11.   ENVIRONMENTAL MANAGEMENT

11.21  

Industrial Minerals – Glen Douglas

The mine, where dolomite is mined from 3 open pits (2 of which are operational), is constructed on the banks of the Klipriver, adjacent to the town of Henley-on-Klip and upstream of the industrial area of Vereeniging. The area around the mine is utilised by farmers, many of whom abstract water from the Kilpspruit for irrigation. The defunct A-pit has been converted into a recreational facility where various adventure activities occur (scuba diving, quad biking and 4 x 4 routes).

11.21.1  

Compliance

The mine is currently operating under an EMPR approved in 2002, however the mine expects to submit a MPRDA conversion by the end of the year. A SLP is currently being developed in support of this process. The process has, however, been hampered by the potential sale of the mine. Water uses on the mine have been registered, with the exception of removal of ground water inflow from A-pit. The north east waste rock dump is built within the 1-in-50-year floodline of the Klipriver and clean runoff the surrounding catchment is not adequately diverted through the mine. DWAF is aware of these problems and is negotiating with the mine regarding exemption from GN0 4, which the the mine currently convenes with these activities. The plans are to make the necessary submissions by the end of the year. DWAF has not yet requested the mine to submit a water use licence application. The mine is currently operating under the Water Act, 1956, permit with no expiry date on the permit. There are instances when the alkalinity of the discharge water exceeds the permit conditions. The mine maintains that this is a result of geological interactions with groundwater and not a result of mining activities. To this end, the mine has agreed with DWAF to undertake a regional groundwater study to determine background conditions.

The dump, where domestic waste from the mine was historically disposed, has been made redundant and the bulk of the waste lifted and disposed of at the local municipal dump. There is no groundwater monitoring around the dump so there is no information regarding the potential development of a pollution plume. Although the dump is no longer utilised, the mine will still need to close the area in terms of Section 20 of the ECA. The mine undertook an enviro-legal audit during 2004. The aspects identified were rated from 1 to 4 with 1 being low risk and 4 being high risk. The aspects that have not yet been closed out and have a rating of four include the water and waste aspects discussed above and failure to undertake rehabilitation of the surface of the land as an integral part of the operation and pollution of groundwater via hydrocarbon spills. The mine is ISO 14001 certified (2004) and undergoes bi-annual surveillance audits.

11.21.2  

Environmental and Social Management

Environmental management falls within the portfolio of the Technical Services Manager. He is aided by a secretary who is responsible for the ISO 14001 documentation. Social management is the responsibility of the Human Resources Manger. SRK is of the opinion that the mine requires an environmental manager, whose key performance area is solely environmental management. The operational environmental budget for the facility is approximately ZAR0.6mpa, ZAR0.2m of which is contributed to the mine’s closure fund, with the remainder being utilised for specialist studies, ISO audits and environmental monitoring. The mine reports that the rehabilitation of the dumps is funded from a mining budget. SRK is of the opinion that the operational budget is insufficient to carry out ongoing environmental management and should be in the order of ZAR1mpa.

11.21.3  

Environmental Issues

Waste rock dumps: The mine is currently focusing on vegetating the dumps on the mine’s perimeter that are visible from the town of Henley-on-Klip. The mineralogy of the waste rock dumps will not produce acid rock drainage, with seepage reported to be alkaline and enriched in calcium and magnesium. Although, the waste rock dumps are at the angle of repose, the dumps are not high (less than 20m) and do not pose a stability risk. Therefore, it is not expected that the dumps will require re-profiling to a lesser slope.

Tails disposal: Tails from the plant are pumped to temporary storage facilities, where it is allowed to dry. Once dry, these tails are sold to farmers as agricultural lime. It is reported that minimal dust is generated, as the product sold to the farmers still contains approximately 10% moisture.

Hazardous material handling: Historical hydrocarbon housekeeping management has resulted in the contamination of soil adjacent to the plant and workshop area (approximately 2 – 3Ha). The area has been ripped and fertilised to stimulate microbial activity that should degrade the hydrocarbons. Although monitoring boreholes have been drilled in this area, these boreholes have not yet been sampled. Therefore, information on plume development is absent. SRK is of the opinion that groundwater contamination is unlikely to be significant, as it is expected that the groundwater will daylight in the pit where it will be sufficiently diluted.

Asbestos: Some of the older buildings still contain asbestos in the form of ceiling boards (100 – 200m3) that ultimately will require disposal at a hazardous waste site (approximate cost (ZAR0.1m). The mine report that the majority of PCB contaminated oils have been removed from electrical installations with only residual PCB levels remaining. SRK does not consider this a significant liability.

Water contamination: Groundwater inflow to the pits is returned to the plant (68%), discharged to the Klipspruit (22%) and the remainder used for dust suppression. The geology of the area results in an enrichment of calcium, magnesium and alkalinity in discharge water, however, it is only alkalinity that sometimes exceeds permit conditions. The mine is to embark on a baseline survey to determine whether the enrichment is natural or a result of mining activities. Periodically, nitrates (blasting residues) accumulate in the pit water, with the result that the nitrate concentrations in the discharge to the Klipspruit are slightly elevated (15% – 30% above DWAF drinking water guideline). This should improve with the change in blasting procedures.

Water management: The mine is not compliant with GN 704 with clean storm water runoff from the land surrounding the mine flowing through a culvert under the access road to the mine and then through the plant area, where it becomes contaminated with sediments and sometimes alkalinity. It then enters a diversion around the pit and is release into the Klipriver. The mine has investigated the problem and discovered that, due to the topography of the area, there is no other flow path for the water. SRK considers this a risk, as the mine might be forced by DWAF to collect the water in a retention dam and then pump it to the Klipspruit, to prevent the clean water being contaminated. SRK therefore proposes a sensitivity contingency of ZAR1 – 2m.

Sink hole formation: Water accumulating on surface has lead to the formation of sinkholes. Currently, this is not a significant problem and it is managed by ensuring that there is minimal surface water accumulation. No predictive geotechnical work has been undertaken to identify zones of high sinkhole formation potential so the future risk is not known. The mine are, however, aware of potential sinkhole formation and regularly monitor this area.

Air emissions: Dust emissions from the mine are currently a problem for the local community with dust being generated in the pit, on haul roads and in the plant. The mine has implemented dust control measures, however there are still occasions when the DEAT action level guidelines are triggered at three of the boundary monitoring points. Assuming appropriate management is implemented, this is not considered a major risk.

Community relationships: The mine built a school for the local community in 1997. There were plans to extend the school, however, the Department of Education never applied for permission to rezone the 13 stands on which the school was located, so Phase II never started. The mine has submitted its Social and Labour Policy, which contains plans to uplift the surrounding community. The mine does however, make ad hoc donations to the community as and when required, with each request for donations being individually evaluated.

Decommissioning and closure liability: The mine has no closure plan, however, closure costing is based on commitments made in the EMPR. The mine has assessed its immediate closure cost (June 2005) to be ZAR9.8m. This includes ZAR6.9m for demolition costs and ZAR1.9m for rehabilitation costs. The primary expense associated with rehabilitation appears to be the re-vegetation of the waste rock dumps. There does not seem to be an allowance for any restoration of the footprints where infrastructure is removed. SRK is of the opinion that the rehabilitation costs are insufficient, with there being a shortfall of ZAR13 – 17m. Based on the information available, SRK is of the opinion that the R6.9m for demolition is sufficient.




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