External Environmental Audits of the Impumelelo Colliery · 2020. 12. 15. · External...
Transcript of External Environmental Audits of the Impumelelo Colliery · 2020. 12. 15. · External...
Digby Wells and Associates
(South Africa) (Pty) Ltd
Company Registration: 2010/008577/07
Turnberry Office Park,
Digby Wells House.
48 Grosvenor Road,
Bryanston,2191
Phone: +27 (0) 11 789 9495
Fax: +27 (0) 11 789 9495
E-mail: [email protected]
Website: www.digbywells.com
Directors: J Leaver (Chairman)*,
NA Mehlomakulu*, A Mpelwane, DJ Otto,
M Rafundisani
*Non-Executive
External Environmental Audits of the Impumelelo Colliery
Environmental Audit Report
Prepared for:
Sasol Mining (Pty) Ltd
Project Number:
SAS6652
December 2020
DIGBY WELLS ENVIRONMENTAL
www.digbywells.com ii
This document has been prepared by Digby Wells Environmental.
Report Type: Environmental Audit Report
Project Name: External Environmental Audits of the Impumelelo Colliery
Project Code: SAS6652
Name Responsibility Signature Date
Anela Sotashe Report Compiler
November 2020
Justin du Piesanie Report Reviewer
November 2020
Mia Smith Senior Reviewer
December 2020
This report is provided solely for the purposes set out in it and may not, in whole or in part, be used for any other purpose
without Digby Wells Environmental prior written consent.
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EXECUTIVE SUMMARY
Sasol Mining (Pty) Ltd (hereinafter Sasol Mining) appointed Digby Wells Environmental
(hereinafter Digby Wells) to undertake an environmental audit at the Impumelelo Colliery,
located near Greylingstad in the Mpumalanga Province. The independent external
environmental audit was undertaken in terms of Regulation 34 of the Environmental Impact
Assessment Regulations, 2014 (GN R982 of 04 December 2014, as amended) (the “EIA
Regulations, 2014”) promulgated under the National Environmental Management Act, 1998
(Act No. 107 of 1998) (NEMA). The Impumelelo Colliery holds an Environmental Authorisation
(EA) and associated Environmental Management Programme (EMPr) (Clean Stream, 2009)
for mining of coal and relevant listed activities.
The main objectives of this Environmental Audit Report are therefore to:
● Provide the Department of Mineral Resources and Energy (DMRE) and other relevant
stakeholders with appropriate information on the colliery’s compliance to stated
commitments;
● Determine the colliery’s level of compliance with the EA and EMPr and identify
potential non-compliances;
● Propose mitigation measures for environmental impacts not previously identified in the
EMPr and recommend measures to address areas of non-compliance; and
● Supply a basis for the initiation of corrective action where necessary or appropriate as
identified through the assessment.
An initial audit opening meeting was held on 21 October 2020, after which the site assessment
was completed from 21 to 23 October 2020 with the representatives from the Impumelelo
Colliery.
Compliance with the commitments of the both the EA and EMPr were rated using the
evaluation criteria described in the table below.
Evaluation Criteria
Not Compliant
(NC)
These areas were found non-compliant as observed during the site visit with the
commitments of EMPr conditions.
Compliant (C) These are areas of complete fulfilment of the stated commitment/ requirement.
Not Applicable
(N/A)
These areas which were found not to be relevant to the operations at this phase
of the activity, i.e. pre-construction, construction and decommissioning phase
commitments.
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The table shows the percentage of non-compliances, compliances and commitments that are
no longer applicable on both the EA and EMPr. Detailed tables of the conditions and the audit
findings can be found in Section 9 of this report.
Overall Compliance for Impumelelo Colliery
Total
Number of
Conditions
Total
Compliance
Total Non-
Compliances
Total Not
Applicable
Total
possible
score
Score
EA 84 57 3 24 60 95%
EMPr 328 196 39 93 235 83.4%
Summary of the Findings
The main findings and areas of non-compliance included the following:
● Erosion was noticed at various areas, including at the Sewage Treatment Plant (STP),
the outlet of the stormwater drain and at the reservoirs. This is due to the lack of
vegetation. Erosion was also noted along the Sasol Coal Supply (SCS) conveyor as a
result of steep slopes and lack of stability measures;
● Contaminated water (oily water) was observed in clean water areas on site;
● Various oil spills were noticed on the paved areas where vehicles are parked;
● The general housekeeping around the site was found to be insufficient. Stormwater
drains were clogged with mixed mine waste, thus preventing the flow of water through
the system. Clean and dirty water drains were not separated; and
● Dirty oily rags were found in clean water trenches. Sediment and coal dust was also
observed in clean water trenches during the time of audit.
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TABLE OF CONTENTS
1 Introduction ....................................................................................................................... 8
2 Project Description ............................................................................................................ 8
3 Terms of Reference .......................................................................................................... 8
4 Details and Declaration of the EAP ................................................................................. 10
5 Scope and Purpose of the Audit ..................................................................................... 10
6 Methodology.................................................................................................................... 11
6.1 Audit Initiation Meeting .......................................................................................... 11
6.2 Site Assessment and Interviews ............................................................................ 12
6.3 Site Observations .................................................................................................. 12
6.3.1 Sewage Treatment Plant ............................................................................... 12
6.3.2 Waste Management ....................................................................................... 13
6.3.3 Bunker and the Conveyor .............................................................................. 14
6.3.4 Pollution Control Dam .................................................................................... 15
6.3.5 Hydrocarbon Spillages ................................................................................... 16
6.4 Document Review ................................................................................................. 17
6.5 Performance Assessment and Reporting .............................................................. 19
7 Evaluation of the Relevance and Effectiveness of the EMPr .......................................... 19
8 Assumptions, Uncertainties and Gaps in Knowledge ..................................................... 19
9 Audit Findings ................................................................................................................. 20
9.1 Detailed Audit Findings.......................................................................................... 20
9.2 Summary of Level of Compliance .......................................................................... 54
10 Conclusion and Findings ................................................................................................. 54
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LIST OF FIGURES
Figure 6-1: Sewage Treatment Plant ................................................................................... 13
Figure 6-2: ISO Yard (Waste Management area) ................................................................ 14
Figure 6-3: SCS Conveyor Infrastructure ............................................................................ 15
Figure 6-4: Silt trap and PCD .............................................................................................. 16
Figure 6-5: Hydrocarbon Spillages ...................................................................................... 17
LIST OF TABLES
Table 3-1: Contents of the Report as per Appendix 7 of the EIA Regulations, 2014 .............. 9
Table 4-1: Details of the EAP .............................................................................................. 10
Table 6-1: Auditors’ Details ................................................................................................. 11
Table 6-2: Interviewed Personnel during the Compliance Audit .......................................... 12
Table 6-3: Evaluation Criteria .............................................................................................. 19
Table 9-1: Assessment of Compliance to the Operational Requirements of the EA ............ 21
Table 9-2: Assessment of Compliance to the Operational Requirements of the EMPr ........ 29
Table 9-3: Compliance Rating: EA and EMPr ..................................................................... 54
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LIST OF ACRONYMS AND ABBREVIATIONS
DEDET Department of Economic Development, Environment and Tourism
Mpumalanga
Digby Wells Digby Wells Environmental
EA Environmental Authorisation
EAP Environmental Assessment Practitioner
EIA Environmental Impact Assessment
EIA Regulations,
2014
Environmental Impact Assessment Regulations, 2014 (GN R982 of 04
December 2014, as amended)
EMPr Environmental Management Programme
IMP Integrated Management Plan
IWWMP Integrated Water and Waste Management Plan
MPRDA Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of
2002)
NEMA National Environmental Management Act, 1998 (Act No. 107 of 1998)
ROM Run of Mine
RSIP Rehabilitation Strategy and Implementation Plan
PCD Pollution Control Dam
ROM Run of Mine
Sasol Mining Sasol Mining (Pty) Ltd
SOP Standard Operating Procedure
STP Sewage Treatment Plant
WUL Water Use Licence
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1 Introduction
Sasol Mining (Pty) Ltd (hereinafter Sasol Mining) appointed Digby Wells Environmental
(hereinafter Digby Wells) to undertake an audit at the Impumelelo Colliery, located near
Greylingstad in the Mpumalanga Province. The independent external environmental audit was
undertaken in terms of Regulation 34 of the Environmental Impact Assessment Regulations,
2014 (GN R982 of 04 December 2014, as amended) (the “EIA Regulations, 2014”)
promulgated under the National Environmental Management Act, 1998 (Act No. 107 of 1998)
(NEMA). The Impumelelo Colliery holds an Environmental Authorisation (EA) and associated
Environmental Management Programme (EMPr) (Clean Stream, 2009) for mining of coal and
relevant listed activities.
2 Project Description
Sasol Mining developed the Impumelelo Colliery as an underground bord and pillar operation,
with the intention to satisfy the existing Sasol Synfuels market after the closure of the
Brandspruit Colliery. Impumelelo is located southwest of Secunda, east of Greylingstad and
northwest of Standerton. An Environmental Authorisation (EA) was granted for the Impumelelo
Colliery by the Mpumalanga Department of Economic Development, Environment and
Tourism Mpumalanga (DEDET) on 11 August 2010 and amended on 12 December 2011.
The Sasol Coal Supply (SCS) blending plant is located near the Brandspruit Colliery. To
deliver coal to the blending plant, Sasol Mining has constructed a conveyor belt (the “SCS
Conveyor”) from the Impumelelo Colliery to the plant. The SCS Conveyor servitude includes
a service road, water pipelines, as well as power and communication lines.
Process water transfer pipelines have been installed between the Impumelelo Colliery and
Brandspruit. All effluent water captured at the Impumelelo Colliery is disposed of via concrete-
lined trenches to containment dams. The colliery currently operates three dams 7 and 84
megalitre (Mℓ) where all effluent water and water that has been removed from the underground
workings is collected and stored. This water is reused as process water as far as possible.
Water from these dams is also transferred to the Brandspruit Colliery and SCS blending plant
to be used in the coal-washing process where required.
3 Terms of Reference
The environmental audit is a systematic, periodic, objective and documented evaluation of the
continued relevance and effectiveness of the contents of an EA and approved EMPr, as well
as the execution thereof.
This Environmental Audit Report has been compiled to comply with Regulation 34 of the EIA
Regulations, 2014 (as amended). Compliance of this Environmental Audit Report with
Appendix 7 of the EIA Regulations, 2014 is summarised in Table 3-1.
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Table 3-1: Contents of the Report as per Appendix 7 of the EIA Regulations, 2014
No. Requirement Section of this Report
Content of the Environmental Audit Report
3 (1) (a)
An environmental audit report prepared in terms of these
Regulations must contain (a) details of-
i. the independent person who prepared the
environmental audit report; and
ii. The expertise of independent person that compiled
the environmental audit report.
See 4: Details and
Declaration of the EAP
3 (1) (b) A declaration that the independent auditor is independent in
a form as may be specified by the competent authority.
See 4: Details and
Declaration of the EAP
3 (1) (c) An indication of the scope of, and the purpose for which,
the environmental audit report was prepared.
See Section 5: Scope
and Purpose of the
Audit.
3 (1) (d) A description of the methodology adopted in preparing the
environmental audit report.
See Section 6:
Methodology.
3 (1) (e)
An indication of the ability of the EMP, and where
applicable, the closure plan to
i. sufficiently provide for the avoidance, management
and mitigation of environmental impacts associated
with the undertaking and closure of the activity on an
on-going basis;
ii. Ensure compliance with the provisions of the EA, EMP,
and where applicable, the closure plan.
See Section 7:
Evaluation of the
Relevance and
Effectiveness of the
EMPr.
3 (1) (f) A description of any assumptions made, and any
uncertainties or gaps in knowledge.
See Section 8:
Assumptions,
Uncertainties and
Effectiveness of the
EMPr
3 (1) (g)
A description of any consultation process that was
undertaken during the course of carrying out the
environmental audit report.
Consultation with Site
staff was undertaken.
No consultation with
the public was
undertaken as part of
this audit. 3 (1) (j)
A summary and copies of any comments that were received
during any consultation process; and
3 (1) (k) Any other information requested by the competent
authority. None.
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4 Details and Declaration of the EAP
Sasol Mining appointed Digby Wells as the independent Environmental Assessment
Practitioner (EAP) to undertake the environmental audit. Details and experience of the person
who compiled this report are provided in Table 4-1 below.
Table 4-1: Details of the EAP
Name Mia Smith
Qualifications MSc Geography (University of Johannesburg)
EAPASA Registration No. 2019/1282
Experience 13 years
Company Digby Wells and Associates (South Africa) (Pty) Ltd
Telephone 011 789 9495 Email: [email protected]
I, Mia Smith, herewith declare that:
● I act as the independent environmental practitioner in this Audit;
● I will perform the work relating to the Audit in an objective manner, even if this results
in views and findings that are not favourable to the Holder;
● I declare that there are no circumstances that may compromise my objectivity in
performing such work;
● I have expertise in conducting environmental audits, including knowledge of the Act,
Regulations and any guidelines that have relevance to the activity;
● I have no, and will not engage in, conflicting interests in the undertaking of the audit;
● declare that all the information furnished by me in this application are true and correct;
● I will perform all other obligations as expected from an environmental assessment
practitioner in terms of the Regulations; and
● I realise that a false declaration is an offence in terms of section 24F of the Act.
Signature of the EAP:
Date: December 2020
5 Scope and Purpose of the Audit
An Environmental Audit Report must determine compliance with the EA and EMPr and the
appropriateness and adequacy of the EA and EMPr through on-going assessment.
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The objectives of the Environmental Audit Report are to:
● Report on the level of compliance with the conditions of the EA and the EMPr and the
extent to which the avoidance, management and mitigation measures provided for in
the EMPr are implemented;
● Identify and assess any new impacts and risks as a result of undertaking activities at
the colliery;
● Evaluate the effectiveness of the EMPr;
● Identify shortcomings in the EMPr; and
● Identify the need for any changes to the avoidance, management and mitigation
measures provided for in the EMPr.
6 Methodology
The methodology used in the undertaking of the environmental audit was as follows:
● Review of the conditions of the EA and EMPr commitments;
● Review of all documentation required to assess compliance with the EA and EMPr;
● Undertake a site visit of the colliery from 21 to 23 October 2020 to identify instances of
compliance and non-compliance with the EA and EMPr; and
● Compilation of this Environmental Audit Report.
6.1 Audit Initiation Meeting
An initial audit opening meeting was held on 21 October 2020, after which the site assessment
was completed from 21 to 23 October 2020 with representative of the Impumelelo Colliery.
The meeting was attended by the Digby Wells Auditors and representatives of the Impumelelo
Colliery, which are listed in Table 6-1 and Table 6-2.
Table 6-1: Auditors’ Details
Digby Wells Auditors Qualifications
Carol Hooghiemstra MSc (Environmental Management)
BSc Hons (Agriculture)
BSc (Agriculture)
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Stephanie Aken BSc Hons, PG Diploma Environmental Management
Anela Sotashe BSc (Environmental Studies)
Tshepiso Ratlagane BSc Hons (Environmental and Water)
Table 6-2: Interviewed Personnel during the Compliance Audit
Impumelelo representatives Position and Department
Duane MacPherson Environmental Control Officer
Boipelo Mongale SHE
Johan Rensberg Survey
Mxolisi Motshwane SHE
JR Phiri Engineer
D Mapleeson Environmentalist
Lawrence Maben Production
6.2 Site Assessment and Interviews
During the site assessment, the auditors undertook interviews, reviewed relevant
documentation and completed an inspection of the site.
The following areas were assessed by the auditors:
● Sewage Treatment Plant (STP);
● Waste Management Area (ISO yards);
● Pollution Control Dam (PCD);
● Bunker area and emergency stockpile;
● Overland conveyor belt and its servitude; and
● Contractors yards.
6.3 Site Observations
Observations made during the site assessment undertaken from 21 to 23 October 2020 are
presented in the section below.
6.3.1 Sewage Treatment Plant
The STP is well fenced and access is controlled. Sewage is treated and the treated effluent is
discharged to the environment and later make its way to the farm dam situated outside of the
boundaries of the Impumelelo Colliery. However, Proxa was appointed to operate and
maintain the STP and conduct monthly samples of the treated effluent.
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Figure 6-1 below shows the components of the STP. The dried sludge is removed from the
sludge drying bed and stored in hazardous waste bins, which are later removed by a
contractor.
Aerator
Chlorine tank
Balancing tanks
Dried Sludge
Figure 6-1: Sewage Treatment Plant
6.3.2 Waste Management
All waste types at the Impumelelo Colliery is collated and stored at the ISO yard where it gets
sorted into different waste streams. The ISO yard is concreted and separated into the different
waste streams, e.g. recyclable waste, domestic waste and hazardous waste, plastic waste,
cable waste, steel waste, rubber waste, old oil, wood, as well as geological core waste.
Hazardous waste is contained in skips that are covered by a roof to prevent ingress of
rainwater. Figure 6-2 below provides few waste types that are generated and found at the
Impumelelo Colliery.
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ISO Yard
Pastic waste
Cable waste
Figure 6-2: ISO Yard (Waste Management area)
6.3.3 Bunker and the Conveyor
All dirty runoff from the bunker area and emergency throw-out area is diverted to the 84 Mℓ
PCD. This water is then used underground for dust suppression and for other mining
purposes.
Runoff from the bunker is diverted through a silt trap which is inspected and cleaned on a
regular basis. The drains and the silt trap were maintained to ensure that the runoff from the
emergency throw-out area will be contained. The silt trap is concrete lined.
The overland conveyor conveys the coal mined at the Impumelelo Colliery to the SCS site
where it is blended and conveyed to the Sasol Synfuels Operations. Due to unavailability of
responsible people from SCS and time constraints, the total length of the conveyor was not
visited (see Figure 6-3).
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Shaft
Silt trap
Conveyor belt
Figure 6-3: SCS Conveyor Infrastructure
6.3.4 Pollution Control Dam
All PCDs are locked to prevent unauthorised entrance to these dams and prevent any potential
harm to people and animals. Signage indicating persons in charge and the risks associated
are adequately displayed at the entrance to the PCDs. These PCDs are kept at 30% or less
to avoid overflows; however, no overflow was reported since the commencement of the
operation. The silt traps are used to trap coal sediments in water that is pumped from the
underground mine workings, as well as the bunker. Overflow from the silt traps make its way
to the PCD. The silt trap is inspected on a weekly basis; however, the silt trap was not in good
condition at the time of the site visit, as it appeared to be overflowing (Figure 6-4).
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Silt trap
Pollution control dam
Figure 6-4: Silt trap and PCD
6.3.5 Hydrocarbon Spillages
Housekeeping throughout the shaft area were not of a high standard. Various spillages (i.e.
hydrocarbon and fine coal) were noticed which were not cleaned immediately after the spill,
as indicated in Figure 6-5 below.
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Figure 6-5: Hydrocarbon Spillages
6.4 Document Review
The auditors conducted a document review based on the commitments set out in the EA and
commitment contained in the EMPr. The following documents are considered as relevant to
the audit and these were provided and reviewed during and/or after the site assessment. The
following documentation was reviewed and available in an electronic format device:
● IsoMetrix checklist of the Impumelelo EMPr;
● IsoMetrix checklist of the Impumelelo EA;
● EA approval dated 15 September 2010;
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● EA Amendment approval dated 12 December 2011;
● EMPr dated 06 July 2010;
● Impumelelo Colliery: Environmental Noise Monitoring Survey 2019;
● Job Cards generated for the maintenance of the 7 megalitre (Mℓ) dam;
● Job Cards generated for the maintenance of the 84 Mℓ dam;
● Job Card: Inspection on erosion;
● Job Card generated for the inspection on LHD 0218;
● SCS Job Card inspection of the silt traps and trenches;
● Job Card created for the pipeline inspection;
● Job Card generated on visual inspection of V drain;
● Certificates of Safe Disposal (Interwaste Environmental Solution);
● SCS Integrated Management Plan (IMP): 16 March 2020;
● SCS IMP: 10 March 2020
● Proof of submission of the Environmental Performance Assessment and EA audit
report for Impumelelo Mine dated 20 April 2020;
● Training records January to December 2019;
● Mine Water Balance (m3/d) for 01 January 2020 to 27 May 2020;
● External EMP Performance Assessment Report, 2019 compiled by Digby Wells
Environmental;
● External EA audit 2019, compiled by Digby Wells Environmental;
● Impumelelo Incident Register, 2020;
● Monitoring Reports;
● Integrated Water Monitoring and Reporting Programme: Brandspruit Colliery:
Impumelelo Mine (License No: 08/C12D/ABCEFGIJ/2160), dated 30 September 2020;
● Impumelelo Integrated Water Monitoring Report covering the period January 2020 to
June 2020;
● Integrated water use license (Licence No. 08/C12D/ABCEFGIJ/2160), Bi-annual
Report, dated August 2020;
● Biomonitoring Assessment: Impumelelo Coal Conveyor, Dry Season Survey 2019;
● Biomonitoring Assessment: Impumelelo Coal Conveyor and D714 road, Wet Season
Survey 2019;
● 2013 Annual External Audit to determine compliance with Water Use License issued
to Sasol Mining Impumelelo Mine, dated 30 September 2014;
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● Rehabilitation Strategy and Implementation Plan (RSIP) for Impumelelo Shaft (2020);
and
● Integrated Water and Waste Management Plan, 2019 to 2020.
6.5 Performance Assessment and Reporting
Table 6-3 summarises the scoring system the auditors used to measure compliance with the
conditions contained in the both the EA and EMPr.
Table 6-3: Evaluation Criteria
Not Compliant
(NC)
These areas were found non-compliant as observed during the site visit with the
commitments of EMPr conditions.
Compliant (C) These are areas of complete fulfilment of the stated commitment/ requirement.
Not Applicable
(N/A)
These areas which were found not to be relevant to the operations at this phase
of the activity, i.e. pre-construction, construction and decommissioning phase
commitments.
Compliance is evaluated by determining the total number of conditions to be complied with,
excluding those conditions deemed not applicable. Where conditions are identified as “not-
applicable” reasons for excluding the condition from the assessment are provided.
The overall compliance score is then calculated as a percentage of the total possible
compliance score.
7 Evaluation of the Relevance and Effectiveness of the EMPr
In the opinion of the auditor, the EMPr provides comprehensive requirements for achieving
environmental objectives and clear monitoring and reporting requirements. However,
duplication of conditions and commitments within the EA and EMPr have been noted.
Conditions pertaining to subsidence were found to not be applicable during the environmental
audit; however, they may be relevant at a later stage of the Operational Phase.
8 Assumptions, Uncertainties and Gaps in Knowledge
The following assumptions, uncertainties and gaps in knowledge are applicable to this environmental audit:
● The findings recorded in this Environmental Audit Report are limited to the
observations made at the mining areas inspected from 21 to 23 October 2020;
● Areas identified by the audit team in conjunction with the operation were visited and
are referred to in this report;
● The full extent of the conveyor route was not inspected due to the unavailability of
responsible people from SCS and time constraints; and
● This audit was undertaken in terms of the approved EMPr dated 15 September 2010.
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9 Audit Findings
9.1 Detailed Audit Findings
Table 9-1 below presents the detailed audit findings against compliance against the EA;
whereas Table 9-2 contains detailed audit findings against each condition of the Operational
Phase of the EMPr.
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Table 9-1: Assessment of Compliance to the Operational Requirements of the EA
Condition Compliance
Rating Audit Comments Proof of Compliance
3.1 Authorization of the activity is subject to the conditions contained in
this authorization that are part of the environmental authorization and
are legally binding on the holder of the authorization.
C
This condition is noted. N/A
3.2 The holder of the authorization must ensure compliance with the
conditions by any person acting on his or her behalf, an agent, sub-
contractor, employee or person rending a service to the holder of the
authorization.
C
This condition is noted. N/A
3.3 The activities that are authorized may only be carried out at the
property indicated in the Environmental Authorization. C
This condition is noted. N/A
3.5 Any changes to, or deviations from, the project description set out in
this authorization must be approved, in writing, by the Department
before such changes or deviation may be affected. In assessing whether
to grant such approval or not, the Department may request such
information as it deems necessary to evaluate the significance and
impacts of such changes or deviations and it may be necessary for the
holder of the authorization to apply for further authorization in terms of
the regulations.
C
This condition is noted. N/A
3.6 These activities must commence within a period of (2) years from
the date of issue. If commencement of the activity does not occur within
that period, the authorization lapses and a new application for
environmental authorization must be made in order for the activity to be
undertaken.
C
This condition is noted. N/A
3.7 The authorization does not negate the holder of the authorization,
responsibility to comply with any other statutory requirements that may
be applicable to the undertaking of the activities.
C
This condition is noted. N/A
3.8 The holder of the authorization is responsible for the compliance
with the provisions for Duty of Care and Remediation of Environmental
Damage contained in Section 28 of the National Environmental
Management Act, 1998 (Act 107 of 1998).
C
This condition is noted. N/A
3.9 The holder of the authorization must notify every registered
interested and affected party, in writing and within seven (7) calendar
days, of receiving notice from the Department's decision to authorize the
activities.
C
This condition is noted. N/A
3.10 a) The notification referred to above must:
a) Specify the date on which the authorization was issued;C
This condition is noted. N/A
3.10 b) Inform the interested and affected parties of the appeal
procedure provided for in chapter 7 of the regulations; and C
This condition is noted. N/A
DIGBY WELLS ENVIRONMENTAL
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Condition Compliance
Rating Audit Comments Proof of Compliance
3.10 c) Advise the interested and affected parties that a copy of the
authorization and reasons for the decision will be furnished on request. C
This condition is noted. N/A
3.11 The EMPr in the EIA Report must be implemented and strictly
adhered to throughout the life cycle of these activities. C
The EMP and its conditions are implemented and audited against by
way of the audit conducted on site. An audit was previously
conducted by Digby Wells in November 2017 and November 2019.
External EMP Performance Assessment Report, 2019 compiled
by Digby Wells Environmental.
3.12 The applicant must appoint an independent Environmental Control
Officer (ECO) that will have the responsibility of implementing the EMPr
and ensuring compliance with the conditions of this environmental
authorization. C
Emile Blaauw (SHE Professional Services) was appointed as ECO at
the commencement of the construction phase. Digby Wells was
provided with proof of appointment of Themko Mavuso in October
2014 and Mirie Grant who replaced Themko Mavuso in February
2015 as the ECO at the operation.
Currently the responsibility of implementing the EMP lies with the
Impumelelo Environmental Practitioner as the project is in its
Operational Phase.
Letter dated 22 September 2020. Appointment letter of an ECO.
3.12.1 The ECO must be appointed before the commencement of
construction and the Department must be notified of such an
appointment for communication purposes.
C
Letters communicating the appointment of Themko Mavuso, Mirie
Grant and Emile Blaauw were submitted to the Department.
Letter dated 22 September 2020. Appointment letter of an ECO.
3.12.2 The ECO must submit quarterly compliance reports to the
Department in writing and copy the applicant with such reports. The
reports must include a description of all activities on site, problems
identified, transgressions noted and remedial action implemented. All
reports must reflect the Department's reference number of the project on
the cover page.
C
The ECO submits the quarterly compliance report to the Department
biannually. Proof of submission to the department was available at
the time of audit.
Proof of submissions.
3.12.3 The ECO must be available on site during the evaluation,
monitoring and implementation of the Environmental Plan and; C
The appointed ECOs and now Impumelelo Environmental
Practitioner is available on site to evaluate, monitor and implement
the conditions of the EA and EMP.
Site observations.
3.12.4 Act as a guide, advisor and consultant to the contractor and client
on environmental issues during construction. C
The appointed ECOs discussed environmental issues during weekly
operations meetings with contractors and Sasol Mining personnel.
This is now the responsibility of the Impumelelo Environmental
Practitioner.
Site observations.
3.13 Ground water monitoring boreholes must be monitored bi-annually
at least once in summer and once in winter to avert any potential danger
to the livestock farming activities down slope of the activities.
C
Groundwater monitoring boreholes are monitored bi-annually. A
biannual report is compiled and this is then submitted to the
Department of Water and Sanitation (DWS).
Impumelelo Integrated Water Monitoring Report covering the
period of January 2020 to June 2020.
3.14 Monitoring site for soil sampling must be established to monitor any
chemical changes in the soil profile- such sampling sites must be
established downstream of the neighbouring farms.
N/A
This condition is only applicable to the construction phase, which has
been completed.
N/A
3.15 Monitoring of dust, baskets must be in placed in various strategic
positions around the site.
C
Dust fallout monitoring is undertaken on a regular basis and no
exceedances of the non-residential dust fallout limit have been noted.
In addition, the ROM stockpile is visually monitored on a daily basis
to detect wind dispersion of dust. Dust suppression will only be done
when needed.
Dust fallout monitoring results, 2020. Interview with the ECO.
Environmental Audit Report
External Environmental Audit of the Impumelelo Colliery
SAS6652
DIGBY WELLS ENVIRONMENTAL
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Condition Compliance
Rating Audit Comments Proof of Compliance
3.16 The monitoring of the fuel tanks must take place on a continuous
basis and should any product be encountered the oil company must be
informed immediately to undertake integrity tests and/or remedial action. C
The ECO indicated that fuel tanks are being monitored by visual
inspections. The fuel bay is built according to Sasol best practice.
Bund walls will contain more than 110%, the current legal
requirement.
Site observations, interview with ECO.
3.17 The holder of the authorization must submit an environmental
compliance audit report to the Department within 30 days of completion
of construction. The environmental Audit report must be compiled by an
independent auditor, and must indicate the date of the audit, the name
of the auditor and the outcome of the audit in terms of compliance with
the conditions of this authorization.
N/A
This condition is only applicable to the construction phase, which has
been completed.
N/A
3.18 The Department retains the right to monitor and/ or inspect the
proposed project during both construction and operational phases. N/A
This condition is noted. N/A
3.19 Fourteen (14) days written notice must be given to the Department
that the activity will commence. Commencement for the purposes of this
condition includes site preparation. The notice must include a date on
which it is anticipated that the activity will commence.
N/A
The DEDET was informed of the commencement of the authorised
activities for the Impumelelo Mine on 17/02/2019.
Letter to DEDET dated 17/02/2019.
3.20 In the event of any runnels or erosion channels developed during
the construction period, they must be backfilled and compacted, and the
areas restored to an acceptable condition.
N/A
Erosion was noticed at various areas on the mine (STP at the outlet
of the stormwater and at the reservoirs) due to the lack of vegetation.
Site observations.
3.21 The water quality monitoring must be conducted biannually, at least
once after the summer and once after the winter to avert any potential
danger to the livestock farming activities down slope of the activities. C
Monthly surface water quality monitoring and biannual groundwater
monitoring is undertaken. The results of the monitoring are compiled
in the bi-annual reports in January and July of each year and then
submitted to the DWS.
Surface water monitoring reports, 2020.
3.22 Groundwater monitoring program must be developed. This must
include the monitoring boreholes for effluent up-gradient and down-
gradient of the activities.
C
Sasol Mining conduct a monthly surface water quality monitoring and
biannual groundwater monitoring , this was done in August 2020 and
thus, submitted to the department.
Integrated Water Monitoring and Reporting Programme:
Brandspruit Colliery: Impumelelo Mine (License No:
08/C12D/ABCEFGIJ/2160): 30 September 2020.
Impumelelo Integrated Water Monitoring Report covering the
period January 2020 to June 2020.
Integrated water use license (08/C12D/ABCEFGIJ/2160) - Bi-
annual report: August 2020.
3.23 Monitoring site for soil sampling must be established to monitor any
chemical changes in soil profile. Such sampling sites must be
established downstream of the neighbouring farms.
C
Hydrocarbon monitoring and biomonitoring of watercourses around
the mine is undertaken to determine operational impacts.
Biomonitoring Assessment: Impumelelo Coal Conveyor and -
Adherence to and Applicability of Stipulations contained in the
Water Use Licence; (Licence No. 08/C12D/ABCEFGIJ/2160 and
10/C12D/C1/4899): Dry Season Survey 2019.
Biomonitoring Assessment: Impumelelo Coal Conveyor and
D714 road - Adherence to and Applicability of Stipulations
contained in the Water Use Licence: (Licence No.
08/C12D/ABCEFGIJ/2160 and 10/C12D/C1/4899) Wet Season
Survey 2019.
Environmental Audit Report
External Environmental Audit of the Impumelelo Colliery
SAS6652
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Condition Compliance
Rating Audit Comments Proof of Compliance
3.24 Dust and air quality monitoring programme must be set up to
assess ambient dust levels and the amount of dust generated by the
construction activities. C
Dust fallout monitoring is undertaken on a regular basis and no
exceedances of the non-residential dust fallout limit have been noted.
In addition, the ROM stockpile is visually monitored on a daily basis
to detect wind dispersion of dust. Dust suppression will only be done
when needed.
Dust fallout monitoring results, 2020. Interview with the ECO.
3.25 A noise monitoring programme must be set up to determine if noise
levels from certain equipment are not exceeding usual noise levels,
determine mitigation, management or servicing of the equipment if
required.
C
Noise monitoring results from 2019 showed that there were no
exceedances of the daytime or night-time acceptable noise ratings as
per SANS1013:2008 at the perimeter of the mine.
Impumelelo Colliery: Environmental / Perimeter Noise
Monitoring Assessment, 2019.
3.26 Monitoring of turbidity must occur upstream and not downstream of
the nearby streams during construction. N/A
This condition is only applicable to the construction phase, which has
been completed.
N/A
3.27 The Department retains the right to monitor and/ or inspect the
proposed project during both construction and operational phases. C
This condition is noted. N/A
3.28 Fourteen (14) days written notice must be given to the Department
that the activity will commence. Commencement for the purposes of this
condition includes site preparation. The notice must include a date on
which it is anticipated that the activity will commence.
C
The DEDET was informed of the commencement of the authorised
activities for the Impumelelo Mine on 17/02/2019.
Letter to DEDET dated 17/02/2019.
3.29 The measures taken to control runoff water must take into account
the gradient. The flow must be deducted towards mid-slope and be
spread out into the lower lying area in order to encourage natural
seepage of water into the soil thus protecting areas susceptible to
erosion.
C
Erosion control berms have been placed throughout the mine to
prevent erosion in large cleared areas. These areas have been
allowed to be vegetated through natural succession.
Site observations.
3.30 The applicant must assign the development with the conditions of
the Environmental Officers/scientists who will ensure among other: C
Currently the responsibility of implementing the EMP lies with the
Impumelelo Environmental Practitioner as the project is in its
Operational Phase.
N/A
3.30.a) Ensure strict compliance of the development of the development
with the conditions of the Environmental Authorization as well as the
measures contained in the Environmental Management Plan;
C
Audits and inspections are undertaken against the EA and EMP.
Digby Wells has been appointed to conduct the external EA and
EMP audits for 2020 to assess the level of compliance on site.
External EMP Performance Assessment Report, 2019 compiled
by Digby Wells Environmental.
3.30.b) Discuss and advise contractor on site about the environmental
matters before construction take place;
N/A
The Impumelelo Environmental Practitioner is responsible for
communicating environmental issues during weekly operations
meetings with contractors and Sasol Mining personnel. Inductions
were also undertaken before construction which covered
environmental matters.
Site observations.
3.30.c) Monitor compliance during construction and operation phases of
the activities; C
Audits and inspections are undertaken against the EA and EMP.
Digby Wells has been appointed to conduct the external EA and
EMP audits for 2020 to assess the level of compliance on site.
External EMP Performance Assessment Report, 2019 compiled
by Digby Wells Environmental.
3.30.d) Keep records of all the environmental audits; C
Records of all the environmental audits previously undertaken are
kept safe and were available during the site visit.
External EMP Performance Assessment Report, 2019 compiled
by Digby Wells Environmental.
Environmental Audit Report
External Environmental Audit of the Impumelelo Colliery
SAS6652
DIGBY WELLS ENVIRONMENTAL
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Condition Compliance
Rating Audit Comments Proof of Compliance
3.30.e) Ensure that contingency plans are developed and implemented
in the event of the occurrence of unforeseen circumstances. C
An Emergency and Preparedness Plan is in place at the Impumelelo
Colliery.
Emergency Response Plan for the Impumelelo Colliery.
3.31 All domestic waste generate on site during construction must be
stored in containers and later be disposed of at a registered landfill site N/A
This condition is only applicable to the construction phase, which has
been completed.
N/A
3.32 All heavy vehicles operators and truck drivers must be restricted to
designated areas, such as construction sites and roads. C
Mine vehicles are using dedicated roads that were constructed
around the mine.
Site observations.
3.33 Soil stockpiles must be managed in the manner that they do not
cause any environmental harm. C
Topsoil stockpiles were vegetated through natural succession.
Topsoil stockpiles are demarcated with limited access to prevent
vehicles driving over.
Site observations.
3.34 The coal stockpile areas must be lined and connect to effective
drainage systems that will channel effluent from the stockpile area into
silt traps and pollution control dams.
C
The coal stockpile areas are lined and water drains to the PCD. Site observations.
3.35 Accidental spillages must have sawdust applied immediately. The
affected soil must be dug out and removed and disposed of with
hydrocarbon waste by a reputable company.
NC
At the time of the audit, various minor oil spills were noticed on the
paved area, as well as on soil where vehicles are parked. It was also
noticed that refuelling is done to the point of overflow, as evident
from hydrocarbon spills at the refuelling area and at the decline shaft.
After a repeat of various incidents, a Management Site Inspection
was held in August 2019. This was used to highlight the issues and
appoint responsible people to address these concerns. However, it
was found that these issues have not yet successfully been
addressed.
Site observations.
3.36 Fuels, lubricants and hydrocarbons must be stored in bunded
facilities. C
All fuels, lubricants and hydrocarbon are stored within a bunded area
which complies with the necessary SANS standards.
Site observations.
3.37 The road surfaces, in particular those used by heavy vehicles must
be treated with dust binding agent. The form of the dust-binding agent
will determine the type of watering to be used. C
Dust fallout monitoring is undertaken by Sasol Mining (Pty) Ltd and
the results indicate that there have been no exceedances of the non-
residential dust fallout limit. Dust suppression can be undertaken
when necessary.
Dust fallout monitoring results, 2020. Interview with the ECO.
3.38 Regularly spaced low level speed humps must be constructed
across the width of the service road at the approach and departure
slopes to valley bottom wetlands to intercept surface runoff and to
deflect it to the surrounding grasslands
NC
No low level speed humps were constructed on site; however, the
vehicles are driven at a very low speed within the mine area.
Site observations.
3.39 Construction of the conveyor gantries across streams must be
planned to occur during dry seasons. N/A
This condition is only applicable to the construction phase, which has
been completed.
N/A
3.40 Erosion control measures such as contour banks and down drains
must be constructed and vegetated in rehabilitated areas NC
The erosion control measures are not implemented along the
conveyor crossing, this issue was raised in the previous year (2019)
during the site inspection by Digby Wells.
Site observations.
3.41 Erosion control berms must be placed reversely, at regular
intervals, across the terrestrial section of the conveyor servitude after
vegetation and topsoil stripping.
C
Erosion control berms were put in place to prevent the blockage of
water by the sediments and erosion.
Site observations.
Environmental Audit Report
External Environmental Audit of the Impumelelo Colliery
SAS6652
DIGBY WELLS ENVIRONMENTAL
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Condition Compliance
Rating Audit Comments Proof of Compliance
3.42 Gantries must be constructed over wetland area to contain coal
spillage. Such construction works must target the dry season to alleviate
negative impacts on the wetlands.
N/A
This condition is only applicable to the construction phase, which has
been completed.
N/A
3.43 The relevant water use license must be obtained from the
Department of water affairs. C
The Water Use Licence is in place. An amendment application for the
licence has been submitted but has not been issued to date.
WUL for Impumelelo Colliery (Licence no:
16/2/7/C121/ABCEFGIJ/2160).
3.44 The storage and handling of coal must comply with the precepts of
the NEM: AQA (Act 39 of 2004). N/A
There is no permanent storage of coal on site. Site observations.
3.45 No power line pylons must be located in wetlands. N/A No inspection was done along the powerline pylons. N/A
3.46 All road crossings over streams or wetlands must not impede the
flow of the water. C
Due to the nature of the culverts, it impedes the flow of the water.
The necessary WUL has been issued.
WUL for Impumelelo Colliery (Licence no:
16/2/7/C121/ABCEFGIJ/2160).
3.47 No surface runoff from the construction sites must enter the stream
area. N/A
This condition is only applicable to the construction phase, which has
been completed.
N/A
3.48 The PCDs must be lined to prevent any potential of grounds water
pollution. The lining must comply strictly with the requirements as set out
by the Department of Water Affairs.
C
The PCDs are lined with an HDPE liner to prevent infiltration of water
into the soil and groundwater. The seepage water downstream from
PCD shows no contamination and therefore the assumption is made
that the liner is still intact. An anomaly was noticed during the
evaluation of the biannual reports of 2019. A surface water dam
downstream of the PCD is showing signs of contamination. The
surface water dam is now being monitored.
Site observations.
3.49 The design and capacity of the evaporation ponds must take into
account the impact of the additional inflow due to runoff during rainy
season. These ponds must be constructed to sufficient capacity to
minimize overflowing during rainy seasons as this might result in serious
pollution potential to surface water.
C
The Pollution Control Dams (evaporation dams) are designed to
cater for 1:50 year flood event. Furthermore, Sasol Mining aims to
maintain the dams at a maximum of 30% of their full capacity which
further reduces risk of overflowing.
Site observation
3.50 The evaporation dam must be often de-sludge. The silt and sludge
from the dam must be disposed of in an environmentally friendly manner
considering their pollution potential. C
The silt trap just before the PCDs are maintained and are weekly
monitored. Once it is noticed that there is a silt build-up, the
necessary arrangements are made to desilt the silt trap and the
material is removed to an appropriate licenced facility.
SCS Job Card inspection of the silt traps and trenches, dated 19
October 2019.
3.51 The silt and sludge must be removed off the site and be disposed
of at the appropriate facility. The silt traps must be cleaned regularly. C
The silt trap just before the PCDs are maintained and are weekly
monitored. Once it is noticed that there is a silt build-up, the
necessary arrangements are made to desilt the silt trap and the
material is removed to an appropriate licenced facility.
SCS Job Card inspection of the silt traps and trenches, dated 19
October 2019.
3.52 Chemical toilets or any other approved sanitary facilities must be
made available to workers during construction. The toilets must have
lockable doors to prevent them from blowing over.
N/A
This condition is only applicable to the construction phase, which has
been completed.
Site observation
3.53 A comprehensive Storm Water Management Plan which outlines
the storm water drainage lines and discharge thereof must be compiled
in accordance with the requirements of the Department of Water Affairs.
C
Stormwater management measures have been implemented on site
in the form of trenches and berms throughout the area. Clean water
is diverted away from the dirty water areas and is discharged to the
IWWMP 2019 – 2020 and a schematic diagram.
Environmental Audit Report
External Environmental Audit of the Impumelelo Colliery
SAS6652
DIGBY WELLS ENVIRONMENTAL
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Condition Compliance
Rating Audit Comments Proof of Compliance
clean water system. Dirty water is diverted to the PCDs from where it
is re-used underground.
3.54 Any complaints received from the public during the construction
and operational phases of the activity must be attended to as soon as
possible and addressed to the satisfaction of all concerned. C
A complaint register is in place. Complaints received from the public
will be manged by the Sasol Mining Rights Department (SMRD). Any
complaints raised are discussed during a monthly meeting with the
mine.
N/A
3.55 General waste that is generated during all phases of the activity
must be disposed of at a permitted disposal facility. C
All general waste generated on the mine is collected by Interwaste
Environmental Solutions and disposed of to a permitted landfill site.
Certificates of Safe Disposal (Interwaste Environmental
Solution);
3.56 Hazardous waste must be segregated and stored in appropriate
containers and be disposed of at a permitted waste disposal site by the
registered company/contractor. C
A SOP for waste management is available. The separation of waste
is implemented throughout the mine. Hazardous waste is segregated
and stored in appropriate containers and is later collected by
Interwaste and is disposed of at a permitted waste disposal site.
Site observations, SOP for waste management.
3.57 Hazardous waste must be disposed of at a licensed facility (class
H:H disposal site) by a registered waste management company. C
A SOP for waste management is available. The separation of waste
is implemented throughout the mine. Hazardous waste is segregated
and stored in appropriate containers and is later collected by
Interwaste and is disposed of at a permitted waste disposal site.
Site observations, SOP for waste management.
3.58 Waste chemicals, solvents and paints must be collected into
approved containers for storage and disposal. C
A SOP for waste management is available. The separation of waste
is implemented throughout the mine. Hazardous waste is segregated
and stored in appropriate containers and is later collected by
Interwaste and is disposed of at a permitted waste disposal site.
Site observations, SOP for waste management.
3.59 Records of the mass hazardous waste produced and disposed
must be kept, as well as disposal certificates.
C
The records of mass hazardous waste produced and disposed of to
the appropriate landfill site is monitored on a monthly basis. The
volumes EW made available by Interwaste who is responsible for the
removal of the waste. This data is then provided to Sasol Mining who
in turn populates the SD data and send it to the Sasol Head Office.
Interwaste Environmental Solutions, 22 October 2020
3.60 Records of all safe disposal certificates from a class H:H disposal
site must be kept by the applicant. C
The safe disposal certificates were made available at the time of the
audit.
Interwaste Environmental Solutions, 22 October 2021
3.61 All equipment must be subjected to a noise specification that will
reduce the overall noise in the plant. Where noise levels cannot be
reduced to the acceptable levels (85 dB-ambient) the staff must wear
ear protection equipment.
C
Noise monitoring results from 2019 showed that there were no
exceedances of the daytime or night-time acceptable noise ratings as
per SANS1013:2008 at the perimeter of the mine.
Impumelelo Colliery: Environmental / Perimeter Noise
Monitoring Assessment, 2019.
3.62 The facilities must be operated in accordance with the relevant
provision of Occupational Health and Safety Act (Act No 85 of 1993). N/A
The mine must comply against the requirements of the Mine Health
and Safety Act, 1996.
N/A
3.63 No activity such as construction camps, temporary housing,
temporary ablution, stockpiling of topsoil, storing of equipment and
disturbance of natural habitat, temporary access or haul roads or any
other use, may take place within any watercourse.
N/A
This condition is only applicable to the construction phase, which has
been completed.
N/A
3.64 The graveyards must be conserved in situ by means of a brick wall
or a fence. A buffer zone of at least 20 m must be maintained between
the graveyards and the conveyor.
C
The auditors were provided with GIS information to indicate the
location of graves, as identified by the heritage specialist study
conducted during the EIA process. Furthermore, the Survey
Interview with the Survey Manager.
Environmental Audit Report
External Environmental Audit of the Impumelelo Colliery
SAS6652
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Condition Compliance
Rating Audit Comments Proof of Compliance
Department completed a Section 17 Plan in terms of the Mineral and
Petroleum Resources Development Act, 2002 (Act No. 28 of 2002)
(MPRDA) to indicate all sensitive areas on surface, including the
locations of buildings and graves. It was confirmed that no graves
were damaged during the construction of the mine and no graves
were relocated during the construction of the mine site.
3.65 Construction personnel must be sensitized to the requirements of
the South African Heritage Resources Act (SAHRA). Should any
material of cultural or archaeological significance be encountered during
construction, all activities must be cease immediately and the South
African Heritage Resources Agency must be informed accordingly.
N/A
This condition is only applicable to the construction phase, which has
been completed.
N/A
3.66 Should the use of the facilities ever cease or become redundant,
the applicant must undertake the required actions as prescribed by
legislation at the time and comply with all relevant legal requirements
administered by any relevant and competent authority at that time.
N/A
This condition is noted. N/A
3.67 A rehabilitation plan must be submitted to this Department for
approval at least 6 months prior to the decommissioning phase. N/A
This condition is noted. N/A
3.68 Potential geo-hydrological impacts during post closure,
decommissioning and closure phase must be assessed during the
ground water monitoring and modelling by a qualified and accredited
independent geo-hydrologists.
C
Groundwater monitoring boreholes are monitored bi-annually. A
biannual report is compiled and this is then submitted to the
Department of Water and Sanitation (DWS). Groundwater monitoring reports.
3.70 A copy of this authorization must be kept at the property where the
activities will be undertaken. The authorization must be produced to any
authorized official of the Department who request to see it and must be
available for inspection by any employee or agent of the holder of the
authorization who works or undertakes work at the property.
C
A copy of the EA and the EMP was made available at the time of the
audit.
DEDET Environmental Authorisation approval dated 15
September 2010;
DEDET Environmental approval of amendments dated 12
December 2011;
DEDET Environmental Management Programme amendment
dated 06 July 2010;
3.71 Where any of the applicant's contact details change, including the
name of the responsible person, the physical or postal address and/or
telephonic details; the applicant must notify the Department as soon as
the new details become known to the applicant.
N/A
This condition is noted. N/A
3.72 The holder of the authorization must notify the Department, in
writing and within 24 (twenty-four) hours, if conditions of this
authorization are not adhered to. Any notification in terms of this
condition must be accompanied by reasons for the non-comply
N/A
This condition is noted. N/A
3.73 Non-compliance with a condition of this authorization may result in
criminal prosecution or other actions provided for in the National
Environmental Management Act, 1998 and the regulations.
N/A
This condition is noted. N/A
3.74 National government, provincial government, local authorities or
committees appointed in terms of the conditions of this authorization or
any other public authority shall not be held responsible for any damages
N/A
This condition is noted. N/A
Environmental Audit Report
External Environmental Audit of the Impumelelo Colliery
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DIGBY WELLS ENVIRONMENTAL
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Condition Compliance
Rating Audit Comments Proof of Compliance
or losses suffered by the applicant or his successor in title in any
instance where construction of operation subsequent to construction be
temporarily or permanently stopped for reasons of non-compliance by
the applicant with the conditions of authorization as set out in this
document or any other subsequent document emanating from these
conditions of authorization.
6. You are instructed in terms of regulation 10(2) of the Regulation to
notify all registered interested and affected parties in writing and within
12 days of the date of this letter, of the Departments decision to amend
this Environmental Authorization as well as the provisions regarding the
making of appeals that are provided for in the regulations
N/A
This condition is noted. N/A
Table 9-2: Assessment of Compliance to the Operational Requirements of the EMPr
Activity Environmental
aspect Potential Impact Condition
Compliance
Rating Audit Comments
Transport of
coal
Noise Generation of noise 7.2.5.2.11 (c Maintain the conveyor belt regularly to
ensure that it is optimally functional. C
Weekly maintenance is undertaken by SCS according to a job card system.
Transport of
coal
Air quality Dust generation 7.2.5.2.10 (a Ensure that the conveyor belt is covered for
its full length.
C
The representatives from SCS indicated that it is not practical to fully
enclose the conveyor due to potential fire hazards and the impact on
prohibiting the cleaning of the conveyors. However, partial covering of the
conveyers were implemented. The conveyer is fully covered at the
Kaalspruit and the Waterval River crossings.
Transport of
coal
Noise Generation of noise 7.2.5.2.11 (b Ensure that the conveyor belt is covered for
its full length.
C
The representatives from SCS indicated that it is not practical to fully
enclose the conveyor due to potential fire hazards and the impact on
prohibiting the cleaning of the conveyors. However, partial covering of the
conveyers were implemented. The conveyer is fully covered at the
Kaalspruit and the Waterval River crossings.
Transport of
coal
Visual aspects Visual impact of dust 7.2.5.2.14 (c Ensure that the conveyor belt is covered for
its full length.
C
The representatives from SCS indicated that it is not practical to fully
enclose the conveyor due to potential fire hazards and the impact on
prohibiting the cleaning of the conveyors. However, partial covering of the
conveyers were implemented. The conveyer is fully covered at the
Kaalspruit and the Waterval River crossings.
Transport of
coal
I&APs Nuisance dust and noise 7.2.5.2.16 (c Ensure the conveyor is covered for its full
length to minimize dust generation.
C
The representatives from SCS indicated that it is not practical to fully
enclose the conveyor due to potential fire hazards and the impact on
prohibiting the cleaning of the conveyors. However, partial covering of the
conveyers were implemented. The conveyer is fully covered at the
Kaalspruit and the Waterval River crossings.
Transport of
coal
I&APs Nuisance dust and noise 7.2.5.2.16 (e Ensure that the conveyor belt is covered for
its full length. C
The representatives from SCS indicated that it is not practical to fully
enclose the conveyor due to potential fire hazards and the impact on
prohibiting the cleaning of the conveyors. However, partial covering of the
Environmental Audit Report
External Environmental Audit of the Impumelelo Colliery
SAS6652
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Activity Environmental
aspect Potential Impact Condition
Compliance
Rating Audit Comments
conveyers were implemented. The conveyer is fully covered at the
Kaalspruit and the Waterval River crossings.
Underground
mining of coal
Socio- economic
structure
Retaining of current
Brandspruit Staff
7.2.3.2.15 (a Employees can be further uplifted by being
provided with opportunities to take part in courses to
further their existing career at the proposed mine.
C
Impumelelo has a dedicated Training Department that manages and
provides various training courses to employees. The auditors met with the
Training Manager to discuss the types of courses provided.
Construction of
infrastructure
I&APs Increase in crime 7.2.2.2.16 (a Security measures should be implemented at
the surface land use area. C
The shaft area and mining area is fenced off and this is patrolled by Security
throughout the day.
Construction of
infrastructure
I&APs Increase in crime 7.2.2.2.16 (b Restrict access to the surface land use area
to authorized and on- duty personnel. C
The shaft area and mining area is fenced off and this is patrolled by Security
throughout the day.
Mining related
activities
Animal life Loss of life 7.2.4.2.7 (l Restrict access to the surface land use area to
authorized and on- duty personnel. C
The shaft area and mining area is fenced off and this is patrolled by Security
throughout the day.
Mining related
activities
Surface water Decrease in surface water
quality
7.2.4.2.8 (d Ensure that the dam wall has grass cover to
minimize erosion. C
The PCDs do not have dam walls, but the areas around the dams have
been grassed to minimise erosion.
Underground
mining of coal
Ground water Decrease in groundwater
quality
7.2.3.2.9 (e The pollution control dam should be lined so
as to limit seepage. C
The PCDs are lined with HDPE.
Construction of
infrastructure
Visual aspects Visual impact of
infrastructure
7.2.2.2.14 (a Construct the conveyor belt close to the
ground (not elevated) wherever possible. C
The overland conveyor belt is constructed close to the ground.
Mining related
activities
Surface water Increase in catchment yield 7.2.4.2.8 (j Ensure that all the relevant permissions are
obtained for the release of water into the catchment. C
The necessary WUL is in place which authorise the discharge of treated
sewage effluent.
Underground
mining of coal
I&APs Irritation of I&AP’s by dust
and noise
7.2.3.2.16 (h Conduct noisy activities during day time.
C
Noise is generated from the ventilation shaft, incline shaft, bunker area, as
well as the conveyor belt, which are all operational 24 hours a day.
Noise monitoring results from 2019 showed that there were no exceedances
of the daytime or night-time acceptable noise ratings as per
SANS1013:2008 at the perimeter of the mine.
Mining related
activities
Noise Noise generation 7.2.4.2.11 (a Conduct noisy activities during daytime.
C
Noise is generated from the ventilation shaft, incline shaft, bunker area, as
well as the conveyor belt, which are all operational 24 hours a day.
Noise monitoring results from 2019 showed that there were no exceedances
of the daytime or night-time acceptable noise ratings as per
SANS1013:2008 at the perimeter of the mine.
Mining related
activities
I&APs Nuisance dust and noise 7.2.4.2.16 (d Conduct noisy activities during the day time.
C
Noise is generated from the ventilation shaft, incline shaft, bunker area, as
well as the conveyor belt, which are all operational 24 hours a day.
Noise monitoring results from 2019 showed that there were no exceedances
of the daytime or night-time acceptable noise ratings as per
SANS1013:2008 at the perimeter of the mine.
Underground
mining of coal
Noise generation of noise 7.2.3.2.11 (d Conduct noisy activities during the day time.
C
Noise is generated from the ventilation shaft, incline shaft, bunker area, as
well as the conveyor belt, which are all operational 24 hours a day.
Noise monitoring results from 2019 showed that there were no exceedances
of the daytime or night-time acceptable noise ratings as per
SANS1013:2008 at the perimeter of the mine.
Environmental Audit Report
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Activity Environmental
aspect Potential Impact Condition
Compliance
Rating Audit Comments
Construction of
infrastructure
Visual aspects Visual impact of
infrastructure
7.2.2.2.14 (c Construct shafts and other tall infrastructure
with materials that blend into surroundings. C
The materials used to construct infrastructure was observed to blend in with
the environment as much as possible.
Transport of
coal
Animal life Frightening of fauna 7.2.5.2.7 (a Any fencing should allow an opportunity for
smaller animals to pass through the fence to escape the
conveyor servitude, but prevent re- entry.
C
The fencing along the conveyor servitude will allow smaller animals to pass
through the fence.
Transport of
coal
Animal life Loss of life 7.2.5.2.7 (b Any fencing should allow an opportunity for
smaller animals to pass through the fence to escape the
construction activates, but prevent re-entry.
C
The fencing along the conveyor servitude will allow smaller animals to pass
through the fence.
Clearing of land Vegetation Establishment of invader
species
7.2.2.1.17.6 (a Check all revegetated and surrounding
areas for any invader plant species on a regular basis. C
The ECO indicated that Impumelelo has appointed Libra Landscaping to
undertake an alien invasive plant assessment. An alien invasive plant
eradication plan is being implemented on site.
Clearing of land Vegetation Establishment of invader
species
7.2.2.1.17.6 (b Remove any invader plant species.
C
The ECO indicated that Impumelelo has appointed Libra Landscaping to
undertake an alien invasive plant assessment. An alien invasive plant
eradication plan is being implemented on site.
Clearing of land Soil Soil erosion 7.2.2.1.17.3 (b Ensure that the gradient of stockpiles is 1:3
or less (shallower) so as to allow for the establishment of
vegetation on all stockpiles.
C
The ECO did confirm that the slopes of the overburden stockpile were less
than 1:3. The topsoil stockpiles were also found to be naturally vegetated.
Underground
mining of coal
Soil Degradation of soil quality 7.2.3.2.3 (a The dirty water management area should be
kept as small as possible. C
All clean water is diverted around the mine in clean water drains. Water from
roofs and clean areas is discharged through clean water drains to the
watercourse. Dirty water areas drain towards a 7 ML PCD.
Underground
mining of coal
Land capability Degradation of land
capability
7.2.3.2.4 (a The dirty water management area should be
kept as small as possible. C
All clean water is diverted around the mine in clean water drains. Water from
roofs and clean areas is discharged through clean water drains to the
watercourse. Dirty water areas drain towards a 7 ML PCD.
Underground
mining of coal
Surface water Decrease in surface water
quality
7.2.3.2.8 (a The dirty water management area should be
kept as small as possible. C
All clean water is diverted around the mine in clean water drains. Water from
roofs and clean areas is discharged through clean water drains to the
watercourse. Dirty water areas drain towards a 7 ML PCD.
Underground
mining of coal
Surface water Decrease in surface water
quality
7.2.3.2.8 (b No dirty water should be allowed to leave the
dirty water management area (except during an
exceptional flood event, as per the National Water Act, Act
36 of 1998, and only under license conditions).
C
All clean water is diverted around the mine in clean water drains. Water from
roofs and clean areas is discharged through clean water drains to the
watercourse. Dirty water areas drain towards a 7 ML PCD.
Underground
mining of coal
Ground water Decrease in groundwater
quality
7.2.3.2.9 (b The dirty water management area should be
kept as small as possible. C
All clean water is diverted around the mine in clean water drains. Water from
roofs and clean areas is discharged through clean water drains to the
watercourse. Dirty water areas drain towards a 7 ML PCD.
Construction of
infrastructure
Vegetation Development of gardens 7.2.2.2.6 (b Plant only indigenous plants.
C
The Auditors were informed that only indigenous plants were planted in the
gardens. This was confirmed with an email from the Project Engineer, which
shows that the landscaping contractors were tasked to plant only indigenous
species.
Mining related
activities
Vegetation Establishment of invader
species
7.2.4.2.6 (b Ensure that only indigenous plants are planted
in garden areas. C
The Auditors were informed that only indigenous plants were planted in the
gardens. This was confirmed with an email from the Project Engineer, which
Environmental Audit Report
External Environmental Audit of the Impumelelo Colliery
SAS6652
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Activity Environmental
aspect Potential Impact Condition
Compliance
Rating Audit Comments
shows that the landscaping contractors were tasked to plant only indigenous
species.
Underground
mining of coal
Visual aspects Visual impact of ROM
stockpile
7.2.3.2.14 (a Ensure the height of the rock stockpile does
not interrupt the line of the horizon. C
Stockpile areas are in line with horizon and were not found to be a
significant visual obstruction.
Underground
mining of coal
Noise generation of noise 7.2.3.2.11 (f Provide protective gear for workers exposed
to high noise levels. C
Signs were displayed at areas where personal noise protection is required.
All personnel are issued with the necessary PPE.
Mining related
activities
Noise Noise generation 7.2.4.2.11 (b Provide workers with protective gear to
mitigate the impact of noise. C
Signs were displayed at areas where personal noise protection is required.
All personnel are issued with the necessary PPE.
Mining related
activities
Soil Enrichment of soils in
garden areas
7.2.4.2.3 (g Fertilize gardens when necessary. C
Service providers are appointed to do landscaping and to maintain gardens.
The fertilising of the gardens would take place as and when required.
Construction of
infrastructure
Vegetation Development of gardens 7.2.2.2.6 (d Maintain gardens regularly. C
Service providers are appointed to do landscaping and to maintain gardens.
The fertilising of the gardens would take place as and when required.
Mining related
activities
Soil Enrichment of soils in
garden areas
7.2.4.2.3 (h Maintain gardens appropriately. C
Service providers are appointed to do landscaping and to maintain gardens.
The fertilising of the gardens would take place as and when required.
Underground
mining of coal
Socio- economic
structure
Creation of additional jobs 7.2.3.2.15 (c The employment process should be fair and
transparent. C
Employment is undertaken in line with the Social Labour Plan (SLP) and
strict procedures apply to the recruitment and employment process.
Transport of
coal
Socio- economic
structure
upliftment of individuals /
organizations
7.2.5.2.15 (b Encourage BEE participation in the tender
process.
C
Procurement is undertaken in line with the SLP and strict procurement
procedures.
BEE is further promoted through the employee share scheme and that they
measure BEE in terms of opportunities within Impumelelo. They also
monitor and report on diversity stats (which includes AIC – African, Coloured
and Indian [target of 30%] and women in mining). Reporting is done to the
line managers who report to the GM monthly.
Transport of
coal
Socio- economic
structure
upliftment of individuals /
organizations
7.2.5.2.15 (c Ensure that the tender process is fair and
well documented.
C
Procurement is undertaken in line with the SLP and strict procurement
procedures.
BEE is further promoted through the employee share scheme and that they
measure BEE in terms of opportunities within Impumelelo. They also
monitor and report on diversity stats (which includes AIC – African, Coloured
and Indian [target of 30%] and women in mining). Reporting is done to the
line managers who report to the GM monthly.
Mining related
activities
Ground water increase in groundwater
quantity
7.2.4.2.9 (e Pipelines should be regularly monitored for
leaks, and leaks patched so as to prevent spillage of
water.
C
Pipelines are monitored and inspected on a weekly basis to prevent leaks.
The water pipelines are also located within the servitude that runs from
Impumelelo to Brandspruit to allow for ease of access in the event of failure.
Mining related
activities
Surface water Decrease in surface water
quality
7.2.4.2.8 (g Pipelines should be regularly monitored for
leaks, and leaks patched so as to prevent spillage of
water.
C
Pipelines are monitored and inspected on a weekly basis to prevent leaks.
The water pipelines are also located within the servitude that runs from
Impumelelo to Brandspruit to allow for ease of access in the event of failure.
Underground
mining of coal
Sites of
archaeological and
cultural interest
Degradation of sites of
archaeological and cultural
7.2.3.2.12 (a Avoid undermining of archaeological sites
with high extraction mining. C
Maps are available to indicate where heritage sites exist and a permitting
process is in place before high extraction mining can occur in an area.
Environmental Audit Report
External Environmental Audit of the Impumelelo Colliery
SAS6652
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Activity Environmental
aspect Potential Impact Condition
Compliance
Rating Audit Comments
interest result of subsidence
and / or fracturing
Mining related
activities
Socio- economic
structure
Community projects 7.2.4.2.15 (a Monitor community projects to ensure that
they are effective. C
People, Organisation and Effectiveness (POE) Corporate Affairs
Department has quarterly and monthly meetings with the community. The
mine is not responsible for the implementation of community projects.
Mining related
activities
Socio- economic
structure
Community projects 7.2.4.2.15 (b Modify community projects if necessary to
increase effectiveness. C
People, Organisation and Effectiveness (POE) Corporate Affairs
Department has quarterly and monthly meetings with the community. The
mine is not responsible for the implementation of community projects.
Mining related
activities
Socio- economic
structure
Community projects 7.2.4.2.15 (c Give preference to local contractors.
C
People, Organisation and Effectiveness (POE) Corporate Affairs
Department has quarterly and monthly meetings with the community. The
mine is not responsible for the implementation of community projects.
Underground
mining of coal
Socio- economic
structure
Retaining of current
Brandspruit Staff
7.2.3.2.15 (b Sasol Mining can carry out community
projects in order to aid the upliftment of the surrounding
community.
C
People, Organisation and Effectiveness (POE) Corporate Affairs
Department has quarterly and monthly meetings with the community. The
mine is not responsible for the implementation of community projects.
Underground
mining of coal
Socio- economic
structure
Creation of additional jobs 7.2.3.2.15 (d Employees for any additional jobs created
should be sourced from the local area (Lekwa, Dipaliseng
and Govern Mbeki Local Municipalities).
C
People, Organisation and Effectiveness (POE) Corporate Affairs
Department has quarterly and monthly meetings with the community. The
mine is not responsible for the implementation of community projects.
Underground
mining of coal
Socio- economic
structure
Creation of additional jobs 7.2.3.2.15 (e Should any additional contract work become
available, preference should be given to local contractors. C
People, Organisation and Effectiveness (POE) Corporate Affairs
Department has quarterly and monthly meetings with the community. The
mine is not responsible for the implementation of community projects.
Underground
mining of coal
Socio- economic
structure
Community projects 7.2.3.2.15 (f Monitor community projects to ensure that
they are effective. C
People, Organisation and Effectiveness (POE) Corporate Affairs
Department has quarterly and monthly meetings with the community. The
mine is not responsible for the implementation of community projects.
Underground
mining of coal
Socio- economic
structure
Community projects 7.2.3.2.15 (g Modify community projects if necessary to
increase effectiveness. C
People, Organisation and Effectiveness (POE) Corporate Affairs
Department has quarterly and monthly meetings with the community. The
mine is not responsible for the implementation of community projects.
Transport of
coal
Ground water Decrease in groundwater
quality
7.2.5.2.9 (e The conveyor belt should be covered so as to
limit the chances of spillage. C
Partial covering of the conveyers were implemented, as it is impractical to
clean the conveyor if fully covered. The conveyer is fully covered at the
Kaalspruit and the Waterval River crossings.
Transport of
coal
Surface water Decrease in surface water
quality
7.2.5.2.8 (e The conveyor belt should be covered so as to
limit the chances of spillage. C
Partial covering of the conveyers were implemented, as it is impractical to
clean the conveyor if fully covered. The conveyer is fully covered at the
Kaalspruit and the Waterval River crossings.
Clearing of land Vegetation Establishment of invader
species
7.2.2.1.17.6 (c Ensure stockpiles are vegetated with flora
indigenous to the study area. C
Overburden and topsoil stockpiles were vegetated through natural
succession. No stockpiles were seeded during the time of the audit.
Mining related
activities
Soil Loss of soil structure and
function
7.2.4.2.3 (e Ensure stockpiles and berms remain
vegetated to prevent erosion. C
Overburden and topsoil stockpiles were vegetated through natural
succession. No stockpiles were seeded during the time of the audit.
Mining related
activities
Vegetation Establishment of invader
species
7.2.4.2.6 (c Ensure stockpiles are vegetated with flora
indigenous to the area. C
Overburden and topsoil stockpiles were vegetated through natural
succession. No stockpiles were seeded during the time of the audit.
Environmental Audit Report
External Environmental Audit of the Impumelelo Colliery
SAS6652
DIGBY WELLS ENVIRONMENTAL
www.digbywells.com 34
Activity Environmental
aspect Potential Impact Condition
Compliance
Rating Audit Comments
Clearing of land Soil Soil erosion 7.2.2.1.17.3 (a Ensure stockpiles are vegetated. C
Overburden and topsoil stockpiles were vegetated through natural
succession.
Clearing of land Visual aspects Visual impact of dust 7.2.2.1.17.14 (c Ensure stockpiles are vegetated to
minimize dust generation. C
Overburden and topsoil stockpiles were vegetated through natural
succession.
Clearing of land I&APs Irritation caused by dust
generation
7.2.2.1.17.16 (c Ensure stockpiles are vegetated to
minimize dust generation. C
Overburden and topsoil stockpiles were vegetated through natural
succession.
Mining related
activities
Visual aspects visual impact of dust 7.2.4.2.14 (c Ensure stockpiles are vegetated to minimize
dust generation. C
Overburden and topsoil stockpiles were vegetated through natural
succession.
Mining related
activities
I&APs Nuisance dust and noise 7.2.4.2.16 (c Ensure stockpiles are vegetated to minimize
dust generation. C
Overburden and topsoil stockpiles were vegetated through natural
succession.
Underground
mining of coal
Geology Geological strata will be
altered by subsidence
7.2.3.2.1 (c Plough and rip fractures at the surface. N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Underground
mining of coal
Topography Hollows will be created
(subsidence)
7.2.3.2.2 (c Plough and rip fractures on the surface. N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Underground
mining of coal
Soil Degradation of soils caused
by subsidence and / or
fracturing
7.2.3.2.3 (k Fertilize and vegetate damaged subsided
areas to restore its pre- mining status if required. N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Underground
mining of coal
Land use Degradation of land use as a
result of subsidence and / or
fracturing
7.2.3.2.5 (b Plough and rip fractures at the surface.
N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Underground
mining of coal
Vegetation Degradation of vegetation as
a result of subsidence and /
or fracturing
7.2.3.2.6 (e Plough and rip fractures at the surface.
N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Underground
mining of coal
Vegetation Degradation of vegetation as
a result of subsidence and /
or fracturing
7.2.3.2.6 (g Fertilize and vegetate damaged subsided
areas to restore its pre- mining status if required. N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Underground
mining of coal
Animal life Impact on animals as a
result of subsidence and / or
fracturing
7.2.3.2.7 (e Plough and rip fractures at the surface.
N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Underground
mining of coal
Surface water Degradation of surface water
as a result of subsidence
and / or fracturing
7.2.3.2.8 (d Plough and rip fractures at the surface.
N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Underground
mining of coal
Ground water Alteration of groundwater
flow paths as a result of
subsidence and / or
fracturing
7.2.3.2.9 (i Plough and rip fractures at the surface.
N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Environmental Audit Report
External Environmental Audit of the Impumelelo Colliery
SAS6652
DIGBY WELLS ENVIRONMENTAL
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Activity Environmental
aspect Potential Impact Condition
Compliance
Rating Audit Comments
Underground
mining of coal
Sites of
archaeological and
cultural interest
Degradation of sites of
archaeological and cultural
interest result of subsidence
and / or fracturing
7.2.3.2.12 (b Plough and rip fractures at the surface.
N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Underground
mining of coal
Sensitive
landscapes
Degradation of sensitive
landscapes as a result of
subsidence and / or
fracturing
7.2.3.2.13 (b Plough and rip fractures at the surface.
N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Underground
mining of coal
I&APs Degradation of land as a
result of subsidence and / or
fracturing
7.2.3.2.16 (k Plough and rip fractures at the surface.
N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Underground
mining of coal
Topography Hollows will be created
(subsidence)
7.2.3.2.2 (e Fertilize and vegetate damaged subsided
areas to restore its pre- mining status if required. N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Underground
mining of coal
Soil Degradation of soils caused
by subsidence and / or
fracturing
7.2.3.2.3 (i Plough and rip fractures at the surface.
N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Underground
mining of coal
Land capability Degradation of land
capability
7.2.3.2.4 (d Limit the extent of surface disturbances. C
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Underground
mining of coal
Land capability Degradation of land
capability as a result of
subsidence and / or
fracturing
7.2.3.2.4 (e Plough and rip fractures at the surface.
N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Underground
mining of coal
Land capability Degradation of land
capability as a result of
subsidence and / or
fracturing
7.2.3.2.4 (f Use cut and fill techniques to ensure that
subsided areas are free draining. N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Underground
mining of coal
Land capability Degradation of land
capability as a result of
subsidence and / or
fracturing
7.2.3.2.4 (g Fertilize and vegetate damaged subsided
areas to restore its pre- mining status if required. N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Underground
mining of coal
Land use Degradation of land use as a
result of subsidence and / or
fracturing
7.2.3.2.5 (d Fertilize and vegetate damaged subsided
areas to restore its pre- mining status if required. N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Underground
mining of coal
Animal life Impact on animals as a
result of subsidence and / or
fracturing
7.2.3.2.7 (f Use cut and fill techniques to ensure that
subsided areas are free draining. N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Underground
mining of coal
Animal life Impact on animals as a
result of subsidence and / or
fracturing
7.2.3.2.7 (g Fertilize and vegetate damaged subsided
areas to restore its pre- mining status if required. N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Environmental Audit Report
External Environmental Audit of the Impumelelo Colliery
SAS6652
DIGBY WELLS ENVIRONMENTAL
www.digbywells.com 36
Activity Environmental
aspect Potential Impact Condition
Compliance
Rating Audit Comments
Underground
mining of coal
Surface water Degradation of surface water
as a result of subsidence
and / or fracturing
7.2.3.2.8 (f Fertilize and vegetate damaged subsided
areas to restore its pre- mining status if required. N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Underground
mining of coal
Sensitive
landscapes
Degradation of sensitive
landscapes as a result of
subsidence and / or
fracturing
7.2.3.2.13 (d Fertilize and vegetate damaged subsided
areas to restore its pre- mining status if required. N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Underground
mining of coal
I&APs Degradation of land as a
result of subsidence and / or
fracturing
7.2.3.2.16 (j Prevent impacts on I&AP’s by excluding
sensitive landscapes (such as wetlands) and infrastructure
(such as farm houses) from areas to be mined by high
extraction mining methods.
N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Underground
mining of coal
I&APs Degradation of land as a
result of subsidence and / or
fracturing
7.2.3.2.16 (l Use cut and fill techniques to ensure that
subsided areas are free draining. N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Underground
mining of coal
I&APs Degradation of land as a
result of subsidence and / or
fracturing
7.2.3.2.16 (m Fertilize and vegetate damaged subsided
areas to restore its pre- mining status if required. N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Underground
mining of coal
I&APs Degradation of land as a
result of subsidence and / or
fracturing
7.2.3.2.16 (n Compensate landowners for any loss
incurred as a direct result of subsidence and / or
fracturing.
N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Underground
mining of coal
Topography Hollows will be created
(subsidence)
7.2.3.2.2 (d Use cut and fill techniques to ensure that
subsided areas are free draining. N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Underground
mining of coal
Soil Degradation of soils caused
by subsidence and / or
fracturing
7.2.3.2.3 (j Use cut and fill techniques to ensure that
subsided areas are free draining. N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Underground
mining of coal
Land use Degradation of land use as a
result of subsidence and / or
fracturing
7.2.3.2.5 (c Use cut and fill techniques to ensure that
subsided areas are free draining. N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Underground
mining of coal
Vegetation Degradation of vegetation as
a result of subsidence and /
or fracturing
7.2.3.2.6 (f Use cut and fill techniques to ensure that
subsided areas are free draining. N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Underground
mining of coal
Surface water Degradation of surface water
as a result of subsidence
and / or fracturing
7.2.3.2.8 (e Use cut and fill techniques to ensure that
subsided areas are free draining. N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Underground
mining of coal
Ground water Alteration of groundwater
flow paths as a result of
subsidence and / or
fracturing
7.2.3.2.9 (j Use cut and fill techniques to ensure that
subsided areas are free draining and to reduce infiltration
of clean water to underground. N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Environmental Audit Report
External Environmental Audit of the Impumelelo Colliery
SAS6652
DIGBY WELLS ENVIRONMENTAL
www.digbywells.com 37
Activity Environmental
aspect Potential Impact Condition
Compliance
Rating Audit Comments
Underground
mining of coal
Sites of
archaeological and
cultural interest
Degradation of sites of
archaeological and cultural
interest result of subsidence
and / or fracturing
7.2.3.2.12 (c Use cut and fill techniques to ensure that
subsided areas are free draining. N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Underground
mining of coal
Sensitive
landscapes
Degradation of sensitive
landscapes as a result of
subsidence and / or
fracturing
7.2.3.2.13 (c Use cut and fill techniques to ensure that
subsided areas are free draining, N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Underground
mining of coal
Ground water Alteration of groundwater
flow paths
7.2.3.2.9 (h Removal of only coal and rock required for the
continuation of the proposed mining, C
Extraction of material was limited to the removel of bedrock to establish the
incline, decline and ventilation shaft; and the current extraction of coal.
Clearing of land Animal life No anticipated impacts 7.2.2.1.17.7 N/A No anticipated impacts, N/A Noted.
Underground
mining of coal
Topography Mounds will be created 7.2.3.2.2 (a Ensure the height of the rock and ROM
stockpiles do not interrupt the line of the horizon. C
The ROM stockpiles were observed to be kept at a minimum height (lower
than the bunker) and therefore, are not considered to interrupt the line of the
horizon.
Mining related
activities
Surface water Decrease in surface water
quality
7.2.4.2.8 (c Remove shrubs and trees from the dam wall, C
The area adjacent to the PCDs are kept grassed and shrubs and trees are
removed as and when required.
Underground
mining of coal
Geology Geological strata will be
altered by subsidence
7.2.3.2.1 (d Use cut and fill techniques to ensure that
subsided areas are free draining, N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Underground
mining of coal
Geology Geological strata will be
altered by subsidence
7.2.3.2.1 (e Fertilize and vegetate damaged subsided
areas to restore its pre- mining status if required, N/A
Only one area within the Mining Right area was subjected to stooping and
there have been no signs of surface subsidence.
Transport of
coal
Visual aspects visual impact of haul trucks 7.2.5.2.14 (a Ensure haul trucks are clean and free of coal
dust, N/A
Not applicable, as no haul trucks are used to transport coal.
Underground
mining of coal
Noise generation of noise 7.2.3.2.11 (b Ensure blasting in suitably controlled, N/A
Not applicable. Blasting is only done underground and will therefore not
generate noise on surface.
Transport of
coal
Noise generation of noise 7.2.5.2.11 (a Fit the conveyor belt with noise reduction
idlers, and ensure that they remain efficiently functional, C
Noise monitoring results from 2019 showed that there were no exceedances
of the daytime or night-time acceptable noise ratings as per
SANS1013:2008 at the perimeter of the mine.
Transport of
coal
I&APs Nuisance dust and noise 7.2.5.2.16 (d Fit the conveyor belt with noise reduction
idlers, and ensure that they remain efficiently functional, C
Noise monitoring results from 2019 showed that there were no exceedances
of the daytime or night-time acceptable noise ratings as per
SANS1013:2008 at the perimeter of the mine.
Mining related
activities
Surface water Decrease in surface water
quality
7.2.4.2.8 (b Monitor the dam wall of the pollution control
dam for nature of vegetation cover, C
The area adjacent to the PCDs are kept grassed and shrubs and trees are
removed as and when required.
Underground
mining of coal
Visual aspects Visual impact of ROM
stockpile
7.2.3.2.14 (b Build visual barriers between the ROM
stockpile and sensitive viewpoints,
C
No trees have been planted as visual barriers. This has not been deemed
necessary, as the nearest receptors are more than 1 km away from the
operations. In addition to the above, Soweto Highveld Grasslands are found
in this area. This vegetation unit is typically devoid of trees. Impumelelo
have however planted Karee trees and Acacia trees along the road entrance
for beatification.
Environmental Audit Report
External Environmental Audit of the Impumelelo Colliery
SAS6652
DIGBY WELLS ENVIRONMENTAL
www.digbywells.com 38
Activity Environmental
aspect Potential Impact Condition
Compliance
Rating Audit Comments
Construction of
infrastructure
Visual aspects Visual impact of
infrastructure
7.2.2.2.14 (b Plant trees to create a visual barrier,
C
No trees have been planted as visual barriers. This has not been deemed
necessary, as the nearest receptors are more than 1 km away from the
operations. In addition to the above, Soweto Highveld Grasslands are found
in this area. This vegetation unit is typically devoid of trees. Impumelelo
have however planted Karee trees and Acacia trees along the road entrance
for beatification.
Underground
mining of coal
Sensitive
landscapes
Degradation of sensitive
landscapes as a result of
subsidence and / or
fracturing
7.2.3.2.13 (a Appoint a qualified specialist to design
appropriate mitigation measures should this impact occur,
C
Biomonitoring specialists, hydrologists, ecologists, wetland specialists and
Environmental Assessment Practitioners (EAPs) are and have been
employed at various stages throughout the mine's life cycle to assess
environmental impacts on sensitive landscapes. Information is provided and
if impacts occur, these are communicated to Impumelelo and appropriate
action plans are developed.
Mining related
activities
Soil Pollution of soils by spillage 7.2.4.2.3 (c One the spillage has been cleaned up the soils
should be tested and fertilized if necessary, NC
No soil results were available at the time of the audit to indicate that areas
that have been cleaned and rehabilitated have been tested.
Transport of
coal
Sensitive
landscapes
Alteration of structure and
function of sensitive
landscapes
7.2.5.2.13 (c One the spillage has been cleaned up the
soils should be tested and fertilized if necessary, NC
No soil results were available at the time of the audit to indicate that areas
that have been cleaned and rehabilitated have been tested.
Transport of
coal
Vegetation Establishment of invader
species
7.2.5.2.6 (e Monitor surface area within the conveyor
servitude to check whether any invader plant species can
be found there,
NC
No proof was available at the time of the audit that the conveyor servitude is
checked for invader plant species and that the alien invasive species were
removed.
Transport of
coal
Vegetation Establishment of invader
species
7.2.5.2.6 (f Remove any invader plant species as soon as
they are identified. NC
No proof was available at the time of the audit that the conveyor servitude is
checked for invader plant species and that the alien invasive species were
removed.
Underground
mining of coal
Noise generation of noise 7.2.3.2.11 (a Only allow noise generation when necessary
(i.e. switch off inactive machinery), C
No machines were observed to be left on when inactive.
Underground
mining of coal
Noise generation of noise 7.2.3.2.11 (e Only allow noise generation when necessary
(i.e. switch off inactive machinery), C
No machines were observed to be left on when inactive.
Underground
mining of coal
I&APs Irritation of I&AP’s by dust
and noise
7.2.3.2.16 (f Only allow noise generation when necessary
(i.e. switch off inactive machinery), C
No machines were observed to be left on when inactive.
Underground
mining of coal
I&APs Irritation of I&AP’s by dust
and noise
7.2.3.2.16 (i Only allow noise generation when necessary
(i.e. switch off inactive machinery), C
No machines were observed to be left on when inactive.
Mining related
activities
Air quality Decrease in air quality as a
result of additional vehicle
movement
7.2.4.2.10 (b Switch off machinery and vehicles when not
in use, C
No machines were observed to be left on when inactive.
Mining related
activities
I&APs Nuisance dust and noise 7.2.4.2.16 (e Only allow noise generation when necessary
(i.e. switch off inactive machinery) C
No machines were observed to be left on when inactive.
Construction of
infrastructure
I&APs Increase in crime 7.2.2.2.16 (c Implement penalties and fines for poaching, N/A
No incidents of poaching have been reported to the mine thus far.
Environmental Audit Report
External Environmental Audit of the Impumelelo Colliery
SAS6652
DIGBY WELLS ENVIRONMENTAL
www.digbywells.com 39
Activity Environmental
aspect Potential Impact Condition
Compliance
Rating Audit Comments
Mining related
activities
Animal life Loss of life 7.2.4.2.7 (m Implement penalties and fines for poaching, N/A
No incidents of poaching have been reported to the mine thus far.
Underground
mining of coal
Sites of
archaeological and
cultural interest
Degradation of sites of
archaeological and cultural
interest result of subsidence
and / or fracturing
7.2.3.2.12 (d Reconstruct graves if they have been
damaged,
C
The auditors were provided with GIS information to indicate the location of
graves, as identified by the heritage specialist study conducted during the
EIA process. Furthermore, the Survey Department completed a Section 17
Plan in terms of the Mineral and Petroleum Resources Development Act,
2002 (Act No. 28 of 2002) (MPRDA) to indicate all sensitive areas on
surface, including the locations of buildings and graves. It was confirmed
that no graves were damaged during the construction of the mine and no
graves were relocated during the construction of the mine site.
Mining related
activities
Animal life increase in faunal diversity 7.2.4.2.7 (f Monitor the surface land use area and note
changes in faunal diversity, NC
No evidence was available at the time of the audit that the surface land use
area is monitored in terms of its faunal diversity.
Underground
mining of coal
I&APs Irritation of I&AP’s by dust
and noise
7.2.3.2.16 (g Ensure blasting is suitably controlled, N/A
Not applicable. Blasting is only done underground and will therefore not
generate noise on surface.
Underground
mining of coal
I&APs Irritation of I&AP’s by dust
and noise
7.2.3.2.16 (c Suppress dust on the ROM stockpile when
required, C
Dust fallout monitoring is undertaken on a regular basis and no
exceedances of the non-residential dust fallout limit have been noted. In
addition, the ROM stockpile is visually monitored on a daily basis to detect
wind dispersion of dust. Dust suppression will only be done when needed.
Transport of
coal
Soil Pollution of soils by spillage 7.2.5.2.3 (a Monitor conveyor route in order to identify
spillages, C
The conveyor belt route is monitored on a daily basis by SCS.
Transport of
coal
Soil Pollution of soils by spillage 7.2.5.2.3 (b Spillages should be cleaned up immediately, C
No coal spillages were observed on site at the time of site visit.
Transport of
coal
Soil Pollution of soils by spillage 7.2.5.2.3 (d One the spillage has been cleaned up the
soils should be tested and fertilized if necessary, NC
No soil results were available at the time of the audit to indicate that areas
that have been cleaned and rehabilitated have been tested.
Transport of
coal
Soil Pollution of soils by spillage 7.2.5.2.3 (c Spillages should be neutralized if necessary
(i.e. if too basic or too acidic), NC
No soil results were available at the time of the audit to indicate that areas
that have been cleaned and rehabilitated have been tested.
Transport of
coal
Vegetation Pollution of soils by spillage 7.2.5.2.6 (a Spillages should be cleaned up immediately, C
No coal spillages were observed on site at the time of site visit.
Transport of
coal
Vegetation Pollution of soils by spillage 7.2.5.2.6 (b Spillages should be neutralized if necessary
(i.e. if too basic or too acidic), C
No coal spillages were observed on site at the time of audit.
Transport of
coal
Vegetation Pollution of soils by spillage 7.2.5.2.6 (c One the spillage has been cleaned up the soils
should be tested and fertilized if necessary, NC
No soil results were available at the time of the audit to indicate that areas
that have been cleaned and rehabilitated have been tested.
Transport of
coal
Surface water Decrease in surface water
quality
7.2.5.2.8 (a Spillages should be cleaned up immediately, C
No coal spillages were observed on site at the time of audit.
Transport of
coal
Surface water Decrease in surface water
quality
7.2.5.2.8 (b Spillages should be neutralized if necessary
(i.e. if too basic or too acidic), NC
No soil results were available at the time of the audit to indicate that areas
that have been cleaned and rehabilitated have been tested.
Transport of
coal
Surface water Decrease in surface water
quality
7.2.5.2.8 (c One the spillage has been cleaned up the soils
should be tested and fertilized if necessary, NC
No soil results were available at the time of the audit to indicate that areas
that have been cleaned and rehabilitated have been tested.
Environmental Audit Report
External Environmental Audit of the Impumelelo Colliery
SAS6652
DIGBY WELLS ENVIRONMENTAL
www.digbywells.com 40
Activity Environmental
aspect Potential Impact Condition
Compliance
Rating Audit Comments
Transport of
coal
Ground water Decrease in groundwater
quality
7.2.5.2.9 (a Spillages should be cleaned up immediately, C
No coal spillages were observed on site at the time of audit.
Transport of
coal
Ground water Decrease in groundwater
quality
7.2.5.2.9 (b Spillages should be neutralized if necessary
(i.e. if too basic or too acidic) NC
No soil results were available at the time of the audit to indicate that areas
that have been cleaned and rehabilitated have been tested.
Transport of
coal
Ground water Decrease in groundwater
quality
7.2.5.2.9 (c One the spillage has been cleaned up the soils
should be tested and fertilized if necessary, NC
No soil results were available at the time of the audit to indicate that areas
that have been cleaned and rehabilitated have been tested.
Transport of
coal
Sensitive
landscapes
Alteration of structure and
function of sensitive
landscapes
7.2.5.2.13 (a Spillages should be cleaned up immediately,
C
No coal spillages were observed on site at the time of audit.
Transport of
coal
Sensitive
landscapes
Alteration of structure and
function of sensitive
landscapes
7.2.5.2.13 (b Spillages should be neutralized if necessary
(i.e. if too basic or too acidic), C
No coal spillages were observed on site at the time of audit.
Transport of
coal
Visual aspects Visual impact of dust 7.2.5.2.14 (d Ensure that spillages are timeously cleaned
up, C
No coal spillages were observed on site at the time of audit.
Rehabilitation
activities
Topography Alteration of topography to
close to its pre-mining status
7.2.6.2.2 (a Ensure that all rehabilitated surfaces are free-
draining, N/A
No areas have been rehabilitated during the operational phase.
Rehabilitation
activities
Topography Alteration of topography to
close to its pre-mining status
7.2.6.2.2 (b Monitor rehabilitated areas to ensure that
altered topography is stable. N/A
No areas have been rehabilitated during the operational phase.
Rehabilitation
activities
Soil Compaction of soil 7.2.6.2.3 (a Limit vehicle movement to designated
pathways, N/A
No areas have been rehabilitated during the operational phase.
Rehabilitation
activities
Soil Rehabilitation of soil 7.2.6.2.3 (b Soils will be monitored, and if necessary
corrected or maintained on a regular basis to ensure that
the structure and function of the soil are becoming self-
sustaining,
N/A
No areas have been rehabilitated during the operational phase.
Rehabilitation
activities
Soil Soil erosion 7.2.6.2.3 (c Ensure barren areas are vegetated, N/A
No areas have been rehabilitated during the operational phase.
Rehabilitation
activities
Soil Soil erosion 7.2.6.2.3 (d Limit vehicle movement on rehabilitated areas, N/A
No areas have been rehabilitated during the operational phase.
Rehabilitation
activities
Soil Pollution of soils by spillage 7.2.6.2.3 (e Spillages should be cleaned up immediately, N/A
No areas have been rehabilitated during the operational phase.
Rehabilitation
activities
Soil Pollution of soils by spillage 7.2.6.2.3 (f Spillages should be neutralized if necessary
(i.e. if too basic or too acidic), N/A
No areas have been rehabilitated during the operational phase.
Rehabilitation
activities
Soil Pollution of soils by spillage 7.2.6.2.3 (g Once the spillage has been cleaned up the
soils should be tested and fertilized if necessary, N/A
No areas have been rehabilitated during the operational phase.
Rehabilitation
activities
Surface water quality 7.2.6.2.8 (c Water quality will be sampled and monitored
regularly, N/A
No areas have been rehabilitated during the operational phase.
Environmental Audit Report
External Environmental Audit of the Impumelelo Colliery
SAS6652
DIGBY WELLS ENVIRONMENTAL
www.digbywells.com 41
Activity Environmental
aspect Potential Impact Condition
Compliance
Rating Audit Comments
Rehabilitation
activities
Surface water Increase in infiltration 7.2.6.2.8 (d Water quantity will be monitored regularly, N/A
No areas have been rehabilitated during the operational phase.
Rehabilitation
activities
Surface water Increase in infiltration 7.2.6.2.8 (e Backfill the incline shaft and seal other shafts
to minimize surface water ingress, N/A
No areas have been rehabilitated during the operational phase.
Mining related
activities
Animal life Loss of life 7.2.4.2.7 (k Provide animal safe ladders on sloped areas
into the pollution control dam to prevent accidental
drowning,
C
There are yellow safety nets around the PCDs which serve as ladders for
animals to escape, if needed. To date no animals have fallen into the PCDs.
Rehabilitation
activities
Soil Pollution of soils by spillage 7.2.6.2.3 (h Natural vegetation should be established,
C
Natural vegetation have established in some of the cleared areas. The areas
were vegetated through natural succession. The ECO has also allocated
biodiversity areas which represent the natural vegetated areas in this
catchment.
Transport of
coal
Soil Pollution of soils by spillage 7.2.5.2.3 (e Natural vegetation should be established,
C
Natural vegetation has been established through natural succession.
However, in the section between Crossing 1 and Crossing 6, some of the
side slopes are bare and this has resulted in soil erosion.
Transport of
coal
Vegetation Pollution of soils by spillage 7.2.5.2.6 (d Natural vegetation should be established,
C
Natural vegetation has been established through natural succession.
However, in the section between Crossing 1 and Crossing 6, some of the
side slopes are bare and this has resulted in soil erosion.
Transport of
coal
Surface water Decrease in surface water
quality
7.2.5.2.8 (d Natural vegetation should be established,
C
Natural vegetation has been established through natural succession.
However, in the section between Crossing 1 and Crossing 6, some of the
side slopes are bare and this has resulted in soil erosion.
Transport of
coal
Ground water Decrease in groundwater
quality
7.2.5.2.9 (d Natural vegetation should be established,
C
Natural vegetation has been established through natural succession.
However, in the section between Crossing 1 and Crossing 6, some of the
side slopes are bare and this has resulted in soil erosion.
Transport of
coal
Sensitive
landscapes
Alteration of structure and
function of sensitive
landscapes
7.2.5.2.13 (d Natural vegetation should be established,
C
Natural vegetation has been established through natural succession.
However, in the section between Crossing 1 and Crossing 6, some of the
side slopes are bare and this has resulted in soil erosion.
Mining related
activities
Soil Pollution of soils by spillage 7.2.4.2.3 (d Natural vegetation should be established,
C
Natural vegetation have established in some of the cleared areas. The areas
were vegetated through natural succession. The ECO has also allocated
biodiversity areas which represent the natural vegetated areas in this
catchment.
Underground
mining of coal
Soil Pollution of soils by spillage 7.2.3.2.3 (h Natural vegetation should be established,
C
Natural vegetation have established in some of the cleared areas. The areas
were vegetated through natural succession. The ECO has also allocated
biodiversity areas which represent the natural vegetated areas in this
catchment.
Construction of
infrastructure
Visual aspects Visual impact of lights 7.2.2.2.14 (e Turn of lights not required for the operation
continuation of activities, C
Motion sensitive sensors were implemented in all offices to ensure that
lights are turned off when nobody is in the office.
Mining related
activities
Visual aspects Visual impact of lights 7.2.4.2.14 (e Turn off lights not required for the
continuation of mining related activities, C
Motion sensitive sensors were implemented in all offices to ensure that
lights are turned off when nobody is in the office.
Environmental Audit Report
External Environmental Audit of the Impumelelo Colliery
SAS6652
DIGBY WELLS ENVIRONMENTAL
www.digbywells.com 42
Activity Environmental
aspect Potential Impact Condition
Compliance
Rating Audit Comments
Mining related
activities
I&APs Irritation of I&AP’s as a result
of visual disturbance
7.2.4.2.16 (g Turn off lights not required for the
continuation of mining related activities, C
Motion sensitive sensors were implemented in all offices to ensure that
lights are turned off when nobody is in the office.
Underground
mining of coal
Geology Geological strata will be
altered by mining
7.2.3.2.1 (a Restrict the removal of rock to the mining area
only, C
Extraction of material was limited to the removal of bedrock to establish the
incline, decline and ventilation shaft; and the current extraction of coal.
Clearing of land Soil Compaction of soil 7.2.2.1.17.3 (g Ensure designated pathways are allocated
for vehicle movement, C
Mine vehicles are using dedicated roads that were constructed around the
mine.
Underground
mining of coal
Topography Mounds will be created 7.2.3.2.2 (b Ensure that the gradient of stockpiles is 1:3 or
less (shallower) so as to allow for the establishment of
vegetation on all stockpiles,
C
It was confirmed with the Engineer that the slopes of the overburden
stockpile were less than 1:3.
Underground
mining of coal
Noise generation of noise 7.2.3.2.11 (c Ensure designs of ventilation shafts take the
minimization of noise into consideration, C
Noise monitoring results from 2019 showed that there were no exceedances
of the daytime or night-time acceptable noise ratings as per
SANS1013:2008 at the perimeter of the mine.
Construction of
infrastructure
Vegetation Development of gardens 7.2.2.2.6 (c Check regularly for alien invader plant species
and remove any found, C
The ECO indicated that Impumelelo has appointed Libra Landscaping to
undertake an alien invasive plant assessment. An alien invasive plant
eradication plan is being implemented on site.
Underground
mining of coal
Vegetation Establishment of invader
species
7.2.3.2.6 (a Check all surface land use areas for any
invader plant species on a regular basis, C
The ECO indicated that Impumelelo has appointed Libra Landscaping to
undertake an alien invasive plant assessment. An alien invasive plant
eradication plan is being implemented on site.
Underground
mining of coal
Vegetation Establishment of invader
species
7.2.3.2.6 (b Remove any invader plant species.
C
The ECO indicated that Impumelelo has appointed Libra Landscaping to
undertake an alien invasive plant assessment. An alien invasive plant
eradication plan is being implemented on site.
Underground
mining of coal
Vegetation Degradation of vegetation as
a result of subsidence and /
or fracturing
7.2.3.2.6 (h Remove any invader plant species as soon as
they are identified. C
The ECO indicated that Impumelelo has appointed Libra Landscaping to
undertake an alien invasive plant assessment. An alien invasive plant
eradication plan is being implemented on site.
Underground
mining of coal
Sensitive
landscapes
Degradation of sensitive
landscapes as a result of
subsidence and / or
fracturing
7.2.3.2.13 (e Remove any invader plant species as soon
as they are identified. C
The ECO indicated that Impumelelo has appointed Libra Landscaping to
undertake an alien invasive plant assessment. An alien invasive plant
eradication plan is being implemented on site.
Mining related
activities
Vegetation Establishment of invader
species
7.2.4.2.6 (a Remove any invader plant species as soon as
they are identified. C
The ECO indicated that Impumelelo has appointed Libra Landscaping to
undertake an alien invasive plant assessment. An alien invasive plant
eradication plan is being implemented on site.
Rehabilitation
activities
Vegetation Establishment of invader
species
7.2.6.2.6 (a Check all revegetated and surrounding areas
for any invader plant species on a regular basis, C
The ECO indicated that Impumelelo has appointed Libra Landscaping to
undertake an alien invasive plant assessment. An alien invasive plant
eradication plan is being implemented on site.
Rehabilitation
activities
Vegetation Establishment of invader
species
7.2.6.2.6 (b Remove any invader plant species,
C
The ECO indicated that Impumelelo has appointed Libra Landscaping to
undertake an alien invasive plant assessment. An alien invasive plant
eradication plan is being implemented on site.
Environmental Audit Report
External Environmental Audit of the Impumelelo Colliery
SAS6652
DIGBY WELLS ENVIRONMENTAL
www.digbywells.com 43
Activity Environmental
aspect Potential Impact Condition
Compliance
Rating Audit Comments
Mining related
activities
Soil Loss of soil structure and
function
7.2.4.2.3 (f Remove alien invasive vegetation from the site,
C
The ECO indicated that Impumelelo has appointed Libra Landscaping to
undertake an alien invasive plant assessment. An alien invasive plant
eradication plan is being implemented on site.
Mining related
activities
Socio- economic
structure
Community projects 7.2.4.2.15 (d Encourage BEE participation in the tender
process, C
HR Department presents diversity statistics to the line managers who
present to the GM on a monthly basis. Sasol has also implemented a Sasol
Share Scheme under BEE.
Underground
mining of coal
Land use Alteration of land use as a
result of dewatering
7.2.3.2.5 (a Monitor the actual development of the cone of
depression (monitor water levels in boreholes) and provide
land owners with alternative water if required,
C
Groundwater monitoring boreholes are monitored bi-annually. A biannual
report is compiled and this is then submitted to the Department of Water and
Sanitation (DWS).
Underground
mining of coal
Ground water Decrease in groundwater
quantity as a result of the
formation of a depression
cone
7.2.3.2.9 (a Monitor the actual development of the cone of
depression (monitor water levels in boreholes) and provide
land owners with alternative water if required, C
Groundwater monitoring boreholes are monitored bi-annually. A biannual
report is compiled and this is then submitted to the Department of Water and
Sanitation (DWS).
Underground
mining of coal
I&APs Decrease in groundwater
quantity as a result of the
formation of a depression
cone
7.2.3.2.16 (a Monitor the actual development of the cone
of depression (monitor water levels in boreholes) and
provide land owners with alternative water when it has
been proven that the impact resulted from the mining
activities associated with the proposed mine.
C
Groundwater monitoring boreholes are monitored bi-annually. A biannual
report is compiled and this is then submitted to the Department of Water and
Sanitation (DWS).
Underground
mining of coal
I&APs Irritation of I&AP’s by dust
and noise
7.2.3.2.16 (d Prevent erosion of loose particles by
vegetating cleared land / stockpiles when possible,
NC
Erosion is prevented through various measures, specifically by backfilling,
sloping and vegetating disturbed areas. Erosion is also monitored through
visual site inspections. Erosion was however noticed at various areas on the
mine (STP at the outlet of the stormwater drains; and between Crossing 1
and Crossing 6), due to the lack of vegetation. Erosion control is on-going
and various rehabilitation activities were implemented between 2018 and
2020 to reduce the areas susceptible and showing signs of erosion.
Mining related
activities
Air quality Dust generation 7.2.4.2.10 (d Prevent erosion of loose particles by
vegetating cleared land / stockpiles as soon as possible,
NC
Erosion is prevented through various measures, specifically by backfilling,
sloping and vegetating disturbed areas. Erosion is also monitored through
visual site inspections. Erosion was however noticed at various areas on the
mine (STP at the outlet of the stormwater drains; and between Crossing 1
and Crossing 6), due to the lack of vegetation. Erosion control is on-going
and various rehabilitation activities were implemented between 2018 and
2020 to reduce the areas susceptible and showing signs of erosion.
Rehabilitation
activities
Surface water Quality 7.2.6.2.8 (b Vegetate barren land with natural vegetation
to prevent erosion,
NC
Erosion is prevented through various measures, specifically by backfilling,
sloping and vegetating disturbed areas. Erosion is also monitored through
visual site inspections. Erosion was however noticed at various areas on the
mine (STP at the outlet of the stormwater drains; and between Crossing 1
and Crossing 6), due to the lack of vegetation. Erosion control is on-going
and various rehabilitation activities were implemented between 2018 and
2020 to reduce the areas susceptible and showing signs of erosion.
Rehabilitation
activities
Air quality Dust generation 7.2.6.2.10 (b Prevent erosion of loose particles by
vegetating barren land as soon as possible, NC
Erosion is prevented through various measures, specifically by backfilling,
sloping and vegetating disturbed areas. Erosion is also monitored through
Environmental Audit Report
External Environmental Audit of the Impumelelo Colliery
SAS6652
DIGBY WELLS ENVIRONMENTAL
www.digbywells.com 44
Activity Environmental
aspect Potential Impact Condition
Compliance
Rating Audit Comments
visual site inspections. Erosion was however noticed at various areas on the
mine (STP at the outlet of the stormwater drains; and between Crossing 1
and Crossing 6), due to the lack of vegetation. Erosion control is on-going
and various rehabilitation activities were implemented between 2018 and
2020 to reduce the areas susceptible and showing signs of erosion.
Clearing of land Surface water Decrease in water quality 7.2.2.1.17.8 (b Prevent erosion of loose particles by
vegetating cleared land / stockpiles when no longer
utilized,
NC
Erosion is prevented through various measures, specifically by backfilling,
sloping and vegetating disturbed areas. Erosion is also monitored through
visual site inspections. Erosion was however noticed at various areas on the
mine (STP at the outlet of the stormwater drains; and between Crossing 1
and Crossing 6), due to the lack of vegetation. Erosion control is on-going
and various rehabilitation activities were implemented between 2018 and
2020 to reduce the areas susceptible and showing signs of erosion.
Clearing of land Air quality Dust generation 7.2.2.1.17.10 (b Prevent erosion of loose particles by
vegetating cleared land / stockpiles as soon as possible,
NC
Erosion is prevented through various measures, specifically by backfilling,
sloping and vegetating disturbed areas. Erosion is also monitored through
visual site inspections. Erosion was however noticed at various areas on the
mine (STP at the outlet of the stormwater drains; and between Crossing 1
and Crossing 6), due to the lack of vegetation. Erosion control is on-going
and various rehabilitation activities were implemented between 2018 and
2020 to reduce the areas susceptible and showing signs of erosion.
Transport of
coal
Visual aspects Visual impact of dust 7.2.5.2.14 (b Suppress dust on cleared land (transfer
station), C
Dust suppression is implemented at the coal transfer stations on the
conveyor belt. Dust fallout monitoring is undertaken by Sasol Mining (Pty)
Ltd and the results indicate that there have been no exceedances of the
non-residential dust fallout limit.
Transport of
coal
I&APs Nuisance dust and noise 7.2.5.2.16 (a Suppress dust on cleared land,
C
Dust suppression is implemented at the coal transfer stations on the
conveyor belt. Dust fallout monitoring is undertaken by Sasol Mining (Pty)
Ltd and the results indicate that there have been no exceedances of the
non-residential dust fallout limit.
Transport of
coal
Vegetation Minimization of physiological
processes
7.2.5.2.6 (g Implement a dust suppression programme on
all disturbed soil areas where dust can be generated due
to vehicle movement or the conveyor belt or wind.
C
Dust fallout monitoring is undertaken by Sasol Mining (Pty) Ltd and the
results indicate that there have been no exceedances of the non-residential
dust fallout limit. Dust suppression can be undertaken when necessary.
Clearing of land Surface water Decrease in water quality 7.2.2.1.17.8 (a Suppress dust on cleared land,
C
Dust fallout monitoring is undertaken by Sasol Mining (Pty) Ltd and the
results indicate that there have been no exceedances of the non-residential
dust fallout limit. Dust suppression can be undertaken when necessary.
Clearing of land Air quality Dust generation 7.2.2.1.17.10 (a Suppress dust on cleared land,
C
Dust fallout monitoring is undertaken by Sasol Mining (Pty) Ltd and the
results indicate that there have been no exceedances of the non-residential
dust fallout limit. Dust suppression can be undertaken when necessary.
Clearing of land Visual aspects Visual impact of dust 7.2.2.1.17.14 (a Suppress dust on cleared land,
C
Dust fallout monitoring is undertaken by Sasol Mining (Pty) Ltd and the
results indicate that there have been no exceedances of the non-residential
dust fallout limit. Dust suppression can be undertaken when necessary.
Environmental Audit Report
External Environmental Audit of the Impumelelo Colliery
SAS6652
DIGBY WELLS ENVIRONMENTAL
www.digbywells.com 45
Activity Environmental
aspect Potential Impact Condition
Compliance
Rating Audit Comments
Clearing of land I&APs Irritation caused by dust
generation
7.2.2.1.17.16 (a Suppress dust on cleared land,
C
Dust fallout monitoring is undertaken by Sasol Mining (Pty) Ltd and the
results indicate that there have been no exceedances of the non-residential
dust fallout limit. Dust suppression can be undertaken when necessary.
Construction of
infrastructure
Vegetation Minimisation of physiological
processes
7.2.2.2.6 (a Suppress dust on cleared land,
C
Dust fallout monitoring is undertaken by Sasol Mining (Pty) Ltd and the
results indicate that there have been no exceedances of the non-residential
dust fallout limit. Dust suppression can be undertaken when necessary.
Underground
mining of coal
Animal life Frightening of fauna 7.2.3.2.7 (a Suppress dust on cleared land,
C
Dust fallout monitoring is undertaken by Sasol Mining (Pty) Ltd and the
results indicate that there have been no exceedances of the non-residential
dust fallout limit. Dust suppression can be undertaken when necessary.
Underground
mining of coal
I&APs Irritation of I&AP’s by dust
and noise
7.2.3.2.16 (b Suppress dust on cleared land,
C
Dust fallout monitoring is undertaken by Sasol Mining (Pty) Ltd and the
results indicate that there have been no exceedances of the non-residential
dust fallout limit. Dust suppression can be undertaken when necessary.
Mining related
activities
Vegetation Minimization of physiological
processes
7.2.4.2.6 (d Suppress dust on cleared land,
C
Dust fallout monitoring is undertaken by Sasol Mining (Pty) Ltd and the
results indicate that there have been no exceedances of the non-residential
dust fallout limit. Dust suppression can be undertaken when necessary.
Mining related
activities
Animal life Frightening of fauna 7.2.4.2.7 (a Suppress dust on cleared land,
C
Dust fallout monitoring is undertaken by Sasol Mining (Pty) Ltd and the
results indicate that there have been no exceedances of the non-residential
dust fallout limit. Dust suppression can be undertaken when necessary.
Mining related
activities
Ground water Decrease in groundwater
quality
7.2.4.2.9 (a Ensure that the water used for dust
suppression is of an appropriate quality, C
Dust fallout monitoring is undertaken by Sasol Mining (Pty) Ltd and the
results indicate that there have been no exceedances of the non-residential
dust fallout limit. Dust suppression can be undertaken when necessary. Only
clean water would be used for dust suppression on surface.
Mining related
activities
Ground water Increase in groundwater
quantity
7.2.4.2.9 (c the amount of water used for dust suppression
should be enough to keep dust suppressed but not
enough to cause ponding or increased infiltration.
C
Dust fallout monitoring is undertaken by Sasol Mining (Pty) Ltd and the
results indicate that there have been no exceedances of the non-residential
dust fallout limit. Dust suppression can be undertaken when necessary.
Mining related
activities
Air quality Dust generation 7.2.4.2.10 (c Suppress dust on cleared land,
C
Dust fallout monitoring is undertaken by Sasol Mining (Pty) Ltd and the
results indicate that there have been no exceedances of the non-residential
dust fallout limit. Dust suppression can be undertaken when necessary.
Mining related
activities
Visual aspects Visual impact of dust 7.2.4.2.14 (a Suppress dust on cleared land,
C
Dust fallout monitoring is undertaken by Sasol Mining (Pty) Ltd and the
results indicate that there have been no exceedances of the non-residential
dust fallout limit. Dust suppression can be undertaken when necessary.
Mining related
activities
I&APs Nuisance dust and noise 7.2.4.2.16 (a Suppress dust on cleared land,
C
Dust fallout monitoring is undertaken by Sasol Mining (Pty) Ltd and the
results indicate that there have been no exceedances of the non-residential
dust fallout limit. Dust suppression can be undertaken when necessary.
Mining related
activities
I&APs Irritation of I&AP’s as a result
of visual disturbance
7.2.4.2.16 (i Suppress dust on cleared land,
C
Dust fallout monitoring is undertaken by Sasol Mining (Pty) Ltd and the
results indicate that there have been no exceedances of the non-residential
dust fallout limit. Dust suppression can be undertaken when necessary.
Environmental Audit Report
External Environmental Audit of the Impumelelo Colliery
SAS6652
DIGBY WELLS ENVIRONMENTAL
www.digbywells.com 46
Activity Environmental
aspect Potential Impact Condition
Compliance
Rating Audit Comments
Rehabilitation
activities
Animal life Frightening of fauna 7.2.6.2.7 (a Suppress dust on cleared land,
C
Dust fallout monitoring is undertaken by Sasol Mining (Pty) Ltd and the
results indicate that there have been no exceedances of the non-residential
dust fallout limit. Dust suppression can be undertaken when necessary.
Rehabilitation
activities
Surface water Decrease in surface water 7.2.6.2.8 (a Suppress dust on cleared land,
C
Dust fallout monitoring is undertaken by Sasol Mining (Pty) Ltd and the
results indicate that there have been no exceedances of the non-residential
dust fallout limit. Dust suppression can be undertaken when necessary.
Rehabilitation
activities
Air quality Dust generation 7.2.6.2.10 (a Suppress dust on cleared land,
C
Dust fallout monitoring is undertaken by Sasol Mining (Pty) Ltd and the
results indicate that there have been no exceedances of the non-residential
dust fallout limit. Dust suppression can be undertaken when necessary.
Clearing of land Vegetation Minimisation of physiological
processes
7.2.2.1.17.6 (d Implement a dust suppression programme
on all disturbed soil areas where dust can be generated
due to vehicle movement or wind within the surface land
use area,
C
Dust fallout monitoring is undertaken by Sasol Mining (Pty) Ltd and the
results indicate that there have been no exceedances of the non-residential
dust fallout limit. Dust suppression can be undertaken when necessary.
Mining related
activities
Visual aspects Visual impact of lights 7.2.4.2.14 (d Use directional lighting where possible, C
Directional lighting was installed where practically possible throughout the
shaft area.
Mining related
activities
I&APs Irritation of I&AP’s as a result
of visual disturbance
7.2.4.2.16 (f Use directional lighting where possible, C
Directional lighting was installed where practically possible throughout the
shaft area.
Construction of
infrastructure
Visual aspects Visual impact of lights 7.2.2.2.14 (d Use directional lighting where possible, C
Directional lighting was installed where practically possible throughout the
shaft area.
Transport of
coal
Animal life Loss of life 7.2.5.2.7 (c Monitor fencing of the conveyor route to
ensure that there are no holes. C
Daily security patrols are undertaken and should any concerns be identified;
this would be communicated to the responsible person.
SCS undertakes weekly proactive site inspections along the conveyor belt
route.
Underground
mining of coal
Soil Degradation of soil quality 7.2.3.2.3 (c Only clean or suitably treated water should be
released into the environment (depending on the
catchment objectives and license conditions),
NC
Currently, the treated effluent discharged from the Sewage Treatment Plant
(STP) does not comply with the qualities set out in the Water Use Licence
(WUL). The STP was designed and constructed to treat sewage to the
standards provided for in the General Authorisation regulations. However,
the water qualities specified in the WUL are more stringent and therefore,
the STP effluent qualities do not comply with the necessary limits. An
amendment application to the WUL was prepared and submitted in 2017.
No authorisation has been issued to date.
Underground
mining of coal
Land capability Degradation of land
capability
7.2.3.2.4 (c Only clean or suitably treated water should be
released into the environment (depending on the
catchment objectives and license conditions),
NC
Currently, the treated effluent discharged from the Sewage Treatment Plant
(STP) does not comply with the qualities set out in the Water Use Licence
(WUL). The STP was designed and constructed to treat sewage to the
standards provided for in the General Authorisation regulations. However,
the water qualities specified in the WUL are more stringent and therefore,
the STP effluent qualities do not comply with the necessary limits. An
amendment application to the WUL was prepared and submitted in 2017.
No authorisation has been issued to date.
Environmental Audit Report
External Environmental Audit of the Impumelelo Colliery
SAS6652
DIGBY WELLS ENVIRONMENTAL
www.digbywells.com 47
Activity Environmental
aspect Potential Impact Condition
Compliance
Rating Audit Comments
Underground
mining of coal
Surface water Decrease in surface water
quality
7.2.3.2.8 (c Only clean or suitably treated water should be
released into the environment,
NC
Currently, the treated effluent discharged from the Sewage Treatment Plant
(STP) does not comply with the qualities set out in the Water Use Licence
(WUL). The STP was designed and constructed to treat sewage to the
standards provided for in the General Authorisation regulations. However,
the water qualities specified in the WUL are more stringent and therefore,
the STP effluent qualities do not comply with the necessary limits. An
amendment application to the WUL was prepared and submitted in 2017.
No authorisation has been issued to date.
Mining related
activities
Surface water Increase in catchment yield 7.2.4.2.8 (i Monitor water and only release water if the
quality is good (as per license conditions),
NC
Currently, the treated effluent discharged from the Sewage Treatment Plant
(STP) does not comply with the qualities set out in the Water Use Licence
(WUL). The STP was designed and constructed to treat sewage to the
standards provided for in the General Authorisation regulations. However,
the water qualities specified in the WUL are more stringent and therefore,
the STP effluent qualities do not comply with the necessary limits. An
amendment application to the WUL was prepared and submitted in 2017.
No authorisation has been issued to date.
Mining related
activities
Sensitive
landscapes
Alteration in structure and
functioning of sensitive
landscapes
7.2.4.2.13 (a Only discharge water that is clean,
NC
Currently, the treated effluent discharged from the Sewage Treatment Plant
(STP) does not comply with the qualities set out in the Water Use Licence
(WUL). The STP was designed and constructed to treat sewage to the
standards provided for in the General Authorisation regulations. However,
the water qualities specified in the WUL are more stringent and therefore,
the STP effluent qualities do not comply with the necessary limits. An
amendment application to the WUL was prepared and submitted in 2017.
No authorisation has been issued to date.
Mining related
activities
Sensitive
landscapes
Alteration in structure and
functioning of sensitive
landscapes
7.2.4.2.13 (b Only discharge water according to Integrated
Water Use License conditions,
NC
Currently, the treated effluent discharged from the Sewage Treatment Plant
(STP) does not comply with the qualities set out in the Water Use Licence
(WUL). The STP was designed and constructed to treat sewage to the
standards provided for in the General Authorisation regulations. However,
the water qualities specified in the WUL are more stringent and therefore,
the STP effluent qualities do not comply with the necessary limits. An
amendment application to the WUL was prepared and submitted in 2017.
No authorisation has been issued to date.
Mining related
activities
Sensitive
landscapes
Alteration in structure and
functioning of sensitive
landscapes
7.2.4.2.13 (c If water is discharged not under license
conditions, appoint a qualified specialist to determine and
assist in implementing additional mitigation measures, C
A qualified Environmental Assessment Practitioner (EAP) was contracted to
prepare a WUL amendment application to request more appropriate limits
for effluent discharge qualities, as the qualities are currently in line with the
limits of the General Authorisation Regulations.
Underground
mining of coal
Soil Degradation of soil quality 7.2.3.2.3 (b No dirty water should be allowed to leave the
dirty water management area (except during an
exceptional flood event),
NC
Contaminated water (oily water) was observed in clean water areas on site,
which discharge into the environment.
Underground
mining of coal
Land capability Degradation of land
capability
7.2.3.2.4 (b No dirty water should be allowed to leave the
dirty water management area (except during an
exceptional flood event),
NC
Contaminated water (oily water) was observed in clean water areas on site,
which discharge into the environment.
Environmental Audit Report
External Environmental Audit of the Impumelelo Colliery
SAS6652
DIGBY WELLS ENVIRONMENTAL
www.digbywells.com 48
Activity Environmental
aspect Potential Impact Condition
Compliance
Rating Audit Comments
Underground
mining of coal
Ground water Decrease in groundwater
quality
7.2.3.2.9 (c No dirty water should be allowed to leave the
dirty water management area (except during an
exceptional flood event, as per the National Water Act, Act
36 of 1998, and only under license conditions),
NC
Contaminated water (oily water) was observed in clean water areas on site,
which discharge into the environment.
Transport of
coal
Surface water Decrease in surface water
quality
7.2.5.2.8 (f The conveyor belt should be monitored in order
to determine if any spillages have occurred so that they
can be timeously cleaned up,
C
Coal spillages forms part of the weekly proactive maintenance checklist that
is filled in by the SCS artisans responsible for the inspections.
Transport of
coal
Ground water Decrease in groundwater
quality
7.2.5.2.9 (f The conveyor belt should be monitored in order
to determine if any spillages have occurred so that they
can be timeously cleaned up,
C
Coal spillages forms part of the weekly proactive maintenance checklist that
is filled in by the SCS artisans responsible for the inspections.
Mining related
activities
Surface water Decrease in surface water
quality
7.2.4.2.8 (e Berms and trenches must be monitored
regularly to ensure they are not blocked, C
Berms and trenches are monitored regularly to ensure no dirty material is
present that could result in blockages.
Underground
mining of coal
Soil Pollution of soils by spillage 7.2.3.2.3 (e Spillages should be cleaned up immediately,
NC
At the time of the audit, various minor oil spills were noticed on the paved
area, as well as on soil where vehicles are parked. It was also noticed that
refuelling is done to the point of overflow, as evident from hydrocarbon spills
at the refuelling area and at the decline shaft. After a repeat of various
incidents, a Management Site Inspection was held in August 2019. This was
used to highlight the issues and appoint responsible people to address
these concerns. However, it was found that these issues have not yet
successfully been addressed.
Underground
mining of coal
Soil Pollution of soils by spillage 7.2.3.2.3 (f Spillages should be neutralized if necessary
(i.e. if too basic or too acidic), NC
No soil results were available at the time of the audit to indicate that areas
that have been cleaned and rehabilitated have been tested.
Underground
mining of coal
Soil Pollution of soils by spillage 7.2.3.2.3 (g One the spillage has been cleaned up the
soils should be tested and fertilized if necessary, NC
No soil results were available at the time of the audit to indicate that areas
that have been cleaned and rehabilitated have been tested.
Underground
mining of coal
Geology Geological strata will be
altered by subsidence
7.2.3.2.1 (b No high extraction mining should take place
underneath watercourses and sensitive landscapes, C
At the time of the audit, the ECO indicated that no high extraction mining
has occurred within the 500 m buffer zones around water courses and
sensitive landscapes.
Transport of
coal
Vegetation Minimization of physiological
processes
7.2.5.2.6 (h Ensure that the hauls trucks and / or conveyor
belt are covered so as to minimize dust generation, C
At the time of the audit, no trucks transporting coal were noted. During
discussion with the Environmental Practitioner from SCS, it was confirmed
that when trucks are used (breakdown of conveyor), the trucks are covered
to minimise dust generation.
Underground
mining of coal
Ground water Decrease in groundwater
quality
7.2.3.2.9 (g Spillages should be timeously and effectively
cleaned up so as to prevent infiltration of pollutants,
NC
At the time of the audit, various minor oil spills were noticed on the paved
area, as well as on soil where vehicles are parked. It was also noticed that
refuelling is done to the point of overflow, as evident from hydrocarbon spills
at the refuelling area and at the decline shaft. After a repeat of various
incidents, a Management Site Inspection was held in August 2019. This was
used to highlight the issues and appoint responsible people to address
these concerns. However, it was found that these issues have not yet
successfully been addressed.
Environmental Audit Report
External Environmental Audit of the Impumelelo Colliery
SAS6652
DIGBY WELLS ENVIRONMENTAL
www.digbywells.com 49
Activity Environmental
aspect Potential Impact Condition
Compliance
Rating Audit Comments
Mining related
activities
Soil Pollution of soils by spillage 7.2.4.2.3 (a Spillages should be cleaned up immediately,
NC
At the time of the audit, various minor oil spills were noticed on the paved
area, as well as on soil where vehicles are parked. It was also noticed that
refuelling is done to the point of overflow, as evident from hydrocarbon spills
at the refuelling area and at the decline shaft. After a repeat of various
incidents, a Management Site Inspection was held in August 2019. This was
used to highlight the issues and appoint responsible people to address
these concerns. However, it was found that these issues have not yet
successfully been addressed.
Mining related
activities
Soil Pollution of soils by spillage 7.2.4.2.3 (b Spillages should be neutralized if necessary
(i.e. if too basic or too acidic), NC
No soil results were available at the time of the audit to indicate that areas
that have been cleaned and rehabilitated have been tested.
Rehabilitation
activities
Surface water Pollution of surface water by
spillage
7.2.6.2.8 (f Spillages should be cleaned up immediately,
NC
At the time of the audit, various minor oil spills were noticed on the paved
area, as well as on soil where vehicles are parked. It was also noticed that
refuelling is done to the point of overflow, as evident from hydrocarbon spills
at the refuelling area and at the decline shaft. After a repeat of various
incidents, a Management Site Inspection was held in August 2019. This was
used to highlight the issues and appoint responsible people to address
these concerns. However, it was found that these issues have not yet
successfully been addressed.
Rehabilitation
activities
Surface water Pollution of surface water by
spillage
7.2.6.2.8 (g Spillages should be neutralized if necessary
(i.e. if too basic or too acidic), NC
No soil results were available at the time of the audit to indicate that areas
that have been cleaned and rehabilitated have been tested.
Rehabilitation
activities
Ground water Pollution of groundwater by
spillage
7.2.6.2.9 (a Spillages should be cleaned up immediately,
NC
At the time of the audit, various minor oil spills were noticed on the paved
area, as well as on soil where vehicles are parked. It was also noticed that
refuelling is done to the point of overflow, as evident from hydrocarbon spills
at the refuelling area and at the decline shaft. After a repeat of various
incidents, a Management Site Inspection was held in August 2019. This was
used to highlight the issues and appoint responsible people to address
these concerns. However, it was found that these issues have not yet
successfully been addressed.
Rehabilitation
activities
Ground water Pollution of groundwater by
spillage
7.2.6.2.9 (b Spillages should be neutralized if necessary
(i.e. if too basic or too acidic), NC
No soil results were available at the time of the audit to indicate that areas
that have been cleaned and rehabilitated have been tested.
Mining related
activities
Surface water Decrease in surface water
quality
7.2.4.2.8 (a Monitor water levels in the pollution control
dam to ensure that they comply with GN704, C
At the time of the audit the PCDs were operated below the 800 mm
freeboard. The levels of the dams are monitored on a continuous basis on
SCADA.
Transport of
coal
Air quality Dust generation 7.2.5.2.10 (b Ensure that haul trucks are covered with
tarpaulins, C
At the time of the audit, no trucks transporting coal were noted. During
discussion with the Environmental Practitioner from SCS, it was confirmed
that when trucks are used (breakdown of conveyor), the trucks are covered
to minimise dust generation.
Underground
mining of coal
Air quality Decrease in air quality due
to dust
7.2.3.2.10 (a Fit all vehicles that will operate underground
with custom exhaust systems which filter exhaust fumes. C
Occupational health monitoring is undertaken to determine exposure of
employees to exhaust fumes. In addition, the Ventilation Team continuously
monitors underground air quality. Maintenance is undertaken on any
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Activity Environmental
aspect Potential Impact Condition
Compliance
Rating Audit Comments
equipment that is seen to result in an unacceptable level of exhaust fume
emissions.
Underground
mining of coal
Air quality Decrease in air quality
underground
7.2.3.2.10 (b Fit all vehicles that will operate underground
with custom exhaust systems which filter exhaust fumes.
C
Occupational health monitoring is undertaken to determine exposure of
employees to exhaust fumes. In addition, the Ventilation Team continuously
monitors underground air quality. Maintenance is undertaken on any
equipment that is seen to result in an unacceptable level of exhaust fume
emissions.
Transport of
coal
Socio- economic
structure
Upliftment of individuals /
organizations
7.2.5.2.15 (a Give preference to local contractors, NC
At the time of the audit, no evidence was available to indicate that local
contractors are provided preference when contractors are appointed.
Underground
mining of coal
Animal life Frightening of fauna 7.2.3.2.7 (b Any fencing should allow an opportunity for
smaller animals to pass through the fence to escape the
construction activates, but prevent re-entry,
C
At the time of the audit, it was confirmed that smaller animals can pass
through the fence. These include mongooses and servals.
Mining related
activities
Animal life Frightening of fauna 7.2.4.2.7 (b Any fencing should allow an opportunity for
smaller animals to pass through the fence to escape the
construction activities, but prevent re-entry,
C
At the time of the audit, it was confirmed that smaller animals can pass
through the fence. These include mongooses and servals.
Mining related
activities
Animal life Loss of life 7.2.4.2.7 (g Any fencing should allow an opportunity for
smaller animals to pass through the fence to escape the
construction activates, but prevent re-entry,
C
At the time of the audit, it was confirmed that smaller animals can pass
through the fence. These include mongooses and servals.
Rehabilitation
activities
Animal life Frightening of fauna 7.2.6.2.7 (b Any fencing should allow an opportunity for
smaller animals to pass through the fence to escape the
rehabilitation activities, but prevent re-entry.
C
At the time of the audit, it was confirmed that smaller animals can pass
through the fence. These include mongooses and servals.
Mining related
activities
Surface water Increase in catchment yield 7.2.4.2.8 (k Maintain sewage treatment works to ensure
that it operates optimally,
C
Although the treated effluent does not comply with the water qualities
indicated in the WUL, a number of actions have been taken to increase the
optimum performance of the Plant. More effective equipment maintenance
and replacement has been done. This includes optimisation of the efficiency
of the aeration tank and this will be done by implementing level indicators on
the basin.
Underground
mining of coal
Ground water Decrease in groundwater
quality
7.2.3.2.9 (f Ensure that the ROM stockpiling is only
conducted within the designated area, and that the ROM
stockpile area is lined to limit infiltration,
C
The ROM stockpiles are kept within the boundaries of the dirty water
catchment, which flows via a silt trap to the PCD.
Underground
mining of coal
Vegetation Impact on surrounding
vegetation as a result of the
use of the ROM stockpile
7.2.3.2.6 (d Ensure that the ROM stockpile remains within
its designated area. C
The ROM stockpiles are kept within the boundaries of the dirty water
catchment, which flows via a silt trap to the PCD.
Underground
mining of coal
Soil Degradation of soil quality 7.2.3.2.3 (d Ensure that stockpiling of ROM coal is only
undertaken within the designated and purposefully
constructed area,
C
The ROM stockpiles are kept within the boundaries of the dirty water
catchment, which flows via a silt trap to the PCD.
Mining related
activities
Visual aspects Visual impact of lights 7.2.4.2.14 (f Draw blinds at night to limit the light emitted
from inside buildings, C
Although all offices have been fitted with blinds, motion sensitive sensors
were implemented to ensure that lights are turned off.
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Activity Environmental
aspect Potential Impact Condition
Compliance
Rating Audit Comments
Mining related
activities
I&APs Irritation of I&AP’s as a result
of visual disturbance
7.2.4.2.16 (h Draw blinds at night to limit the light emitted
from inside buildings, C
Although all offices have been fitted with blinds, motion sensitive sensors
were implemented to ensure that lights are turned off.
Mining related
activities
Surface water Decrease in surface water
quality
7.2.4.2.8 (f Pumps should be regularly checked to ensure
that they are functioning optimally, C
All pumps are put onto a planned maintenance schedule; and a job card is
then issued to ensure that the work is undertaken. The pumps are also on
SCADA and continuously monitored by the control room.
Mining related
activities
Ground water Increase in groundwater
quantity
7.2.4.2.9 (d Pumps should be regularly checked to ensure
that they are functioning optimally, C
All pumps are put onto a planned maintenance schedule; and a job card is
then issued to ensure that the work is undertaken. The pumps are also on
SCADA and continuously monitored by the control room.
Mining related
activities
Air quality Decrease in air quality as a
result of additional vehicle
movement
7.2.4.2.10 (a Maintain and service all machinery and
vehicle on a regular basis as per the requirements of the
specific machinery and vehicles,
C
All machinery and vehicles are maintained and serviced according to a
preventative maintenance schedule.
Mining related
activities
Animal life Loss of life 7.2.4.2.7 (j Ensure that all dirty water containment facilities
are sufficiently fenced to prevent animals from entering the
area,
C
All dirty water containment facilities are sufficiently fenced to prevent
unauthorised access to the PCDs.
Clearing of land Visual aspects Visual impact of dust 7.2.2.1.17.14 (b Limit vehicle movement to designated
roads wherever possible, C
Access roads have been constructed for vehicle movement. No vehicles
were noticed to move in undesignated roads or areas.
Underground
mining of coal
Animal life Frightening of fauna 7.2.3.2.7 (c Restrict vehicle movement to designated
pathways. C
Access roads have been constructed for vehicle movement. No vehicles
were noticed to move in undesignated roads or areas.
Underground
mining of coal
I&APs Irritation of I&AP’s by dust
and noise
7.2.3.2.16 (e Limit vehicle movement to designated roads
wherever possible, C
Access roads have been constructed for vehicle movement. No vehicles
were noticed to move in undesignated roads or areas.
Mining related
activities
Visual aspects Visual impact of dust 7.2.4.2.14 (b Limit vehicle movement to designated roads
wherever possible, C
Access roads have been constructed for vehicle movement. No vehicles
were noticed to move in undesignated roads or areas.
Transport of
coal
I&APs Nuisance dust and noise 7.2.5.2.16 (b Limit vehicle movement to designated roads
wherever possible, C
Access roads have been constructed for vehicle movement. No vehicles
were noticed to move in undesignated roads or areas.
Mining related
activities
I&APs Nuisance dust and noise 7.2.4.2.16 (b Limit vehicle movement to designated roads
wherever possible, C
Access roads have been constructed for vehicle movement. No vehicle
movement were noticed to move in undesignated roads or areas.
Rehabilitation
activities
Air quality Dust generation 7.2.6.2.10 (c Limit vehicle movement to designated roads
wherever possible, C
Access roads have been constructed for vehicle movement. No vehicle
movement were noticed to move in undesignated roads or areas.
Clearing of land I&APs Irritation caused by dust
generation
7.2.2.1.17.16 (b Limit vehicle movement to designated
roads wherever possible, C
Access have been constructed for vehicle movement. No vehicles were
noticed to move in undesignated roads or areas.
Clearing of land Soil Compaction of soil 7.2.2.1.17.3 (f Restrict vehicle access to stockpiles, C
Access control is implemented at the stockpiles. No vehicles were observed
at the stockpile area at the time of site visit.
Clearing of land Soil Soil erosion 7.2.2.1.17.3 (c Limit vehicle movement on stockpiles to
prevent compaction of soils, C
Access control is implemented at the stockpiles. No road traverses the
topsoil stockpile.
Clearing of land Soil Compaction of soil 7.2.2.1.17.3 (e Limit vehicle movement on stockpiles to
prevent compaction of soils. C
Access control is implemented at the stockpiles. No road traverses the
topsoil stockpile.
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Activity Environmental
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Compliance
Rating Audit Comments
Clearing of land Ground water Decrease in groundwater
recharge
7.2.2.1.17.9 Prevent compaction of soils by limiting vehicle
movement to prescribed pathways. C
Access control is implemented at the stockpiles. No road traverses the one
topsoil stockpile
Clearing of land Air quality Dust generation 7.2.2.1.17.10 (c Limit vehicle movement to designated
roads wherever possible, C
Access roads have been constructed for vehicle movement. No vehicle
movement were noticed to move in undesignated roads or areas.
Mining related
activities
Animal life Loss of life 7.2.4.2.7 (h Restrict vehicle movement to designated
pathways. C
Access roads have been constructed for vehicle movement. No vehicle
movement were noticed to move in undesignated roads or areas.
Mining related
activities
Animal life Frightening of fauna 7.2.4.2.7 (c Restrict vehicle movement to designated
pathways, C
Access roads have been constructed for vehicle movement. No vehicle
movement were noticed to move in undesignated roads or areas.
Mining related
activities
Air quality Dust generation 7.2.4.2.10 (e Limit vehicle movement to designated roads
wherever possible, C
Access roads have been constructed for vehicle movement. No vehicle
movement were noticed to move in undesignated roads or areas.
Rehabilitation
activities
Animal life Frightening of fauna 7.2.6.2.7 (c Restrict vehicle movement to designated
pathways, C
Access roads have been constructed for vehicle movement. No vehicle
movement were noticed to move in undesignated roads or areas.
Clearing of land Soil Soil erosion 7.2.2.1.17.3 (d Regularly inspect and maintain stockpiles
to ensure timeous rehabilitation of erosion from side
slopes,
C
A weekly inspection of the overburden stockpile and soil erosion is being
undertaken on site.
Transport of
coal
Air quality Decrease in air quality due
to gaseous emissions
7.2.5.2.10 (c Maintain and service coal trucks on a regular
basis as be the requirements of the vehicles, C
A Standard Operating Procedure (SOP) and task observation is in place
which requires that all tipper trucks be inspected on a daily basis.
Underground
mining of coal
Animal life Frightening of fauna 7.2.3.2.7 (d Restrict speed of vehicles at all times. C
A speed limit of 40km/hr is implemented on site.
Mining related
activities
Animal life Frightening of fauna 7.2.4.2.7 (d Restrict speed of vehicles at all times, C
A speed limit of 40km/hr is implemented on site.
Mining related
activities
Animal life Loss of life 7.2.4.2.7 (i Restrict speed of vehicles at all times. C
A speed limit of 40km/hr is implemented on site.
Mining related
activities
Surface water Decrease in surface water
quality
7.2.4.2.8 (h Ensure waste is suitably disposed of in
labelled bins, C
A SOP for waste management is available. The separation of waste is
implemented throughout the mine. Hazardous waste is segregated and
stored in appropriate containers and is later collected by Interwaste and is
disposed of at a permitted waste disposal site.
Mining related
activities
Ground water Decrease in groundwater
quality
7.2.4.2.9 (b Ensure that waste is appropriately separated
and disposed of in marked containers, C
A SOP for waste management is available. The separation of waste is
implemented throughout the mine. Hazardous waste is segregated and
stored in appropriate containers and is later collected by Interwaste and is
disposed of at a permitted waste disposal site.
Mining related
activities
Animal life Increase in abundance of
pests (mice, rats, etc.)
7.2.4.2.7 (e Dispose of domestic waste regularly as per
waste management procedure, C
A SOP for waste management is available. At the time of the audit the
general waste was removed by Interwaste and then disposed of to the
Secunda landfill site.
Construction of
infrastructure
Animal life Increase in abundance of
pests (mice, rats, etc.)
7.2.2.2.7 Dispose of domestic waste regularly as per
waste management procedure, C
A SOP for waste management is available. At the time of the audit the
general waste was removed by Interwaste and then disposed of to the
Secunda landfill site.
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Activity Environmental
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Compliance
Rating Audit Comments
Rehabilitation
activities
Animal life Frightening of fauna 7.2.6.2.7 (d Restrict speed of vehicles at all times, C
A speed limit of 40km/hr is implemented on site.
Underground
mining of coal
Vegetation Impact on surrounding
vegetation as a result of the
use of the ROM stockpile
7.2.3.2.6 (c Implement a dust suppression programme on
all disturbed areas as well as the ROM stockpile, C
A dust suppression programme is implemented at the coal transfer stations
and at the product stockpiles at the throw out area.
Underground
mining of coal
Ground water Decrease in groundwater
quality
7.2.3.2.9 (d Only clean or suitably treated water should be
released into the environment,
NC
Currently, the treated effluent discharged from the Sewage Treatment Plant
(STP) does not comply with the qualities set out in the Water Use Licence
(WUL). The STP was designed and constructed to treat sewage to the
standards provided for in the General Authorisation regulations. However,
the water qualities specified in the WUL are more stringent and therefore,
the STP effluent qualities do not comply with the necessary limits. An
amendment application to the WUL was prepared and submitted in 2017.
No authorisation has been issued to date.
Mining related
activities
Socio- economic
structure
Community projects 77.2.4.2.15 (e Ensure that the tender process is fair and
well documented,
C
Procurement is undertaken in line with the SLP and strict procurement
procedures.
BEE is further promoted through the employee share scheme and that they
measure BEE in terms of opportunities within Impumelelo. They also
monitor and report on diversity stats (which includes AIC – African, Coloured
and Indian [target of 30%] and women in mining). Reporting is done to the
line managers who report to the GM monthly.
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9.2 Summary of Level of Compliance
A summary of the compliance to operational phase conditions of the EA and EMPr is provided
on Table 9-3 below.
Table 9-3: Compliance Rating: EA and EMPr
Total
Number of
Conditions
Total
Compliance
Total Non-
Compliances
Total Not
Applicable
Total
possible
score
Score
EA 84 57 3 24 60 95%
EMPr 328 196 39 93 235 83.4%
10 Conclusion and Findings
The main findings and areas of non-compliance included the following:
● Erosion was noticed at various areas, including at the STP, the outlet of the stormwater
drain and at the reservoirs. This is due to the lack of vegetation. Erosion was also noted
along the SCS conveyor as a result of steep slopes and lack of stability measures;
● Contaminated water (oily water) was observed in clean water areas on site;
● Various oil spills were noticed on the paved areas where vehicles are parked;
● The general housekeeping around the site was found to be insufficient. Stormwater
drains were clogged with mixed mine waste, thus preventing the flow of water through
the system. Clean and dirty water drains were not separated; and
● Dirty oily rags were found in clean water trenches. Sediment and coal dust was also
observed in clean water trenches during the time of audit.