in terms of separation of clean and dirty water is concerned is currently receiving attention and is expected to be resolved effectively.

Post-closure decant of polluted water contaminated by the neutralised oxidation of sulfides is expected from both No. 8 and No. 10 Shafts. It is expected that this water will require treatment to improve its quality for discharge to watercourse and use by downstream users. In the case of both mines, ground water users have been identified as potentially affected, and the EMPRs for both the No. 8 Shaft (2000) and the No. 10 Shaft (2004) record the mine’s commitment to provide affected users with an alternative water supply if necessary.

Noise, vibration and dust: Arnot has received a small number of complaints relating to noise, vibration and dust from blasting and traffic. These issues have apparently been resolved satisfactorily and Arnot describes its relationships with its IAPs as “very good”.

11.10.3  

Occupational Health

No data has been made available on numbers of employees affected either by occupational noise-induced hearing loss or by loss of lung function due to exposure of to silicate-laden dust.

11.10.4  

Land claims

Land claims have been lodged with respect to the following farms within the Arnot Mining Licence area:

• Mooifontein 448 JS;
• Klippan 452 JS;
• Grootpan 456 JS (to be confirmed); and
• Rietkuil 491 JS.

The implication of the lodging of these land claims is unknown.

11.10.5  

Environmental and social funding

Funds for new and on-going environmental remediation work are provided by Eskom on motivation, in terms of its contract with Eyesizwe in respect of the Arnot operations. Arnot currently allocates funding amounting to 2% of its payroll value to human resources development and a further 1% of after-tax profits to social investment.

11.10.6  

Closure planning and costing

In terms of the coal supply contract between Arnot and Eskom, Arnot will undertake the closure planning activity and Eskom will manage and fund the closure and rehabilitation of the site as well as the post-closure monitoring and maintenance commitments.

The closure and rehabilitation cost for the Arnot site has been estimated in 2004 on the basis of rates and quantities at ZAR115m.

Approximately R60.9m of this cost has been allocated to the treatment of contaminated decant water. It is understood that Eyesizwe has no liability for closure and rehabilitation costs.

On this basis, SRK has not made an assessment of the adequacy of the closure provisions.

11.11.1  

Environmental and Social Management

Matla Colliery has its environmental policy displayed widely within its premises. The policy focuses on compliance with guidelines, standards and legislation, effective monitoring of the environment, communication on environmental matters with stakeholders, encouraging commitment to environmental protection from employees, minimising the impacts of mining operations, implementing performance standards and promoting sustainable development. Day-to-day environmental management at the colliery is overseen by a well-qualified, recently-appointed Senior Environmental Officer who reports through the Technical Manager to the General Manager. Consultants are being used to investigate potential ground water issues and to update the EMPR to meet the requirements of the MPRDA. Matla is currently developing an EMS in line with the requirements of ISO 14001 and expects ISO 14001 certification in 2006. Social management is the responsibility of the Human Resources Manager. Comprehensive training programmes are provided not only in safety, first aid and technical skills but also in literacy and career development. Community services and social investment are actively developed in the areas of small business development, schooling and housing.

11.11.2  

Compliance

Environmental authorisations: Matla Colliery has an approved EMPR (1995) for its operations, which is currently being updated to include more recent developments and the requirements of the MPRDA. No Integrated Water Use Licence application (“IWULA”) has yet been compiled for the operations on the site, although certain water uses have been registered. (SRK has been advised subsequently that work on compiling an IWULA has been initiated.) Compliance with Regulation 704 is lacking in some respects: Subsequent to the audit in August 2005, work has commenced on a water balance study which is anticipated to finish in December 2005. Storm water management and clean and dirty water separation need further development and this work is reportedly on-going. At the time of the due diligence audit, no document could be shown to indicate that Audits on EMP compliance have been carried out.

Conversion of mining rights: Matla Colliery holds old order mining rights (Section 9 licence) which are in the process of undergoing conversion to new order rights (Section 22). The outlines of the social and labour plans required in terms of the MPRDA in support of conversion to new order rights are in preparation by the Eyesizwe Head Office, but aspects and details specific to Matla are being developed between the Human Resources Manager and the Senior Environmental Officer. No date for submission has been advised.

11.11.3  

Environmental Issues

Water: As is typical for many coal mining operations water management at Matla remains a significant environmental issue:

• Surface subsidence has taken place above areas mined by total extraction. Subsidence has left depressed areas that tend to collect storm water resulting in enhanced infiltration and contamination of water collecting in mine workings. Water discharged from Mine 1 generally has water quality acceptable for most use categories, but water from Mines 2 and 3 is characterised by high sulfates resulting from neutralised sulfide oxidation. Excess water is pumped from underground workings into a pollution control dam. There is a periodic/seasonal excess of water spilling from the pollution control dam that is generally unsuitable in terms of quality for unrestricted discharge to the watercourse (Rietspruit). However, this water could theoretically be utilised selectively by the adjacent Eskom Power Station, but no agreement on this has yet been concluded. DWAF has on occasion permitted Matla to discharge excess water to the Rietspruit in terms of its Managed Release Scheme. Matla is considering different water management options for its excess water to ensure that it could discharge to the watercourse when required.
• The following options will be investigated further based on the water balance:
  • Storing UG;
  • Recycling;
  • Pipeline;
  • Wetland; and
  • Treatment Plant.
  • Occasional spillages from the pollution control dam indicate that its capacity to contain dirty water does not comply with the requirements of Regulation 704, which requires that capacity is adequate and an 800mm freeboard is maintained for the 1-in-50-year storm event. Compliance with Regulation 704 requirements in terms of separation of clean and dirty water requires further attention.
  • Post-closure decant of polluted water contaminated by the neutralised oxidation of sulfides is not expected to occur although there are differences of opinion on this matter. Provision has been made in the closure costing budget to treat a water volume of about 750m³/d to improve the quality for discharge to watercourse and subsequent use by downstream users. A number of neighbouring ground water users have been identified as potentially affected and may need to be provided with a suitable alternate water supply for the long term.

Air quality: There is no spontaneous combustion of discard material that may affect air quality. No complaints have been reported from neighbours with respect to air quality.

11.11.4  

Occupational Health

No data has been made available on numbers of employees affected either by occupational noise-induced hearing loss or by loss of lung function due to exposure of to silicate-laden dust.

11.11.5  

Land claims

Land Claims have been lodged with respect to the following farms within the Matla Licence area:

• Rietvlei 62 IS and Vaalpan 68 IS;
• Haasfontein 85 IS;
• Grootpan 86 IS;
• Moedverloren 88 IS;
• Schaapkraal 93 IS; and
• Eskom Power Station 141 IS.

The implication of the lodging of these land claims is unknown.

11.11.6  

Environmental and social funding

Funds for new and on-going environmental remediation work are provided by Eskom on motivation, in terms of its contract with Eyesizwe in respect of Matla.

11.11.7  

Closure planning and costing

In terms of the coal supply contract between Matla and Eskom, Matla will undertake the closure planning activity and Eskom will manage and fund the closure and rehabilitation of the site as well as the post-closure monitoring and maintenance commitments. The closure and rehabilitation cost for the Matla site was initially estimated in 2001, but updated annually. The closure and rehabilitation costs for 2005 are estimated to be ZAR88m on the basis of rates and quantities. The costs for water management include provision for the evaporation or release of 0.5 Ml/d of excess water. Although decant of contaminated water after closure is not foreseen according to recent hydrogeological investigation, further provision has been made for the desalination of limited decant of up to 0.75 Ml/d and treatment for ten years at an estimated cost of ZAR14.7m. On this basis, SRK has not made an assessment of the adequacy of the closure provisions, other than to note that despite the understanding that Eskom would buy environmentally affected property, there does not appear to be provision for property purchase in the closure cost estimate.

11.12.1  

Compliance

Environmental authorisations: New Clydesdale Colliery has an approved EMPR (October 1998) for many of its operations, but updates are needed for the more recent developments. No Integrated Water Use Licence application has yet been compiled for the operations on the site but underwent registration of all its water-uses. Compliance with Regulation 704 is lacking in some respects: water balances, storm water management and clean and dirty water separation need further development. Surface water quality monitoring is carried out monthly. Ground water monitoring is carried on a quarterly basis on quality and monthly on water levels. No water quality reports that define corrective actions were available at the time of the audit. Internal audits on EMP compliance have been carried out and outstanding actions defined accordingly.

11.12.2  

Conversion of mining rights

New Clydesdale Colliery holds old order mining rights (Section 9 licence) which are in the process of undergoing conversion to new order rights (Section 22). The outlines of the social and labour plans required in terms of the MPRDA in support of conversion to new order rights are in preparation by the Eyesizwe Head Office, but aspects and details specific to New Clydesdale Colliery will be developed with the assistance of the Human Resources Manager. No date for submission has been advised.

11.12.3  

Environmental issues

Water:

• Plant runoff water quality has total salt concentrations of up to 2,500mg/l, of which about 1,500mg/l is sulfate. New Clydesdale Colliery is in the process of constructing a lined pollution control dam for plant runoff.
• New Clydesdale Colliery straddles a water divide with flow both to the Olifants River in the north-east and the Steenkoolspruit in the south-west. The quality in these rivers is adversely affected both by ground water flow and surface water flow emanating from mines in the catchment area. Integrated management of water is complicated by the wide distribution of mining operations. Improvement of surface water management is required to bring the mine into compliance with Regulation 704 aimed at separating clean and dirty water.
• The quality of ground water in the mining areas is adversely affected by the open cast and underground operations as a result of acid generation from sulfide oxidation, followed by in-situ neutralisation. In time neighbouring farmers, who use ground water for domestic purposes and livestock watering, may be affected, as projected in the groundwater section of the EMPR.
• Post-closure decant of polluted water contaminated by the neutralised oxidation of sulfides is expected to occur.

Air quality: New Clydesdale Colliery has initiated a programme to improve the air quality by means of attention to dust caused by heavy earth-moving equipment and vehicles and by attention to burning stockpiles. Ambient air sampling has been initiated.

Waste: Oil spillages around the workshops have added to the soil contamination. New Clydesdale Colliery has appointed contractors to manage and remove the waste materials associated with its workshops, and to recycle waste oil and other recoverable materials.

11.12.4  

Occupational Health

No indications have been made available on numbers of employees affected either by occupational noise-induced hearing loss or by loss of lung function due to exposure of to silicate-laden dust.

11.12.5  

Land Claims

Two Land Claims have been lodged with respect to the following farms within the New Clydesdale Colliery Mining Licence area: Enkeldebosch 20 IS and Haasfontein 28 IS.

These Land Claims are expected to have little effect on New Clydesdale Colliery because the farms in question have been mined out and rehabilitated.

11.12.6  

Environmental and social funding

Funds for new and on-going environmental remediation work are provided from coal sales revenue. The budget for environmental monitoring, investigations by consultants and social expenditure in 2006 appears to be about ZAR357kpm. It is assumed that the ground water investigations, the works required in terms of Regulation 704 and the compilation of EMP reports and IWULAs for the various mining areas under the control of New Clydesdale Colliery will be funded under the normal environmental operating budgets.

11.12.7  

Closure planning and costing

Most of the land affected by mining is owned by Eyesizwe. The stated intention would be to purchase land that is owned by other parties if it were considered affected by mining, although there is no item identifiable in the closure cost budget for land purchase. The closure and rehabilitation costs for the site were most recently updated in 2004.

The closure and rehabilitation costs were estimated at ZAR49.5m excluding VAT, of which only ZAR14.5m has been provided or allocated to a trust fund, leaving an Eyesizwe liability of ZAR35.0m outstanding. The provision for water management of ZAR4.2m does not include desalination. Although decant of contaminated water after closure is expected according to the most recent hydrogeological investigation, no further provision has been made for treatment. Aspects of water management are currently under investigation.

11.13.1  

Environmental and Social Management

As a relatively small mine, Glisa relies to an extent on input and resources from the Eyesizwe Corporate office as well as from Arnot and Matla with regard to environmental and social matters. It subscribes to the environmental policies of Eyesizwe and receives regular visits and input from Lucas Nengovhela, the Corporate Environmental Manager. Consultants have been used to monitor water quality and investigate dust arisings and to produce an EMPR for the mining of Portion 24 of Paardeplaats 380 JT (previously owned by Duiker). Social management at Glisa is the responsibility of the Human Resources Manager. Glisa currently employs about 116 personnel; labour is supplied on contract. Induction and training are outsourced. Glisa maintains close ties with Belfast Municipality and receives applications from the community for assistance in small business opportunities, painting of schools, provision of computers and short-term job opportunities around the mine.

11.13.2  

Compliance

Environmental authorisations: Glisa Colliery has an approved EMPR (2001) for its operations on Portions 1 – 5 of Paardeplaats 380 JT, and a further approved EMPR (2004) for the operations on Portion 24. An Integrated Water Use Licence application was compiled for the operations on the site, but this may need to be supplemented with additional information normally required by the Department of Water Affairs. Certain water uses have been registered. Compliance with Regulation 704 is lacking in some respects: water balances, storm water management and clean and dirty water separation need further development. Audits on EMP compliance have been carried out.

Conversion of mining rights: Glisa holds old order mining rights (Section 9 licence) which are in the process of undergoing conversion to new order rights (Section 22). The outlines of the social and labour plans required in terms of the MPRDA in support of conversion to new order rights are in preparation by the Eyesizwe Head Office, but aspects and details specific to Glisa will be developed with the assistance of the Human Resources Manager. No date for submission has been advised.

11.13.3  

Environmental issues

Water: As is typical for many coal mining operations the management of excess water at Glisa remains a significant environmental issue:

• Dirty pit and stormwater is diverted to a pollution control dam for settlement, evaporation and limited reuse, for dust suppression and particularly by the neighbouring Hadeco bulb nurseries. Spillage into the watercourse that feeds the downstream Belfast Dam, used for potable water supply periodically occurs, resulting in the downstream sulfate concentrations rising to around 100mg/l from a background level of about 10mg/l. It is believed there is no water quality impact for existing users of the Belfast Dam water. Other informal users include livestock, particularly cattle, which should remain unaffected by the water quality reported.
• Spillages from the pollution control dam indicate that its capacity to contain dirty water does not comply with the requirements of Regulation 704, which requires that capacity is adequate and an 800mm freeboard is maintained for the 1-in-50-year storm event. Compliance with this regulation in terms of separation of clean and dirty water requires further attention.
• Improvement of surface water management has been prioritised as an urgent issue in the 2006 environmental budget, where focus will be put on creating water and salt balances and defining the works required to meet the requirements of Regulation 704.
• Post-closure decant of polluted water contaminated by the neutralised oxidation of sulfides is expected to occur. Initial indications are that if the pits and workings are flooded the rise in sulfate concentrations will be limited to a maximum of 1,000mg/l. Provision has been made in the closure costing budget to construct three 15Ha evaporation areas to minimise the spillage of contaminated water to the watercourse.

Air quality: Glisa has initiated annual dust fallout monitoring, largely in response to complaints from neighbouring farmers. Open-cast operations entail the use of heavy motorised earth-moving equipment which raises dust from the workings, although road spraying is practised on all haul roads. Product is removed from site by road transport. Although there are no discard dumps, there are isolated outbreaks of spontaneous combustion within ore stockpile material that may affect air quality.

Noise and vibration: Glisa has received repeated complaints from local farmers and through the Escarpment Environmental Protection Group about noise and vibration from blasting and operations, to the extent that blasting is restricted by Glisa to certain times and days.

11.13.4  

Occupational health

No indications have been made available on numbers of employees affected either by occupational noise-induced hearing loss or by loss of lung function due to exposure of to silicate-laden dust.

11.13.5  

Land Claims

A number of Land Claims have been lodged with respect to the following farms within the Glisa Coal Mining Licence area and the Belfast resource area (the implication of the lodging of these Land Claims is unknown):

• Paardeplaats 380 JT (Glisa);
• Wintershoek 390 JS (Belfast) and Zoekop 426 JS (Belfast); and
• Leeuwbank 427 JS (Belfast) and Blyvooruitzicht 383 JT (Belfast).

11.13.6  

Environmental and social funding

Funds for new and on-going environmental remediation work are provided from coal sales revenue. A sum of ZAR12.4m has been budgeted for environmental and social expenditure in 2006. Of this, ZAR1m is earmarked for Sustainable Development Projects and a further ZAR6.8m for development of the Wonderfontein Siding.

11.13.7  

Closure planning and costing

Most of the land affected by mining at Glisa is owned by Eyesizwe. The stated intention would be to purchase land (under operating costs) that is owned by other parties if it were considered affected by mining, although there is no item identifiable in the closure cost budget for land purchase.

The closure and rehabilitation cost for the Glisa Colliery site was most recently updated in June 2005. The closure and rehabilitation costs were estimated at ZAR16.5m, on the basis of rates and quantities. The costs for water management include provision of ZAR900k for the evaporation of excess water. Although decant of contaminated water after closure is expected according to the most recent hydrogeological investigation, no further provision has been made for treatment. The provision for 2 – 3 years of maintenance and aftercare does not appear to include ongoing water quality monitoring, which SRK would expect to be needed for at least 10 years, post-closure.

11.14.1  

Environmental and Social Management

As a relatively small mine, Strathrae relies to an extent on input and resources from the Eyesizwe Corporate office as well as from Glisa, Arnot and Matla with regard to environmental and social matters. It subscribes to the environmental policies of Eyesizwe and receives regular visits and input from Lucas Nengovhela, the Corporate Environmental Manager. Consultants have been used to update the approved EMPR, to carry out a hydrogeological investigation to determine the potential for contaminated underground water to decant to surface after closure.

Social management at Strathrae is the responsibility of the Glisa Human Resources Manager. Labour is supplied partly on contract. Induction and training are outsourced.

11.14.2  

Compliance

Environmental authorisations: Strathrae Colliery has an approved EMPR (2004) updated from the previous 1997 version. No Integrated Water Use Licence application has yet been compiled for the operations on the site. Compliance with Regulation 704 is lacking in some respects: water balances, storm water management and clean and dirty water separation need further development. Audits on EMP compliance have not been carried out.

Conversion of mining rights: Strathrae holds old order mining rights (Section 9 licence) which are in the process of undergoing conversion to new order rights (Section 22). The outlines of the social and labour plans required in terms of the MPRDA in support of conversion to new order rights are in preparation by the Eyesizwe Head Office, but aspects and details specific to Strathrae will be developed with the assistance of the Glisa Human Resources Manager. No date for submission has been advised.

11.14.3  

Environmental issues

Water: As is typical for many coal mining operations the management of excess water at Strathrae remains a significant environmental issue:

• Dirty stormwater is diverted to a pollution control dam for settlement, evaporation and limited reuse such as dust suppression. Spillages from the pollution control dam are currently flowing to local tributaries and to Grootpan. The pollution control dam is heavily silted from discard and sediment. The discard dump, adjacent to the pollution control dam, is currently being reclaimed and will be reconstructed with new discard on the same footprint and will form the final discard dump, funded by operating costs.
• The spillages indicate that the capacity of the pollution control dam to contain dirty water does not comply with the requirements of Regulation 704, which requires that capacity is adequate and an 800mm freeboard is maintained for the 1-in-50-year storm event. Compliance with Regulation 704 requirements in terms of separation of clean and dirty water requires further attention. Once the discard dump has been moved steps are planned to remove silt from the pollution control dam.
• The quality of ground water can potentially be affected by the mining operations as a result of acid generation from sulfide oxidation, followed by in-situ neutralisation. At present, it is reported that there is no water quality impact on neighbouring ground water users.
• Post-closure decant of polluted water contaminated by the neutralised oxidation of sulfides is expected to occur. Initial indications are that decant from the underground workings will occur in about 40 years after closure at rates of up to 60m³/d and sulfate concentrations of up to 500 mg/l.

Air quality: Strathrae uses water sprays to help control dust from conveyors and road traffic. There are isolated outbreaks of spontaneous combustion within the discard and ore stockpile material that may affect air quality. No complaints appear to have been received from neighbours.

11.14.4  

Occupational health

No indications have been made available on numbers of employees affected either by occupational noise-induced hearing loss or by loss of lung function due to exposure of to silicate-laden dust.

11.14.5  

Land Claims

It is not known whether Land Claims have been lodged in respect of the farms covered by the Strathrae mining licence.

11.14.6  

Environmental and social funding

Funds for new and on-going environmental remediation work are provided from coal sales revenue. No information has been made available on the expenditure budgeted for 2006 in respect of environmental and social issues relating to Strathrae.

11.14.7  

Closure planning and costing

The stated intention is that Eyesizwe would purchase land owned by other parties if it were considered affected by mining. There is no item identifiable in the closure cost budget for land purchase.

The closure and rehabilitation cost for the Strathrae Colliery site was most recently updated in June 2005. The closure and rehabilitation costs were estimated at ZAR14.5m excluding VAT, of which all has been provided.

The provision for water management totals ZAR30k for cleaning out existing dams at the plant. Although decant of contaminated water after closure is expected according to the most recent hydrogeological investigation, no further provision has been made for treatment. In the view of SRK, this provision is unlikely to be adequate. The provision for 2 – 3 years of maintenance and aftercare does not appear to include ongoing water quality monitoring, which SRK would expect to be needed for at least 10 years, post-closure.