appendix m closure cost estimate and report
TRANSCRIPT
March 2020 19121900-328397-9
APPENDIX M
Closure Cost Estimate and Report
REPORT
Specialist Assessment for the Proposed Surface
Pipeline and Associated Infrastructure - Closure Cost
Estimate and Report AngloGold Ashanti (Pty) Ltd South African Operations
Submitted to:
AngloGold Ashanti (Pty) Ltd South African Operations Mr J van Wyk
Carletonville - Fochville Road R500
Carletonville
Gauteng
2501
Submitted by:
Golder Associates Africa (Pty) Ltd.
Podium at Menlyn, Second Floor, 43 Ingersol Road, Menlyn, Pretoria, 0181, South Africa
P O Box 6001, Halfway House, 1685
+27 11 254 4800
19121900-326804-1
February 2020
February 2020 19121900-326804-1
i
Distribution List 1 eCopy to AngloGold Ashanti (Pty) Limited South African Operations
1 eCopy to [email protected]
February 2020 19121900-326804-1
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Executive Summary Project Overview
The AGA operations in the West Wits mining lease areas are at risk of flooding due to ingress of fissure water
from surrounding mining operations. Approximately 25 Mℓ/day of fissure water flows into the underground
workings of the defunct Blyvooruitzicht Mine, which spans a strike of 6 km along the boundary with AGA.
If dewatering at the Old Blyvooruitzicht Shafts (#4, #5 & 6#) shafts were to cease, uncontrolled fissure water
would report to the AGA operations, which would pose both a flood and safety risk of AGA personnel and the
mining operations.
After the liquidation of the Blyvooruitzicht Mine (BLV) in 2013, AGA established a wholly owned subsidiary, the
Covalent Water Company (CWC), to manage the BLV Mine water at 4# and 6# to prevent flooding of the AGA
West Wits Operations. CWC has a 25-year lease to maintain water management infrastructure at the BLV
shafts #4 and #6. CWC currently abstracts approximately 20 Mℓ/d of good quality water from BLV #4 and #6
shafts and discharge this into the Wonderfonteinspruit under directive, 16/2/7/C231/C/116 dated 25 November
2014.
Approximately 6.5 Mℓ/d of Acid Mine Drainage (AMD) water containing elevated levels of heavy metals and
salts have been accumulating in the lower, mined out areas of BLV shaft #5 (BLV #5) bordering the Savuka
Mine. The pumping and removal of this impacted water was initiated at the Savuka Mine when this water
reached a critical level and started to decant to the AGA Operations, threatening AGA operational
infrastructure and posing a safety risk. Currently Savuka Mine pumps the BLV #5 fissure water from 81 level
to surface, where it is absorbed and used as make-up water in the Savuka Gold Plant Reclamation
Operations.
In summary, AGA propose to install underground infrastructure to route the BVL 5# AMD water to the BVL 4#
to allow for the dewatering, neutralisation and pumping to surface. From the BVL 4# mine this impacted water
will be routed on surface to the North Boundary Dam (NBD) and used as make-up water to the Savuka Gold
Plant Reclamation Operations.
Golder Associates (Golder) was appointed by AngloGold Ashanti to compile a closure cost estimate for AGA’s
proposed pipeline, as at June 2019. This report provides the anticipated closure costs for the proposed
project. For the purpose of this report, only the scheduled closure scenario was assessed, as the pipeline has
not been constructed yet.
The total estimated scheduled closure costs for decommissioning the pipeline and rehabilitating the affected
footprint area, as at June 2019, using Golder’s third-party contractor rates, amount to R 1 238 776 including
P&Gs and contingencies and excluding VAT).
Location
The proposed water pipeline and associated infrastructure is located approximately 80 km west of
Johannesburg and originates in the greater West Wits mining lease areas, approximately 3.3 km southeast of
Carletonville. The proposed pipeline ends at the North Boundary Dam approximately 6 km south-southwest of
Carletonville in Blyvooruitzicht, Merafong City Local Municipality, West Rand District Municipality in the
Gauteng Province of South Africa.
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TERMS AND ABBREVIATIONS
Terms
Care and
maintenance
This involves the maintenance and corrective action conducted on rehabilitated
areas, and the inspection and monitoring required to demonstrate that the closure
measures implemented have successfully achieved their intended purpose
Closure This involves the application for a closure certificate and initiation of the transfer of
ongoing care and maintenance to third parties
Contingencies This allows for making reasonable provision for possible oversights/omissions and
possible work not foreseen at the time of compilation of the closure costs.
Allowance of between 10 percent and 20 percent would usually be made based on
the accuracy of the estimations
Decommissioning This relates to the situation after cessation of operations involving the
deconstruction/removal and/or transfer of surface infrastructure and the initiation of
general site rehabilitation
Post-closure The period of on-going care and maintenance, as per arrangement with third
parties
Preliminary and
Generals (P&Gs)
This is a key cost item that is directly related to whether or not third-party
contractors are used for site rehabilitation. This cost item comprises both fixed and
time-related charges. The former makes allowance for the establishment (and de-
establishment) of contractors on site, as well as covering the operational
requirements (electricity/water/communications) for their offices, latrines,
workshops, etc. Time-related items make allowance for the running costs of the
fixed charged items for the contract period
Rehabilitation The return of a disturbed area to its original state, or as close as possible to this
state
Scheduled closure Closure that happens at the planned date and/or time horizon
Unscheduled
closure
Immediate closure of a site, representing decommissioning and rehabilitation of the
site in its present state
Site relinquishment Receipt of a closure certificate, and handover of the site to third parties for on-going
care and maintenance if required
Abbreviations
AGA AngloGold Ashanti
AMD Acid Mine Drainage
BLV Blyvooruitzicht
CWC Covalent Water Company
km Kilometres
KMZ Keyhole Mark-up language Zipped
Mℓ Megalitres
Mℓ/d Megalitres/day
NEMA National Environmental Management Act
VAT Value Added Tax
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Table of Contents
1.0 INTRODUCTION ......................................................................................................................................... 6
2.0 PROJECT BACKGROUND ........................................................................................................................ 6
2.1 Location of the proposed project ....................................................................................................... 6
3.0 OBJECTIVE ................................................................................................................................................ 8
4.0 DETAILS OF SPECIALIST ......................................................................................................................... 8
5.0 AVAILABLE INFORMATION ..................................................................................................................... 8
6.0 LEGISLATIVE FRAMEWORK .................................................................................................................... 8
7.0 APPROACH TO COST DETERMINATION ................................................................................................ 9
8.0 BATTERY LIMITS ....................................................................................................................................... 9
9.0 CLOSURE MEASURES ............................................................................................................................. 9
10.0 CLOSURE COST DETERMINATION ....................................................................................................... 10
10.1 Unit rates ......................................................................................................................................... 10
11.0 ASSUMPTIONS AND QUALIFICATIONS................................................................................................ 10
12.0 CLOSURE COST SUMMARY .................................................................................................................. 12
13.0 CONCLUSION .......................................................................................................................................... 13
14.0 STATEMENT OF INDEPENDENCE AND COMPETENCE ..................................................................... 13
14.1 Statement of independence ............................................................................................................ 13
14.2 Statement of competence ............................................................................................................... 13
TABLES
Table 1: Key information for this closure cost estimate ........................................................................................ 8
Table 2: Battery limits applicable to the closure cost determination .................................................................... 9
Table 3: Closure measures developed for AGAs proposed pipeline ................................................................... 9
Table 4: Closure costs for AGAs proposed pipeline, with Golder's contractor rates applied to decommissioning and rehabilitation of the footprint area ................................................................................................................ 12
FIGURES
Figure 1: Location of the proposed pipeline ......................................................................................................... 7
Figure 2: Example of a water supply pipeline at Husab Mine, Namibia ............................................................. 11
Figure 3: Plinth measurements used for concrete volume calculation ............................................................... 12
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APPENDICES
APPENDIX A Legal Framework
APPENDIX B Document Limitations
APPENDIX C Acknowledgements, Details of EAP, Declaration of Interest and Specialist Experience
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6
1.0 INTRODUCTION
The AngloGold Ashanti (AGA) operations in the West Wits mining lease areas are at risk of flooding due to
ingress of fissure water from surrounding mining operations. Approximately 25 Mℓ/day of fissure water flows
into the underground workings of the defunct Blyvooruitzicht Mine, which spans a strike of 6 km along the
boundary with AGA.
If dewatering at the Old Blyvooruitzicht Shafts (#4, #5 & 6#) shafts were to cease, uncontrolled fissure water
would report to the AGA operations, which would pose both a flood and safety risk of AGA personnel and the
mining operations.
After the liquidation of the Blyvooruitzicht Mine (BLV) in 2013, AGA established a wholly owned subsidiary, the
Covalent Water Company (CWC), to manage the BLV Mine water at 4# and 6# to prevent flooding of the AGA
West Wits Operations. CWC has a 25-year lease to maintain water management infrastructure at the BLV
shafts #4 and #6. CWC currently abstracts approximately 20 Mℓ/d of good quality water from BLV #4 and #6
shafts and discharge this into the Wonderfonteinspruit under directive, 16/2/7/C231/C/116 dated 25 November
2014.
Approximately 6.5 Mℓ/d of Acid Mine Drainage (AMD) water containing elevated levels of heavy metals and
salts have been accumulating in the lower, mined out areas of BLV shaft #5 (BLV #5) bordering the Savuka
Mine. The pumping and removal of this impacted water was initiated at the Savuka Mine when this water
reached a critical level and started to decant to the AGA Operations, threatening AGA operational
infrastructure and posing a safety risk. Currently Savuka Mine pumps the BLV #5 fissure water from 81 level
to surface, where it is absorbed and used as make-up water in the Savuka Gold Plant Reclamation
Operations.
In summary, AGA propose to install underground infrastructure to route the BVL 5# AMD water to the BVL 4#
to allow for the dewatering, neutralisation and pumping to surface. From the BVL 4# mine this impacted water
will be routed on surface to the North Boundary Dam (NBD) and used as make-up water to the Savuka Gold
Plant Reclamation Operations (Figure 1).
Golder Associates (Golder) was appointed by AGA to compile a closure cost estimate for AGA’s proposed
pipeline, as at June 2019. This report provides the anticipated closure costs for the proposed project. For the
purpose of this report, only the scheduled closure scenario was assessed, as the pipeline has not been
constructed yet.
2.0 PROJECT BACKGROUND
2.1 Location of the proposed project
The proposed water pipeline and associated infrastructure is located approximately 80 km west of
Johannesburg and originates in the greater West Wits mining lease areas approximately 3.3 km south east of
Carletonville. The proposed pipeline ends at the North Boundary Dam approximately 6 km south-south-west
of Carletonville in Blyvooruitzicht, Merafong City Local Municipality, West Rand District Municipality in the
Gauteng Province of South Africa (Figure 1).
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Figure 1: Location of the proposed pipeline
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3.0 OBJECTIVE
The objective of this report is to present the methodology and assumptions used to develop the cost estimate
for the decommissioning of the proposed surface-mounted pipeline and rehabilitation of the associated
disturbed footprint, from BLV #4 Shaft to the North Boundary Dam.
4.0 DETAILS OF SPECIALIST
The specialists who contributed to the closure planning report and associated closure costing, and their
relevant professional registrations and experience, are listed in Table 1:
Table 1: Details of specialists
Specialist Task Professional registration/ experience
Mmakoena Mmola Rehabilitation, Decommissioning
and Mine Closure Plan Closure
costs
BSc (Hons) Geochemistry;
BSc (Hons) Environmental Management and
Two years’ environmental consulting
experience.
Johan Bothma Senior internal reviewer MLArch;
PrLArch SACLAP (20163); and
15 years’ environmental consulting
experience.
5.0 AVAILABLE INFORMATION
The information summarised in Table 2 was made available and used for the determination of the closure cost
estimate.
Table 2: Key information for this closure cost estimate
Document Author Date Received
Proposal: West Wits/Covalent Water Company Operations: Basic
Assessment for Surface Pipeline, Associated Infrastructure and Water
Use Licence Application
Golder 28 May 2019
AGA West Wits Pipeline (Keyhole Mark-up language Zipped) KMZ file AGA 06 June 2019
E-mail: 191212900 AGA BA WUL project client feedback AGA 13 June 2019
6.0 LEGISLATIVE FRAMEWORK
The closure costs presented in this report have been determined according to the requirements of the
National Environmental Management Act (NEMA, Act No. 107 of 1998) Financial Provisioning Regulations
(GN R.1147, Regulations Pertaining to the Financial Provision for Prospecting, Exploration, Mining or
Production Operations – as amended), promulgated on 20 November 2015. These regulations are planned to
be repealed and superseded by revised regulations; however, it is not anticipated that the proposed revised
regulations would impact the computed AGA pipeline closure costs.
Apart from the requirements of the GN R.1147 regulations, mine closure planning is also required to be
compliant with additional legislation, which is summarised in APPENDIX A.
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7.0 APPROACH TO COST DETERMINATION
The approach followed to determine the closure cost estimate is summarised as follows:
Determine the closure costs by undertaking the following:
▪ Identify appropriate measures for dismantling the pipeline infrastructure and rehabilitating the
associated disturbed footprint, including conducting required maintenance and aftercare;
▪ Verify the unit rates for surface infrastructure dismantling/demolition as well as associated
rehabilitation in consultation with demolition practitioners;
▪ Apply the above unit rates and associated quantities in Golder’s latest closure costing model; and
▪ Assess the closure measures applied and update as/if required.
Compile a closure cost report to reflect the computed closure costs, the approach followed, and
assumptions made in the closure cost determination.
8.0 BATTERY LIMITS
The battery limits for AGAs proposed pipeline, as applied to the closure cost determination, are listed in
Table 3 and further illustrated in Figure 1.
Table 3: Battery limits applicable to the closure cost determination
Area Closure components
Infrastructure areas Surface pipeline from BLV #4 Shaft to North Boundary Dam; and
Associated concrete plinths.
9.0 CLOSURE MEASURES
The closure costs are based on the closure measures developed for AGAs proposed pipeline, as outlined in
Table 4.
Table 4: Closure measures developed for AGAs proposed pipeline
Aspect Closure measures
Infrastructure areas
Pipeline Dismantle pipeline; and
Remove concrete plinths.
Demolition waste Crush concrete demolition waste to suitable size and load and
haul for disposal at an authorised landfill site.
*It is assumed that the inert demolition waste will be disposed of at the
Rooipoort landfill site, approximately 20 km from the proposed pipeline
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Aspect Closure measures
General surface rehabilitation
Shaping, ripping and vegetation
establishment Shape and level disturbed area resulting from the removal of
concrete plinths;
Rip footprint area to be free draining; and
Establish vegetation using a suitable indigenous seed mix.
Post-closure aspects
Rehabilitation monitoring Conduct rehabilitation monitoring over the rehabilitated area for a
period of 5 years post-closure.
Care and maintenance Undertake care and maintenance over the rehabilitated area for a
period of 5 years post-closure.
10.0 CLOSURE COST DETERMINATION
10.1 Unit rates
The unit rates for general rehabilitation and closure measures/activities were obtained from Golder’s existing
closure costing database, which is regularly updated in consultation with demolition and earthworks
contractors, as well as with rehabilitation practitioners. Golder undertakes a thorough review of its unit rate
database, as follows:
Minor unit rates are adjusted with standard inflation at least once a year;
Key rates for the dismantling of infrastructure are benchmarked at least annually by a specialised
demolition contractor, to ensure that they remain market-related and take account of the latest
dismantling and demolition techniques. It is noted that as these technologies improve, these rates in real
terms are trending downwards;
Earthworks rates are benchmarked against recent tenders available to Golder as well as benchmarking
in discussion with contractors; and
Aggregated rates dependent on base infrastructure or earthworks-related rates are recalculated given
the latest base rates.
11.0 ASSUMPTIONS AND QUALIFICATIONS
To determine the closure cost estimate for AGA’s proposed pipeline, Golder made use of the following key
assumptions:
The proposed pipeline will be decommissioned at scheduled mine closure;
The diameter of the proposed pipeline is 400 mm (0.4 m). It is assumed that an additional 1 m on either
side of the pipeline will be disturbed during decommissioning of the pipeline, resulting in a total of 2.4 m
of horizontal disturbance. The total length of the pipeline is 5 200 m. Therefore, the total area that will be
disturbed by the pipeline is 12 480 m2 (1.248 ha);
Allowance for the disposal of concrete waste associated with the concrete plinths has been included.
Inert waste (i.e. concrete rubble) will be crushed to aggregate (75 mm) and disposed of at an authorised
landfill site. An average distance of 20 km has been included for load and haul/disposal of demolition
waste at the Rooipoort landfill site;
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It is assumed that the concrete plinths will be spaced 9 m apart over the distance of the pipeline, which
results in a total of approximately 578 concrete plinths;
The volume calculations for each concrete plinth is based on the design shown in Figure 2 and the
measurements presented in Figure 3;
No allowance has been included for the disposal of steel demolition waste. It is assumed that steel waste
will be collected by a third-party for re-use;
No allowance has been included for rehabilitation of access roads that may be constructed for
decommissioning and rehabilitation of the pipeline at scheduled closure;
General surface rehabilitation will involve the shaping and ripping of the surface topography, to allow for
a free-draining uncompacted surface, followed by vegetation establishment;
P&Gs and contingencies have been included at 12% and 10%, respectively; and
Rehabilitation monitoring and care and maintenance has been allowed for a period of 5 years over the
rehabilitated footprint area.
Figure 2: Example of a water supply pipeline at Husab Mine, Namibia
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Figure 3: Plinth measurements used for concrete volume calculation
12.0 CLOSURE COST SUMMARY
The total estimated scheduled closure costs for AGA’s proposed pipeline, as at June 2019, amount to
R 1 238 775.53 (including P&Gs and contingencies and excluding VAT), as summarised in Table 5. These
costs assume third-party contractor rates will be applied to decommissioning and rehabilitation of the pipeline.
Table 5: Closure costs for AGAs proposed pipeline, with Golder's contractor rates applied to decommissioning and rehabilitation of the footprint area
Closure components Scheduled Closure (2035)
1 Infrastructural aspects R 795 281.19
2 Mining aspects R -
3 General surface rehabilitation R 203 406,29
Sub-Total 1 R 998 687.48
5 Post-Closure Aspects
5.1 Rehabilitation monitoring R 3 042,50
5.2 Care and maintenance R 17 334.31
Sub-Total 2 R 20 376.81
6 Additional Allowances
6.1 Preliminary and general R 119 842.50
6.2 Contingencies R 99 868.75
Sub-Total 3 R 219 711.25
Grand Total
Excl. VAT. (Sub-total 1 +2 +3) R 1 238 775.53
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13.0 CONCLUSION
The closure costs reflected in this report were based on information provided by AngloGold Ashanti. In those
cases where the required information was not available, estimates were made based on Golder’s experience
in closure cost estimations. Unit rates for the costing were obtained from Golder’s database.
The reflected costs provide a good indication of the closure costs as at June 2019, providing a sound basis for
making the required financial provision.
14.0 STATEMENT OF INDEPENDENCE AND COMPETENCE
14.1 Statement of independence
Golder is an independent international environmental consultancy. Neither Golder nor its staff, have or have
had, any interest in this project capable of affecting their ability to give an objective and unbiased opinion, and
have and/or will not receive any pecuniary or other benefits in connection with the project, other than normal
consulting fees.
14.2 Statement of competence
Golder prides itself as being at the forefront of mine closure and rehabilitation not only within Africa, but the
world. Golder in Africa is currently taking the lead with respect to the technical innovation in this field, being
the first with a numerical closure costing model, landform modelling as well as unsaturated flow through soil
covers.
We are actively engaged in the evolution of international best practice, as represented by the standards of the
World Bank and the IFC, as well as in the application of that best practice in our environmental and social
consulting. We are also experienced in ensuring that our products, while meeting World Bank and IFC
standards, are compliant with pertinent national legislation and clients’ corporate standards.
Golder has in-depth experience in environmental and mining-related civil engineering, closure planning and
cost determination. All closure-related work is guided and reviewed by Francois Marais, Brent Baxter, Brent
Johnson or Mark Aken, in their respective capacities as senior strategic advisors in terms of rehabilitation and
closure related projects.
The Golder Land use and Closure team has conducted closure planning, including facilitation/consultation
with the respective regulatory authorities/agencies, throughout Africa. The team specializes in the closure of
mining and industrial complexes, addressing the matter from both a strategic and detailed closure/costing
perspective.
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The South African closure cost and liability effort is strongly connected to the global Golder family and
knowledge sharing, and advancement within the discipline is facilitated in this way. In addition, Golder is
known throughout the mining industry for its extensive experience in mining-related environmental
assessment and permitting and has over the years conducted a broad range of services for all major mining
houses and commodities throughout South Africa and the rest of the continent, as well as abroad.
Golder Associates Africa (Pty) Ltd.
Mmakoena Mmola Johan Bothma
Environmental Consultant Senior Environmental Consultant
MM/JB/nbh
Reg. No. 2002/007104/07
Directors: RGM Heath, MQ Mokulubete, MC Mazibuko (Mondli Colbert), GYW Ngoma
Golder and the G logo are trademarks of Golder Associates Corporation
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February 2020 19121900-326804-1
APPENDIX A
Legal Framework
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LEGISLATION PERTAINING TO MINE CLOSURE
Apart from the GN R.1147 (as amended) regulations mine closure planning is also required to be compliant
with the following legislation:
Minerals Petroleum and Resources Development Act No. 28 of 2002 (MPRDA). Section 43 states that a
holder of a prospecting right, mining right, retention permit or mining permit remains responsible for any
environmental liability, pollution or ecological degradation and the management thereof, until the Minister
has issued a closure certificate to the holder concerned;
National Environmental Management Act, No. 107 of 1998 (NEMA):
▪ If it is determined that a mine, having regard to its known ore reserves, is likely to cease mining
operations within a period of five years, the owner of that mine must promptly notify the Minister in
writing -
− of the likely cessation of those mining operations;
− of any plans that are in place or in contemplation for the rehabilitation of the area where the
mining operations were conducted after mining operations have stopped; and
− the prevention of pollution of the atmosphere by dust after those operations have stopped.
▪ Duty of care to take reasonable measures to prevent significant pollution or degradation of the
environment from occurring, continuing or re-occurring or where such pollution or degradation cannot
be reasonably stopped or avoided, such person must take reasonable measures to minimize and
rectify such pollution or degradation.
Environmental Impact Assessment Regulations, 2014: An application for an environmental
authorisation (Basic Assessment) must be submitted for the decommissioning of any activity requiring:
▪ A closure certificate in terms of section 43 of the Mineral and Petroleum Resources Development
Act, 2002 (Act No. 28 of 2002); or
▪ A prospecting right, mining right, mining permit, production right or exploration right, where the
throughput of the activity has reduced by 90% or more over a period of 5 years excluding where the
competent authority has in writing agreed that such reduction in throughput does not constitute
closure.
NEMA Principles
In terms of section 38 of the MPRDA, holders of reconnaissance permissions, prospecting rights, mining
rights, mining permits or retention permits must promote compliance with the principles set out in section
2 of the NEMA, which provide that -
▪ The disturbance of ecosystems and loss of biological diversity is avoided, or, wherever it cannot
altogether be avoided, is minimised and remedied;
▪ Pollution and degradation of the environment is avoided, or where it cannot be altogether avoided, is
minimised and remedied;
▪ The disturbance of landscapes and sites that constitute a nations cultural heritage is avoided, or
where it cannot be altogether avoided, is minimised and remedied;
▪ A risk-averse and cautious approach is applied, which takes into account the limits of current
knowledge about the consequences of decisions and actions; and
February 2020 19121900-326804-1
▪ Negative impacts on the environment and on people’s environmental rights be anticipated and
prevented, and when they cannot be altogether prevented, are minimised and remedied.
The National Water Act (NWA), Act No. 36 of 1998 requires the following:
▪ A duty is imposed on the owner of land, a person in control of land or a person who occupies or
uses the land to take all reasonable measures to prevent the pollution of a water resource from
occurring, continuing or recurring;
▪ Regulations on the Use of Water for Mining and Related Activities Aimed at the Protection of Water
Resources, GN R.704;
▪ Any person in control of an existing mine must notify the DWA 14 days before the temporary or
permanent cessation of the operation of the mine;
▪ Any person in control of a mine must at temporary or permanent cessation of mining operations,
ensure that -
− Any person in control of a mine or activity must at temporary or permanent cessation of
operations ensure that all pollution control measures have been designed, modified,
constructed and maintained in accordance with GN R.704; and
− Any person in control of a mine or activity must ensure that the in-stream and riparian habitat of
any water resource, which may be affected or altered by the mine or activity, is remedied so
as to comply with GN R.704.
▪ Provision is made for, inter alia -
− Regulation 4: Restrictions on locality regarding infrastructure;
− Regulation 5: Restrictions on use of material;
− Regulation 6: Capacity requirements of clean and dirty water systems; and
− Regulation 7: Protection of water resources.
Regulation 7 of GN R. 704:
▪ Every person in control of a mine or activity must take reasonable measures to -
− Prevent water containing waste or any substance which causes or is likely to cause pollution of a
water resource from entering any water resource and must retain or collect such substance or
water for use, re-use, evaporation or for purification and disposal in terms of the Act;
− Cause effective measures to minimise the flow of any surface water or floodwater into mine
workings, open cast workings, other workings or subterranean caverns, through cracked or
fissured formations, subsided ground, sinkholes, outcrop excavations, audits, entrances or any
other openings; and
− Prevent the erosion or leaching of materials from any residue deposit or stockpile from any
area and contain such material or substances so eroded and leached in such area by providing
effective suitable barrier dams, evaporative dams or any other effective measures to prevent
this material or substance from entering and polluting any water resources.
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Conservation of Agricultural Resources Act No. 43 of 1983:
▪ Regulation 15 of the Conservation of Agricultural Resources (CARA), Act No. 43 of 1983 provides
a list of Category 1 plants (Weeds) and Category 2 and Category 3 plants (invaders) that
must be controlled. Category 1, 2 and 3 plants may not occur on any land or inland water surface
other than in biological control reserves and must be controlled by means of the methods
prescribed in the regulations (unless exemption granted).
Constitution of the Republic of South Africa, Act No. 108 of 1996, Section 33:
▪ Everyone has the right to administrative action that is lawful, reasonable and procedurally fair;
▪ Everyone whose rights have been adversely affected by administrative action has the right to be
given written reasons;
▪ Any application for, for example, a closure certificate or an application for transfer of liabilities and
responsibilities in terms of the MPRDA must be considered by the relevant authority according to the
criteria contained in Section 33 of the Constitution; and
▪ Where the relevant authority has been given a discretion, that discretion must be exercised in a
reasonable manner and without bias, prejudice or any personal agenda.
Where the state fails to exercise just administration, the decision in question may be set aside by way of an
application to court or any internal procedures prescribed by the empowering legislation.
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APPENDIX B
Document Limitations
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DOCUMENT LIMITATIONS
This Document has been provided by Golder Associates Africa Pty Ltd (“Golder”) subject to the following
limitations:
i) This Document has been prepared for the particular purpose outlined in Golder’s proposal and no
responsibility is accepted for the use of this Document, in whole or in part, in other contexts or for any
other purpose.
ii) The scope and the period of Golder’s Services are as described in Golder’s proposal, and are subject to
restrictions and limitations. Golder did not perform a complete assessment of all possible conditions or
circumstances that may exist at the site referenced in the Document. If a service is not expressly
indicated, do not assume it has been provided. If a matter is not addressed, do not assume that any
determination has been made by Golder in regards to it.
iii) Conditions may exist which were undetectable given the limited nature of the enquiry Golder was
retained to undertake with respect to the site. Variations in conditions may occur between investigatory
locations, and there may be special conditions pertaining to the site which have not been revealed by the
investigation and which have not therefore been taken into account in the Document. Accordingly,
additional studies and actions may be required.
iv) In addition, it is recognised that the passage of time affects the information and assessment provided in
this Document. Golder’s opinions are based upon information that existed at the time of the production of
the Document. It is understood that the Services provided allowed Golder to form no more than an
opinion of the actual conditions of the site at the time the site was visited and cannot be used to assess
the effect of any subsequent changes in the quality of the site, or its surroundings, or any laws or
regulations.
v) Any assessments made in this Document are based on the conditions indicated from published sources
and the investigation described. No warranty is included, either express or implied, that the actual
conditions will conform exactly to the assessments contained in this Document.
vi) Where data supplied by the client or other external sources, including previous site investigation data,
have been used, it has been assumed that the information is correct unless otherwise stated. No
responsibility is accepted by Golder for incomplete or inaccurate data supplied by others.
vii) The Client acknowledges that Golder may have retained sub-consultants affiliated with Golder to provide
Services for the benefit of Golder. Golder will be fully responsible to the Client for the Services and work
done by all of its sub-consultants and subcontractors. The Client agrees that it will only assert claims
against and seek to recover losses, damages or other liabilities from Golder and not Golder’s affiliated
companies. To the maximum extent allowed by law, the Client acknowledges and agrees it will not have
any legal recourse, and waives any expense, loss, claim, demand, or cause of action, against Golder’s
affiliated companies, and their employees, officers and directors.
viii) This Document is provided for sole use by the Client and is confidential to it and its professional advisers.
No responsibility whatsoever for the contents of this Document will be accepted to any person other than
the Client. Any use which a third party makes of this Document, or any reliance on or decisions to be
made based on it, is the responsibility of such third parties. Golder accepts no responsibility for
damages, if any, suffered by any third party as a result of decisions made or actions based on this
Document.
GOLDER ASSOCIATES AFRICA (PTY) LTD
February 2020 19121900-326804-1
APPENDIX C
Acknowledgements, Details of
EAP, Declaration of Interest
and Specialist Experience
February 2020 19121900-326804-1
Acknowledgements
The following persons are acknowledged for their contribution to the report:
Table A: Acknowledgements
Name Organisation Contribution
AGA Project Team South32 Client
CWC Project Team CWC Developer
Adam Bennett Golder Project manager
Mmakoena Mmola Golder Junior consultant
Johan Bothma Golder Senior closure consultant
February 2020 19121900-326804-1
Details of Specialist and Declaration of interest
(For official use only)
File Reference Number:
NEAS Reference Number:
Date Received:
Application for authorisation in terms of the National Environmental Management Act, 1998 (Act No. 107 of
1998), as amended and the Environmental Impact Assessment Regulations, 2014
PROJECT TITLE
Details of EAP
Specialist Johan Bothma (Golder Associates Africa (Pty) Limited)
Contact Person Johan Bothma
Postal address P.O. Box 6001, Halfway House
Post code 1685
Telephone
Cell
Fax
Professional affiliations South African Council for the Landscape Architectural
Profession (SACLAP)
Registration number #: 20163
Environmental Authorisation for the proposed Surface Pipeline and Associated Infrastructure for
AngloGold Ashanti (Pty) Ltd
+27 11 254 4800
+27 82 803 3882
February 2020 19121900-326804-1
4.2 The Environmental Specialist
I, Johan Bothma declare that:
General declaration:
I act as the independent specialist in this application;
I will perform the work relating to the application in an objective manner, even if this results in views
and findings that are not favourable to the applicant;
I declare that there are no circumstances that may compromise my objectivity in performing such work;
I have expertise in conducting environmental impact assessments, including knowledge of the Act,
regulations and any guidelines that have relevance to the proposed activity;
I will comply with the Act, Regulations and all other applicable legislation;
I will take into account, to the extent possible, the matters listed in regulation 8 of the
Regulations when preparing the application and any report relating to the application;
I have no, and will not engage in, conflicting interests in the undertaking of the activity;
I undertake to disclose to the applicant and the competent authority all material information in my
possession that reasonably has or may have the potential of influencing - any decision to be taken with
respect to the application by the competent authority; and - the objectivity of any report, plan or
document to be prepared by myself for submission to the competent authority;
I will ensure that information containing all relevant facts in respect of the application is distributed
or made available to interested and affected parties and the public and that participation by
interested and affected parties is facilitated in such a manner that all interested and affected parties
will be provided with a reasonable opportunity to participate and to provide comments on documents
that are produced to support the application;
I will ensure that the comments of all interested and affected parties are considered and recorded in
reports that are submitted to the competent authority in respect of the application, provided that
comments that are made by interested and affected parties in respect of a final report that will be
submitted to the competent authority may be attached to the report without further amendment to the
report;
I will keep a register of all interested and affected parties that participated in a public participation
process;
I will provide the competent authority with access to all information at my disposal regarding the
application, whether such information is favourable to the applicant or not;
all the particulars furnished by me in this form are true and correct;
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 regulation 71 and is punishable in terms of
section 24F of the Act.
February 2020 19121900-326804-1
Disclosure of Vested Interest (delete whichever is not applicable)
I do not have and will not have any vested interest (either business, financial, personal or other) in the
proposed activity proceeding other than remuneration for work performed in terms of the Environmental
Impact Assessment Regulations, 2014;
I do not have a vested interest in the proposed activity proceeding:
Signature of the environmental assessment practitioner:
Golder Associates Africa (Pty) limited
Name of company:
19 February 2020
Date:
February 2020 19121900-326804-1
Specialist experience
Johan Bothma is a senior land use and closure consultant and project manager with 16 years’ consulting
experience and is currently advancing closure costing and planning for mining and industrial sites, with a
focus on next land use planning and latent risk mitigation. Johan has completed many closure related projects
for a wide variety of different commodity mines in South Africa as well as throughout the rest of Africa and
abroad.
EAP Specialist Assessment Project Experience
Sasol Secunda - Mpumalanga, South Africa (2015; 2017; 2019) - Project manager 2015 and 2017, and
technical review 2019 closure costs updates, for the Sasol Secunda Synfuels and Chemicals
operations complex, including waste disposal, post-closure water treatment and cash flows.
Sibanye-Stillwater Gold Mines - Gauteng, Free State, and Mpumalanga, South Africa (2013 - ongoing)-
Project manager for ongoing closure planning and costs updates for the Kloof, Driefontein, Cooke,
Ezulwini, RUSO, Beatrix and Burnstone operations, including operational rehabilitation planning and
residual costs quantifications.
Sibanye-Stillwater Platinum operations - Northwest Province and Limpopo, South Africa (2017 -
ongoing) - Project manager for ongoing closure planning and costs updates for RPM, Kroondal,
Marikana and Blue Ridge operations, including operational rehabilitation planning and residual costs
quantifications.
Exxaro Arnot Coal Mine - Mpumalanga, South Africa (2016 - ongoing) - Project manager of
comprehensive GN R.1147 compliant closure plan and costs for final closure of Arnot Coal mine,
including qualitative and quantitative risk assessments, residual and latent risk mitigation and costs.
Anglo New Denmark, New Vaal, Union and Goedehoop Mines interim closure planning and costing -
Mpumalanga, South Africa (2013 - 2014) - Project manager/specialist for Anglo Closure Toolbox
interim closure planning for respective Anglo Coal mines, including state of the environment, rapid
strategic environmental assessment, closure criteria, risk assessment, closure costing and next land
use planning.
golder.com
March 2020 19121900-328397-9
APPENDIX N
Comment & Responses Report (CRR)
REPORT
Comment and Response Report for Basic Assessment, Environmental Management Programme Report and Water Use Application for the Proposed Construction of a Pipeline between the Covalent Water Company (old Blyvooruitzicht Mine Workings) and North Boundary Dam AngloGold Ashanti Limited
Submitted to:
John van Wyk Carletonville-Fochville Road R500 Carletonville Gauteng 2501 Submitted by:
Golder Associates Africa (Pty) Ltd. Building 1, Maxwell Office Park, Magwa Crescent West, Waterfall City, Midrand, 1685, South Africa P.O. Box 6001, Halfway House, 1685
+27 11 254 4800
19121900-330348-15
March 2020
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i
Distribution List 1 x electronic copy AngloGold Ashanti Ltd.
1 x electronic copy e-projects library [email protected]
1 x electronic copy Golder project folder
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ii
Table of Contents
1.0 PURPOSE OF THIS DOCUMENT ................................................................................................................ 1
2.0 STAKEHOLDER COMMENTS ..................................................................................................................... 1
2.1 Water ................................................................................................................................................. 2
2.2 General ............................................................................................................................................ 11
TABLES
Table 1: Comments and responses ...................................................................................................................... 2
FIGURES
Figure 1: Planned pumping scenario with new pipeline to NBD (AGA, 2020). .................................................... 8
Figure 2: Current pumping scenario (Capacity) (AGA, 2020). ............................................................................. 9
Figure 3: Blyvoor 5 shaft water pumping at Savuka shaft (AGA, 2020). ............................................................ 10
APPENDICES
APPENDIX A Written Submissions Received
APPENDIX B Wonderfontein Spruit Forum Draft Meeting Minutes – 3rd December 2019
APPENDIX C Document Limitations
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1
1.0 PURPOSE OF THIS DOCUMENT AngloGold Ashanti Limited (AGA) is proposing to install a pipeline of approximately 5km in length and associated surface infrastructure from the old Blyvooruitzicht Mine (currently Covalent Water Company) to the North Boundary Dam. The proposed project will be undertaken by AngloGold Ashanti. The construction of the proposed pipeline and surface infrastructure is intended to allow for dewatering, neutralise and reuse of treated acid mine drainage water as make-up water in the AGA Savuka Gold Plant.
Before proceeding with the planned construction of the pipeline and infrastructure, AGA is required to obtain Environmental Authorisation (EA) under the National Environmental Management Act No. 107 of 1998. The application for EA must be supported by a Basic Assessment (BA) process as outlined in the Environmental Impact Assessment Regulations, 2014 (as amended). A BA and Environmental Management Programme (EMPr) Report will be submitted to the Gauteng Department of Mineral Resources.
AGA furthermore intends to apply for authorisation under the General Authorisation in terms of section 39 of the National Water Act, 1998 (Act 36 of 1998) (NWA) for water uses defined in section 21(c) and section 21(i), GN 509 of 26 August 2016. An application will be submitted to the Department of Human Settlements, Water and Sanitation in quarter 1 of 2020 (assuming all information are available for the application).
AGA has appointed Golder Associates Africa (Pty) Ltd. (Golder) to undertake all the necessary technical investigations and the required EA and water authorisation processes for the proposed pipeline and surface infrastructure construction.
The Draft BA/EMPr was available for public review and comment for a period of 30 days, from Thursday, 10 October 2019 to Monday, 11 November 2019. The report is also available on the following website: https://www.golder.com/global-locations/africa/south-africa-public-documents/ and at the following public places:
Public Place Contact Person Contact Number
Carletonville Library, corner of Celestine and Emerald Streets, Carletonville
Mr Lungile Letshekha Library Manager
018 788 9541
Wedela Library, 5378 Hawk Street, Wedela, Carletonville
Mr Lungile Letshekha Library Manager
018 788 9541
Golder Associates Africa, Midrand, Building 1, Maxwell Office Park, Magwa Crescent West, Waterfall City, Midrand
Mrs Antoinette Pietersen 011 254 4800
2.0 STAKEHOLDER COMMENTS This document records the issues and concerns, questions and suggestions for enhanced benefits raised by stakeholders during the announcement of the project. The comments have been categorised and responded to by members of the Environmental Impact Assessment (EIA) Team and the proponent Table 1.
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2
Table 1: Comments and responses
ISSUE/COMMENT COMMENTATOR REFERENCE RESPONSE
2.1 Water
The information in 6.1.3 of the Draft BA Report is not correct.
Mr Tom Visser Email dated 01 December 2019
Registration and comment sheet dated 22 October 2019
The section 6.1.3 land-use map is based on the existing Geographic Information System (GIS) data sets of the area. Golder will add a note under the figure stating that there may be some variability on the ground.
The information in 6.1.1.9 of the Draft BA Report is not correct.
Section 6.1.1.9 in the Final BA Report will be amended based on the I&AP feedback to read as follows:
“Golder’s ecologist did not observe any farming practices on site, however according to a local farmer, cattle can graze within the area. Golder flagged that the presence of illegal Zama-Zama miners could lead to stock theft, however the local farmer stated that he has not experienced any stock theft in all the years he has farmed in the area”.
Please provide an analysis of the acid water that will be pumped back and whether the cattle will be harmed if they drink the water.
The underground acidic water will be neutralised with lime dosing underground before being pumped to the North Boundary dam. The pH following neutralisation is anticipated to be neutral (i.e. ±pH 7).
Details of the pumped, neutralised water quality will be made available in the Final Basic Assessment Report.
The North Boundary dam will not be fenced, as AGA do not allow any grazing of animals on their property. Adjacent landowners are responsible for the
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ISSUE/COMMENT COMMENTATOR REFERENCE RESPONSE
maintenance of their property boundary fences and must prevent cattle entering AGA’s property, therefore no risk is foreseen.
The North Boundary dam is classified as a process/dirty water dam in the AGA Water Use License.
Telephonic conversation with Antoinette Pietersen during October 2019 regarding the project
The water is pumped into the North Boundary dam via a discharge pipe and is not sprayed.
AGA has six evaporators on top of the North Boundary dam wall that are used to evaporate water during dry periods to ensure that the water level in the dam is maintained below authorised operating level to contain a 1: 50 year rain storm event.
The evaporators will be operated only when the wind direction is north, north-west so that the water drift will settle out over the North Boundary dam and stopped if wind direction is west, south-west and/or south to prevent the water drift settling out outside the dam.
This water will be neutralised to prevent corrosion to pumping infrastructure and thus will not corrode any nearby structures on adjacent properties.
Page 14 of the Draft BA report states that it is now proposed that AGA "Equip BLV #4 Shaft with surface infrastructure to pump approximately 5 Ml/d of Acid Mine Drainage (AMD) water currently reporting at
Mr Victor Nkuna, Email dated
11 November 2019
Currently 5 Ml/d of Acid Mine Drainage (AMD) reports to Savuka Shaft. This water will be pumped underground to Covalent Water Company number four shaft (CWC 4#), be neutralised by lime dosing and will pumped to
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ISSUE/COMMENT COMMENTATOR REFERENCE RESPONSE
Savuka Mine from BLV #5," which will make the abovementioned water use licence redundant. Therefore, AGA needs to clarify their intention in terms of this water use licence since the pumping will now be conducted at #4 Shaft. Furthermore, page 14 states "Provide dedicated infrastructure at BLV #4 to pump the 6.5 Ml/d AMD water to surface separately from the good quality water." The Department requires clarity regarding the correct volume to be pumped between 5 Ml/d and 6.5 Ml/d.
Department of Water and Sanitation
surface and the North Boundary dam. The project will improve the water quality of the water from CWC 4# being discharged to the environment.
Currently 1.5 Ml/d of AMD is being pumped at CWC 4#, that is mixed with the good quality water (approximately 14 Ml/d).
However, there is an opportunity to pump 1.5 Ml/d of AMD with the 5 Ml/d of good quality water from Blyvooruitzicht 5# to surface and the North Boundary dam, totalling 6.5 Ml/d.
It is the company’s intent to surrender the WUL issued to AGA to pump the AMD water at Savuka Shaft from Blyvooruitzicht 5# and amend the current authorisation at CWC to include the additional volumes.
The preferred pipeline routing, the orange route (as indicated by Figure 2), is outside the "wetland areas" and it is the intention of AGA to motivate to the Department of Water and Sanitation (DWS) to reduce the Water Use Licence (WUL) from a full WUL process to a General Authorisation (GA)". The Department advised the mine to thoroughly assess the exclusion contained in the Government Notice (GN) 509 to determine suitability, since the pipeline will conduit Acid Mine Drainage (AMD) water and the
An assessment of the water quality post underground dosing with lime is in process. This assessment will determine the nature of the water which will be presented in the Final BA Report. The relevant authorisation process will be followed after conclusion of discussions with the Department of Water and Sanitation.
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ISSUE/COMMENT COMMENTATOR REFERENCE RESPONSE
associated volumes to be conduit will require a water use licence.
In the Draft BA report, dated September 2019, page 66 states that a General Authorisation application has been submitted to the Department of Water and Sanitation, while the announcement letter dated 10 October states that AGA intends to submit an application for water use under the General Authorisation in terms of section 39 of the National Water Act 36 of 1998 for water use defined in Section 21(c) and Section 21(i), GN 509 of 26 August 2016. An application will be submitted to the Department of Human Settlements, Water and Sanitation”
Please clarify which is the correct statement between the two.
Noted. The notice of intent, which mentions that the GA will be submitted, was compiled prior to more detailed information becoming available. Thus, the information presented in the notice of intent was correct at the time. The GA application was to be submitted to the DWS along with the submission of the Draft BA Report to the interested and affected parties (I&AP’s) for public review. However, due to issues around landowner consent, the GA application was delayed. As a result, the application could not be submitted. The landowner consent issues have subsequently been resolved and the GA application will be submitted to DWS during quarter 1 of 2020.
The Draft BA Report will be amended to state that a GA or Water Use Licence Application (WULA) will be submitted to the DWS for consideration during quarter 1 of 2020.
Page 40 of the Draft BA states that “One of the options for the proposed pipeline route crosses the non-perennial stream called the Wonderfonteinspruit".
Please clarify if this is the Wonderfonteinspruit or the tributary to the Wonderfonteinspruit.
Golder have revisited underlying surface water data sets as well as the naming of the non-perennial streams in the Draft BA Report and surface water specialist assessment. Based on the re-assessment, page 40 of the Draft BA Report will be amended to read as follows:“One of the options for the proposed pipeline
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ISSUE/COMMENT COMMENTATOR REFERENCE RESPONSE
The Wonderfonteinspruit that the Department samples is a perennial stream because of the constant discharges from the mine’s and waste water treatment works.
route crosses the unnamed tributary to the Mooirivierloop”.
Page 60 states that
"The data was sourced from the Water Management Systems (WMS) point 90622 - C2H013, on the Wonderfonteinspruit approximately 24 km downstream of the confluence".
Please note that if this monitoring point is the "Turffontein on the upper Turffontein eye" then the quality at this point is irrelevant to the project area.
Golder’s surface water specialists have revisited the selected monitoring point in the surface water assessment and have sourced data from an alternative monitoring point, 90652 – C2H069, 14 km downstream of the confluence and is considered more representative than 90622 - C2H013. All graphs and table will be updated accordingly in the surface water specialist assessment and Final BA Report.
Page 66 states that:
“The pipeline will serve purely to dewater the Old Blyvooruitzicht #4 and #6 Shafts and transfer the water to the North Boundary Dam".
Please note that the report need to be consistent in the description of the water to be conduit through the pipeline, since an impression is that the AMD water from # 5 Shaft was created and that BLV #4 and #6 Shafts produce relative good quality water that will continue to be pumped and discharged by Covalent Water Company (CWC).
Page 66 of the Draft BA Report will be updated to read as follows “The pipeline will allow for dewatering, transfer of the water to the North Boundary dam, and reuse as make-up water to the Savuka Gold Plant circuit. The proposed pipeline will be surface mounted, above a hill slope seep wetland area;”
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ISSUE/COMMENT COMMENTATOR REFERENCE RESPONSE
The relation between CWC and AGA needs further explanation so that it is known who is responsible for what activity, it is not clear who assumes responsibility for the pipeline (who will be the applicant for the NWA Section 21(c) and (i) water uses) and the pumping of the AMD water (who will be applicant for Section 21) and (a) water uses).
The GA application for authorisation for the pipeline will be undertaken by AGA as the applicant.
I request details of the water quality to be transported in the line as well as a clear indication of the pipeline route if not contained in the draft BA/ EMPr
Mr Grant Stuart
Far West Rand Dolomitic Water Association
Email dated
1 November 2019
The pipeline route is clearly indicated in the map contained in the background information document and site notice. Figure 1, Figure 2, and Figure 3 provide additional clarity on the proposed pipeline and associated underground water abstraction infrastructure.
The water is impacted by old underground workings in the Blyvooruitzicht mine lease area. The estimated 5 Ml of water that will be pumped, daily, has a low pH, which is treated underground through dosing with lime to protect pumping infrastructure. pH of the treated water which will be pumped to the North Boundary dam will be neutral (i.e. ±pH 7).
Details of the pumped, treated water quality will be made available in the Final Basic Assessment Report .
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ISSUE/COMMENT COMMENTATOR REFERENCE RESPONSE
Figure 1: Planned pumping scenario with new pipeline to NBD (AGA, 2020).
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ISSUE/COMMENT COMMENTATOR REFERENCE RESPONSE
Figure 2: Current pumping scenario (Capacity) (AGA, 2020).
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ISSUE/COMMENT COMMENTATOR REFERENCE RESPONSE
Figure 3: Blyvoor 5 shaft water pumping at Savuka shaft (AGA, 2020).
Please clarify the meaning of this statement:
“The construction of the proposed pipeline and surface infrastructure is intended to allow for dewatering, treatment and re-use of treated acid mine drainage water as make-up water in the AGA Savuka Gold plant.”
Mr Victor Nkuna,
Department of Water and Sanitation
Email dated 16 October 2019
The proposed pipeline and surface pumping infrastructure will allow for the removal of the contaminated groundwater as per Figure 1. This water will be neutralised to prevent corrosion to pumping infrastructure (underground prior to the removal) due to its acidity and then pumped to the North Boundary dam.
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ISSUE/COMMENT COMMENTATOR REFERENCE RESPONSE
This water will then be used as a supplementary (i.e. additional) water source for the AGA Savuka Gold plant.
Prefatory to our comments, kindly advise how this application will / is affecting the Blyvoor Gold Mine. We were under the impression – in fact, this was confirmed by the representatives of Blyvoor Gold at the last Wonderfonteinspruit Water Management Forum – that Blyvoor Gold has been authorised to use this water for their processes.
Ms Mariette Liefferink
Federation for a Sustainable Environment
Email dated
12 October 2019
AGA do not envisage that this application will affect Blyvoor Gold’s future planned mining operations. The water that will be pumped from underground is located on the Blyvooruitzicht 5# / AGA West Wits Savuka Mine boundary.
This is AMD water generated at the Blyvooruitzicht 5#, that currently reports via the boundary pillar to the AGA Savuka Mine. AGA Savuka Mine is currently pumping this water at cost to sustain its current mining operations and to prevent flooding from neighbouring mines.
2.2 General
The statement in 6.1.1.9 is not true. Cattle are farmed and the information is wrong. In 5-years the Zama's neither stole nor slaughtered any cattle. I don't know where this information comes from.
Mr Tom Visser Email dated 01 December 2019
Registration and comment sheet dated 22 October 2019
Section 6.1.1.9 in the Final BA Report will be amended based on the I&AP feedback to read as follows:
“Golder’s ecologist did not observe any farming practices on site, however according to a local farmer, cattle can graze within the area. Golder flagged that the presence of illegal Zama-Zama miners could lead to stock theft, however the local farmer stated that he has not experienced any stock theft in all the years he has farmed in the area”.
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ISSUE/COMMENT COMMENTATOR REFERENCE RESPONSE
The Department on a quarterly basis convene forum meetings to discuss water management issues within the Wonderfontein Spruit Forum. The proposed activity closely relates to the work of the forum and the Department will appreciate if the proposed activity can be presented at the forum as part of the stakeholder engagement.
The next meeting is scheduled for the 3rd of December 2019 at AngloGold Ashanti at 10:00.
Mr Victor Nkuna,
Department of Water and Sanitation
Email dated
11 November 2019
Comment noted and AGA will attend the next Wonderfontein Spruit form meeting scheduled 3rd December 2019.
AGA presented the proposed project to the Wonderfontein Spruit forum on Tuesday 03 December 2019. The draft minutes of the meeting is attached to this Comment and Response Report as APPENDIX B.
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Signature Page
Golder Associates Africa (Pty) Ltd.
Adam Bennett Antoinette Pietersen Senior Environmental Consultant Public Participation Task Lead
AB/AP/jep
Reg. No. 2002/007104/07 Directors: RGM Heath, MQ Mokulubete, SC Naidoo, GYW Ngoma Golder and the G logo are trademarks of Golder Associates Corporation https://golderassociates.sharepoint.com/sites/108123/project files/6 deliverables/final client deliverables/final pp documents/19121900-330348-
15_rep_pipeln_ba_ga_crr_final_6mar20.docx
March 2020 19121900-330348-15
APPENDIX A
Written Submissions Received
From: PPOfficeTo: Pietersen, Antoinette; Qinisile, Mabel SesiSubject: FW: BASIC ASSESSMENT AGADate: Wednesday, October 16, 2019 4:22:05 PM
From: Nkuna Victor (GAU) <[email protected]> Sent: 16 October 2019 15:54To: PPOffice <[email protected]>Cc: Chawane Portia Nkosimani (GAU) <[email protected]>Subject: BASIC ASSESSMENT AGA
EXTERNAL EMAIL
EXTERNAL EMAIL - We could not verify the authenticity of this message. Please be cautious when clicking on links or opening attachments.
Dear Antoinette Pietersen The below statement is an extract from your BID document. Please help me to understand the meaning of the statement. “The construction of the proposed pipeline and surface infrastructure is intended to allow for dewatering, treatment and reuse oftreated acid mine drainage water as make-up water in the AGA Savuka Gold plant” Regards Nkuna VictorGauteng Provincial OperationsPrivate Bag X 995Pretoria0001 Tel No: 012 3921300/1484Cell No: 0829236976/0826039991Fax No: 012 3921359
DISCLAIMER: This message and any attachments are confidential and intended solely for the addressee. If you have received this message in error, please notify the system manager/sender. Any unauthorized use, alteration or dissemination is prohibited. The Department of Water and Sanitation further accepts no liability whatsoever for any loss, whether it be direct, indirect or consequential,arising from this e-mail, nor for any consequence of its use or storage.
From: PPOfficeTo: Qinisile, Mabel SesiSubject: FW: Notification: AngloGold Ashanti BA, EMPr and WULA: Proposed Pipeline, CarletonvilleDate: Monday, October 14, 2019 2:53:56 PM
From: Ria Barkhuizen (NR) <[email protected]> Sent: 14 October 2019 14:47To: PPOffice <[email protected]>Subject: RE: Notification: AngloGold Ashanti BA, EMPr and WULA: Proposed Pipeline, Carletonville
EXTERNAL EMAIL
Good dayThis email is an acknowledgement of receipt for your enquiry.Please note that your enquiry will be evaluated and a response provided within 60 days, in line withrequirements of Section 29 of the Spatial Planning and Land Use management Act (Act No.16 of2013) read with Section 3 of the Promotion of Administrative Justice Act (Act No.3 of 2000).Should you not receive any response within 60 days, kindly follow up on the enquiry by respondingto Jan Oliver who will be dealing with it and will convert back to you. He can be contacted on (012)426-6200 / 6242. Tx and Regards
From: PPOfficeTo: Qinisile, Mabel SesiSubject: FW: Notification: AngloGold Ashanti BA, EMPr and WULA: Proposed Pipeline, CarletonvilleDate: Monday, October 14, 2019 9:09:22 AM
From: Mariette Liefferink <[email protected]> Sent: 12 October 2019 16:32To: PPOffice <[email protected]>Subject: RE: Notification: AngloGold Ashanti BA, EMPr and WULA: Proposed Pipeline, Carletonville
EXTERNAL EMAIL
Dear Mabel
Prefatory to our comments, kindly advise how this application will / is affecting the Blyvoor GoldMine. We were under the impression – in fact, this was confirmed by the representatives of BlyvoorGold at the last Wonderfonteinspruit Water Management Forum – that Blyvoor Gold has beenauthorised to use this water for their processes.
Please clarify.
Best RegardsMariette LiefferinkCEO: FEDERATION FOR A SUSTAINABLE ENVIRONMENTTEL. (+27) 11 465 6910(+27) 73 231 4893Postnet Suite #113, Private Bag X153, Bryanston, 2021E-MAIL: [email protected]: 0864861363
From: PPOffice <[email protected]> Sent: 10 October 2019 11:40 AMTo: Mariette Liefferink <[email protected]>Subject: Notification: AngloGold Ashanti BA, EMPr and WULA: Proposed Pipeline, Carletonville
Dear Mrs Mariette Liefferink Please see attached the announcement letter, registration and comment sheet and locality map for theabovementioned application for Environmental Authorisation and Water Use Licence for the proposedpipeline between the Covalent Water Company (Old Blyvooruitzicht Mine Workings) and AngloGoldAshanti Limited North Boundary Dam, Carletonville, Gauteng. Should you wish to obtain more information or comment, please contact me at (011) 254 4800, fax 086582 1561 or email: [email protected] regards,Mabel Sesi QinisileStakeholder Engagement Specialist Golder Associates Africa (Pty) LtdBuilding 1, Maxwell Office Park, Magwa Crescent West, Waterfall City, Midrand, 1685 P.O. Box 6001,
Halfway House, 1685 T: +27 11 254 4800 | Email: [email protected] | golder.com LinkedIn | Facebook | Twitter
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APPENDIX B
Wonderfontein Spruit Forum Draft Meeting Minutes – 3rd December
2019
1
KROMDRAAI CATCHMENT
Minutes of the Wonderfontein-/Loopspruit Forum Meeting
Date: 03 December 2019 Time: 10:00 Venue: AngloGold Ashanti Limited-West Wits Village Club Auditorium
MINUTES OF THE MEETING Chairperson: Ephraim Matseba (EM) Present
Surname and Initials
Affiliation Contact Number
Email Address
Chawane P (PC) DWS 082 324 5144 [email protected]
Makhari TG (TM) DWS 012 392 1505 [email protected]
Gebhardt Z (ZG) DWS 012 392 1353 [email protected]
Nqelenga L (LN) DWS 012 392 1505 [email protected]
Grond E (EG) AGA 018 700 2002 [email protected]
Van Wyngaarden Z (ZV)
Afarak Mogale 082 573 9141 [email protected]
Mannya ML (MM1) Lafarge 067 132 3124 [email protected]
Ndzilane PM (PN) Merafong City LM 078 544 5844 [email protected]
Penyenye HP (PP) Merafong City LM 073 360 9953 [email protected]
Sondela D (DS) Merafong City LM 083 283 7733 [email protected]
Zwart J (JZ) Merafong City LM 082 552 4710 [email protected]
Loots A (AL) Merafong City LM 018 788 9082 [email protected]
Khoza ML (LK) Merafong City LM 0719613009 [email protected]
Mathedimosa H (HM)
DWS 012 392 1350 [email protected]
Matseba EM (EM) DWS 012 392 1374 [email protected]
Mulaudzi AC (CM) DWS 012 392 1350 [email protected]
Liefferink M (ML) FSE 073 231 4893 [email protected]
Sidogi M (MS) DWS 012 392 1371 [email protected]
Makwela M (MM2) Minerals council 011 498 7100 [email protected]
Marie E (EM) Mogale City LM 083 767 1902 [email protected]
Esterhuizen J (JE) Mogale City LM 083 280 2432 [email protected]
Gewers N (NG) Sibanye Gold Limited
011 278 9749 [email protected]
Nealer E (EN) UNISA 082 876 7397 [email protected]
Maluleke J (JM) Corobrick 073 324 5565 [email protected]
Mabe N (NM) DWS 082 721 1653 [email protected]
Mnyaka A (AS) DWS 082 722 4834 [email protected]
Sithole S (SS) DWS 012 392 1473 [email protected]
Sekgale JP (JS) DMR 011 358 9770 [email protected]
Shibambo A (AS) DWS 012 392 1349 [email protected]
2
Surname and Initials
Affiliation Contact Number
Email Address
Makgoba KP (PM) DWS 066 377 5791 [email protected]
Zwart AR (RZ) WRDM 082 425 3478 [email protected]
Nyama LJ (LN) DWS 012 392 1369 [email protected]
Maphosa CP (CM) DWS 012 392 1388 [email protected]
Jenner D (DJ) Blyvoor Gold 082 875 9430 [email protected]
Lamsley L (LL) Blyvoor Gold Mine
082 550 3484 [email protected]
Wels S (SW) Blyvoor Gold Mine
079 841 8490 [email protected]
Fourie J (JF) Representative Blyvoor Liquidator
082 280 7944 [email protected]
Horak D (DH) 083 267 1350 [email protected]
Harmse J (JH) CWC 018 700 3400 [email protected]
Mangena SW (WM) His Will Innovations
073 686 2034 [email protected]
Van wyk J (JV) AGA 083 682 4089 [email protected]
Human C (CH) AGA 082 828 1518 [email protected]
Tshamano M (MT) Harmony Gold 018 782 9276 [email protected]
Makhuvha L (LM) Harmony Gold 018 782 9543 [email protected]
Barnand R (RB) Harsco Environmental
071 670 7244 [email protected]
Geyer G (GG) Harsco Environmental
082 741 3086 [email protected]
Nonjola V (VN) NNR 012 001 8437 [email protected]
Mogoru J (JM) NNR 076 712 8099 [email protected]
Tlale S (ST) TCTA 012 683 1200 [email protected]
Luthuli M (ML) TCTA 012 638 1226 [email protected]
1. Opening and Welcome EM welcomed all attendees and thanked them for coming to the last Wonderfonteinspruit Forum meeting of 2019. EM then declared the meeting open. 2. Attendance and Apologies EM requested all attendees to introduce themselves and complete the attendance register, which was being circulated. EM added that the documents that all attendees should have was a copy of the agenda, the DWS water quality report and the previous meeting minutes. Apologies:
Lee Davis Ellis - Harsco
Karlien de Villiers - DWS
Willem De Lange - GDARD
Stephan Veldsman - GDARD
Eric Stoch - Community representative
3
Prof Shepherd Molefane - UNISA
Jurgo van Wyk - DWS
Mashudu Mukwevho - DAFF
David - Blyvoor
Simone Liefferink - SGL
Elise - Harsco
3. Approval of the Proposed Agenda The agenda was accepted with the following additions: 9.1 Minutes of the previous meeting 9.2 Video from Eric Stoch (ES) 9.3 Terms of Reference for Wonderfonteinspruit Forum Meeting 9.4 Local Map 9.5 Lounge of the Minister of DWS master plan 9.6 Sustainable development goal six 4. Minutes of the Previous Meeting EM proceeded page by page through the minutes in order to note any suggested corrections. Agenda item under 6.2: Water quality to be presented by Mr H Pretorius. It was corrected to water quality to be presented by Simone Liefferink(SM). Page 11: ML was concerned about the pollution incidents listed on Page 11 that were still on-going; particularly incident number 4, the Mintails-Lancaster Dam Wall. ML asked why there was no enforcement action being taken to resolve this incident. EM said that pollution incidents would be reported under agenda item 7.2. ML noted that on page 11 the first paragraph, PC had said that 1-4 in the table of pollution incidents on the minutes of 02 September 2019 had been long standing items and was on-gong: Wedela WWTW, Blyvoor Village Sewer spillage, Khutsong WWTW and Mintails-Lancaster dam wall. ML asked who was responsible for resolving these incidents at the DWS. EM responded and said that there was a court case regarding the Mintails case and that he would respond on the issue before the end of the meeting. Page 12: paragraph number 4, ML said that she wanted to return to item 4 which was still on-going. ML said that the Mintails Directors were now overseas, and ML asked how the DWS intended to enforce the pre-directive when the directors were overseas. EM said that DWS Provincial Office had requested advice from DWS Legal Services regarding the Mintails regulatory process; since Mintails had gone into liquidation, to whom should the Directive be issued. ML noted that Mogale Gold had not been liquidated. It should read as follows: ML said that although some of Mintails Directives were overseas, DWS intended to enforce the Pre-Directive as Mogale Gold (a subsidiary of Mintails) was still operating under mining 206 and had not been liquidated. ML said she would send the correction information to the DWS. Page 13: 7.4 paragraph 2, ML apologised that she had not been able to attend the Mooi River Forum. ML added that there was dilution coming from Bovenste Oog. Should read
4
as follows: ML said that Bovenste Oog provides dilution to the Wonderfonteinspruit, as the eye flows into the Wonderfonteinspruit. Page 14: Point number 9 paragraph 1, EM said that an advisory committee had been appointed under the previous administration, but as there was a new administration DWS: Gauteng Province had sent a submission requesting that the new administration continue with the previous appointees, appointed under the previous administration. EM corrected this and said that DWS Gauteng Region referred to Head Office colleagues that had done the submission, the submission did not come directly from the Province. With the above corrections the minutes of the meeting held on 03 September 2019 were adopted as a true reflection of the meeting. 5. Matters Arising from the Minutes of the Previous Meeting Addressed and New Actions
No Action Progress Responsible Person
1 DWS to report on the status of the State Co-ordinating Technical Committee (SCTC) submission to the Director General (DG).
Feedback will be given in the next meeting.
EM
EM said that the relevant invitation letters had been sent to the following five entities:
Council for Geo-science (CGC), Sibanye Stillwater, Department of Mineral Resources
and Energy (DMRE), Department of Environmental Affairs (DEA) and Mineral Council
South Africa. EM said that the DWS had not received any responses as of yet, other than
Sibanye Stillwater. The invitation would be resent and therefore the action was still on-
going.
No Action Progress Responsible Person
2. All water users to send their Water Quality (WQ) reports to the DWS for circulation to the Forum members.
Feedback will be given in the next meeting
All Water Users
PC said that not all water users had submitted their WQ reports to DWS. The following
companies submitted their WQ reports to DWS:
Blyvoor Gold Capital
Harmony Gold Mine
Harsco Ilanga Metals
Sibanye Gold Limited: Kloof, Driefontein and Cook Mines
Covalent Water Company
AngloGold Ashanti (AGA) Limited
Flip Human Waste Water Treatment Works (WWTW)
5
Further to this, PC said that the following companies had not submitted their WQ reports
to the DWS:
Lancaster Gold Mine
Mogale Afarak
Lafarge Company
Rand West City Local Municipality (Hannes Van Niekerk WWTW)
Merafong City Local Municipality (Wedela, Welverdiend, Khutsong and Oberholzer
WWTWs).
Morgan Greek Properties (Cooke and Deelkraal WWTWs)
Corobrik
Middelvlei Mine
MM1 said that they had submitted their water quality results but that the results were for
September 2019. EM said that every Forum meeting, water users should send the
previous quarter’s water quality reports, which meant that there should be four water
quality reports every year. Further to this, EM said that all water users were required to
comply by sending their water quality reports to DWS. PC said that Harsco Ilanga should
summarise and compare their water quality results in terms of their Water Use Licence
(WUL) limits to measure compliance and then send the results to the DWS.
No Action Progress Responsible Person
4. MCLM to provide an update on their action plan in terms of repairing the vandalised Waste Water Treatment Works (WWTWs).
Action addressed Merafong Municipality
EM asked AL if there was any action plan regarding Merafong City Local Municipality
(MCLM). AL said that the action plan was available and that he had reported the action
plan to many people, however he noted that as there were no funds available the action
plan could not be implemented. AL said that Rand Water had offered to assist the
Municipality by funding some of the projects. Rand Water had requested the municipality
to provide them with a list of all the WWTWs that were not functional, including a list of
the repairs required at each plant.
AL said that the WWTWs that needed to be repaired were: Wedela, Oberholzer,
Khutsong, and Welverdiend. AL said that he had provided Rand Water with a schedule of
the equipment that was broken or no longer functional. AL said that he had had to source
quotations for new equipment from companies willing to work at all the WWTWs. Those
companies should first look at exactly what needed to be repaired and provide accurate
quotations based on their site assessment. AL said that Rand Water had been receiving
quotations piece by piece but was waiting to take a decision because the process of
obtaining quotations had taken so long. AL said that it took approximately three months
to get one quotation. AL said that Oberholzer WWTWs repair costs were ~R3 million,
according to the quotation he had received, excluding the fencing which was an
6
additional R1 million. AL added that it was pointless to repair the equipment or the Plants
when the WWTW sites were not secured.
AL said that there was a new residential development called Elijah Bagai that was
currently being developed in Welverdiend. The Elijah Bagai residential development was
developed by Department of Human Settlement and they had certain social
responsibilities. AL said that the developer had a service level agreement in place which
had committed over R3.5-5 million for the repair of Khutsong and Welverdiend WWTWs.
AL said that he was not sure about the time frame in terms of the delivery of services to
the WWTWs. AL said that Welverdiend WWTWs would receive a portion of domestic
waste water generated from the Elija Bagai residential development. AL said that Elija
Bagai development was currently on Phase 1 and this phase would discharge waste
water to Welverdiend WWTWs. Elija Bagai development was currently upgrading the
Welverdiend WWTW so that it could accommodate the waste water from the residential
development.
AL said that Wedela WWTW would receive R15 million from DWS: Water Service
Infrastructure Grant (WSIG) funding, however R25 million was needed to refurbish the
whole plant. AL said that they weren’t sure how they would obtain the remaining R10
million required for the repair. AL said that a tender briefing would take place on Friday
the 06th December 2019. AL said that they planned to request the extra R10 million from
the DWS at the briefing. AL said that he had requested assistance from Rand Water and
other companies for fencing at Wedela WWTWs. EM said to AL that an action plan
should have due dates and a budget. EM said that when the Municipality get funding
from the DWS, the DWS expected them to top-up by sourcing from other organisations.
LN said that the DWS should congratulate MCLM because they managed to source
additional funding, after a long time of struggling to find funding.
EM advised organisations that were willing to assist MCLM that they should not transfer
funds to MCLM but rather they should visit the WWTWs, access the plant and then fix
what need to be fixed. AL said that they had experienced theft over the past 6-7 years
and that their biggest fear was theft of the new equipment because their fences always
got stolen. AL said that even if there was security in place, their fences got stolen and
when they tried to make insurance claims, meeting all the requirements, their claims
were still rejected. AL said that theft was a concern and if they did not produce enough
proof the insurance would not pay out. AL reported that there was a certain period where
there was a change-over of security company’s and MCLM had not been protected and
therefore theft had taken place. AL said that there had also been a few months when the
Municipality had not paid the insurance premiums, so when theft had taken place, they
were not able to claim, which resulted in an additional repair expense that the
Municipality had not always budgeted for. AL said that at his office he made sure that
they adequately budgeted for operational and maintenance costs. AL said that the rule of
thumb was that “you should budget 5-7% of value of the equipment for maintenance
purposes”.
7
No Action Progress Responsible Person
5 DWS to provide an update on their action regarding the funding programme in order to assist MCLM.
Action Addressed EM
EM said that the DWS was currently funding two projects under Accelerated Committees
Integrated Programme (ACIP) funding, the first one was the construction of portable
water reservoir at MCLM and the second one was the Wedela WWTW refurbishment.
DV from DWS was not present but sent an apology. ZG said that Ayanda Mtwetwa (AM)
from DWS had reported at the Klipspruit Forum Meeting that the long term solution of
EIA process had been put on hold and that they were investigating other more affordable
treatment technologies/ options for the long term solution.
ML said that she had a presentation in which the AMD long term solution was discussed/
presented. The master plan included the augmentation of desalination of AMD. It was
indicated that there needed to be a recalibration of the salinity and hydrology model and
an investigation of the Vaal River System high salinity before the long term solution could
be implemented. However, short term treatment would continue. ML further said that
there was 362 tonnes of Total Dissolved Solids entering the Vaal River System because
of the short term solution. ML said that she would forward the presentation of the AMD
long term solution to the DWS for circulation to stakeholders.
EM said that they had a discussion with DWS Legal Services and a legal opinion had
been received that the culprits should be pursued and it would be guided by lawyers that
No Action Progress Responsible Person
6 ST to provide an update on the appointment of the engineers for the Acid Mine Drainage (AMD) long term strategy
Action Addressed ST
No Action Progress Responsible Person
7 ML to send the presentation of the AMD
long term solution to the DWS for
circulation to stakeholders.
Feedback would be given in the next meeting
ML
No Action Progress Responsible Person
8 DWS to consult DWS legal service for guidance regarding the next step in the enforcement process since Mintails had been placed under provincial liquidation.
Action Addressed PC
8
would be appointed by the state attorney. EM said that he would have liked to circulate
the information that had been received from the DWS Legal Services but would not be
possible, as the communication had been directed to the Minister. VN said that the
information sent was classified or confidential and it therefore could not be circulated. ML
said that the court case was set for August 2020. ML said that illegal miners were
scavenging all remaining infrastructure from the mine, and that there was nothing left. ML
added that illegal miners were now scavenging the support structures of the main reef
bridge, which was likely to collapse.
LN said that the action would be addressed under the agenda item 7.5.
ML said that she had a discussion as it was indicated in the paragraph of the action that
reads as follows, “If DWS took a mine to court then they need proof beyond reasonable
doubt that there was a pollution of water resources occurring”
EM said that he was not a Lawyer but a person can consult to five different lawyers and
still get five different opinions.
6. Presentations
6.1. Water Quality-Anglo Gold Ashanti Limited-West Wits Mine
CH presented the water quality report for Anglo Gold Ashanti (AGA) – West Wits,
Savuka, CWC and pipeline authorisation process. AGA was currently operating Mponeng
shaft and Savuka and Tau Tona were under orderly closure. At Covalent Water
Company (CWC) they were pumping ground water from the liquidated Blyvooruitzicht
shafts 4 and 6, which was being discharged into the Wonderfonteinspruit (see
presentation attached).
CH said that AGA had submitted an amendment in 2012 which included a new Pollution
Control Dam (PCD) at Mponeng. CH said that they also wanted a cost effective way to
pump the CWC water. ML asked what the possibilities were of “zama zamas” targeting
the proposed CWC pipeline to AGA. CH replied and said it would be quite unlikely;
however they would have the necessary security. ML asked what impact the water would
have on the environment if the pipeline was damaged. CH said that the mine needed that
water in their process and so the pipeline would be fixed as fast as possible. CH said that
the water was partially treated underground, so as long as there was a short spillage the
impact would be minimal.
ML asked what “orderly closure” meant. CH confirmed that all the mines were under one
mining right and so they couldn’t apply for formal closure until Mponeng shaft was ready
No Action Progress Responsible Person
9 LN to present enforcement action taken within the WFS.
Action Addressed LN
9
to close. CH said that they called orderly closure because the shafts were under care
and maintenance.
ML asked what the gooseneck at Elandspruit discharge point was. CH said that in the
spruit there was a clean water dam, which was used by the farmers but had nothing to do
with the mine.
ML asked what would happen after the 25 years lease period at CWC ended. CH said
that the mine had not accepted any liabilities for the Blyvooruitzicht mining compartment;
they were only required to pump to keep AGA dry. CWC had the option to extend the
contract for the first 25 years and after that CWC had the first option to continue for
another 25 years, should they want to. He further said that after 50 years the owner of
that land could choose another contractor should they wish to.
PC requested AGA to use their WUL conditions or limits when presenting their WQ
results. PC stated that CH should amend the presentation and send to the DWS for
circulation. LL asked how they kept the clean and dirty water separate. CH and JH
explained that they would use boreholes and separate pumps to keep the clean and dirty
water separate.
7. Catchment Issues
7.1 Licence Status
HM presented the licence status as follows:
No Application Application date
Water Uses Status
1. Lancaster Gold Mining Company
2019/05/27 Section 21 (g)& (a) Closed
2. Middelvlei Minerals (Pty)Ltd: Middelvlei mine
2019/06/19 21(c ),(i),(a),(j)&(g) Withdrawn
3. Sibanye Gold Limited Driefontein
2019/08/26 21 (c)& (i) Finalised
4. Divine Inspiration Trading 783
2019/09/18 Section 21 (a) Finalised
5. Quantum Foods (Pty ) Ltd
2019/11/27 21(a); (e); (g) & (i) Initial Assessment
6. African Spartan (Pty ) Ltd
2019/11/07 21(c) & (i) Initial Assessment
7. Rand Uranium (Pty) Ltd: Cooke Operation
2018/01/09 21(i) Finalising Assessment
8. Ariobex (Pty) Ltd 2019/01/30 21(c) &(i) Finalising Assessment
9. Anglo Gold Ashanti 2018/08/12 21(a) (e);(f);(g ); (j); (c ) & (I )
Awaiting WUAAAC presentation
10. Randfontein Estate Limited: Harmony
2018/07/09 21(f) ( a ) Finalising Assessment
10
Mine, Kusasalethu Operation
HM said that she had sent the WUL status spreadsheet to the Wonderfonteinspruit
Forum with a small update. CH asked what the status of the AGA amendment application
was. EM said that if amending a licence became difficult, he always advised that people
should apply for an integrated licence so that the new water uses would be incorporated
into the existing licence. EM further said that if water users had a new water use, they
should only update a report and then apply for a new licence, which made the process
much easier. HM said that the WUL amendment was the issue. EM asked CH when the
expiry date of their old licence was.
ML asked what the turnaround time for an amendment of a WUL was, or even a standard
Water Use Licence Application (WULA), because according to her own understanding it
was 300 days, but according to the law that has been lodged by the Minister it says 49
days. EM said that it was possible to meet the legislated 300 day timeframe as long as all
the correct technical documentation was submitted. EM advised that before preparing
technical documents, stakeholders should first consult with the DWS.
LN said that if stakeholders were doing one (1) licence they should focus on it alone in
order to meet those 49 days.
ML asked if it would be possible to process a WUL within 49 days because the
documents still needed to be assessed by DWS.
MM said that the time frame of 49 days was recommended by the task team that was
constituted by the Minister herself.
HM said that she was aware of a proposed 100 day timeframe but she wasn’t sure how
the 49 day timeframe would work. HM said that during a meeting with the Deputy
Director General (DDG) Road show, it was mentioned that the days would no longer be
calculated including site inspections; the timeframe would start once an applicant
submitted all required technical information. HM said that previously the timeframe
started when an applicant submitted an application to the Department, following which
the site visits, technical information and assessments would be included into the
timeframe. It was indicated that, going forward, only once an applicant submitted all
technical documentation would the system start counting the 100 days. Further to this
HM explained that if the information was insufficient it would be rejected automatically.
ZG said that during the meeting with the DDG Road show, they said that the 100 days
was not yet gazetted, only proposed.
EM said that they would wait for the gazette and public comments.
11
7.2 Pollution incidents PC presented the following pollution incidents that had occurred in September 2019 to November 2019.
No Name of Activity
Date of Incident
Nature of incident Action Taken
1. Merafong City Local Municipality - Wedela WWTW
On-going WWTW vandalized Directive issued
2. Blyvoor Village sewer spillage
On-going No functional WWTW Pre-directive issued
3. Merafong City Local Municipality -Khutsong WWTW
On-going May 2019
Electric panel vandalized and during April 2019 there was further vandalism of the power transformer.
On-going
4. Mintails -Lancaster dam wall
On going Dam wall leakage Pre-directive issued
5. Harmony Mine 15 November 2019
Blockage of sewer manhole
Manhole was unblocked
6. Merafong City Local Municipality
07 November 2019
Disposal of effluent from Oberholzer WWTW into dams next to Living Gold
The sluice valve was closed on 12 –November-2019
7. Anglo Gold Ashanti - Slurry
02 September 2019
Release of slurry and process water into the environment.
Plant was stopped and cleaning of slurry was on going
VN presented Pollution incidents of Wonderfonteinspruit Catchment from Sep-Nov 2019
incidents. He said that there were four pollution incidents namely: Khutsong WWTW,
Wedela WWTW, Blyvoor village and Mintails: Lancaster Dam wall, which would be on-
going for some time going forward.
VN reported that there were new pollution incidents; he said that at Harmony Gold Mine
on 15 November 2019, the DWS identified a manhole spillage which was flowing into the
environment towards the water resource. The spillage had been going on for some time
but they had managed to find out where the source of the pollution was coming from. VN
said that they followed the pollution incident to the source and after reporting the issue to
the mine, the mine had managed to resolve the issue.
VN reported that Living Gold Rose Farm, which was using MCLM: Oberholzer WWTW
effluent to irrigate their roses, had been liquidated in April 2019. The Municipality had not
shut down the water supply and they continued supplying waste water to the farm even
though the rose farm was not operational. The effluent was being diverted into historic
dams near to Living Gold. VN said that the MCLM had subsequently closed the pipes
12
that were providing the supply but unfortunately the dams were already filled with waste
water. VN said that the MCLM incident report indicated that they did not have funds to
pump out the effluent from those dams. The dams were historic and were located on
properties which fell under the ownership of the Far West Rand Dolomitic Association.
VN said that a pollution incident occurred at AGA on 02 September 2019, where there
was a slurry spillage from their PCD. The DWS had a meeting with the mine on 15
November 2019 and the mine was still in the process of cleaning the affected area.
VN said that a pollution incident had occurred at Sibanye Gold Limited: Kloof Operation
on 16 October 2019, where there was a slurry spillage from a pipeline which transported
slurry from Kloof Plant No 1 to Tailing Storage Facility No 2. The DWS conducted an
inspection on 17 October 2019 of the affected areas and noted that the mine was in the
process of removing the surface pipeline and burying it underground, as the pipeline had
been known to experience problems resulting in slurry spillages.
VN said that at the Welverdiend area there were regular manhole blockages and the
MCLM had indicated that “zama zamas” were known to be vandalising the pump station.
The Welverdiend pump station was not pumping raw sewage into the Welverdiend
WWTW due to vandalism and this has resulted in raw sewage overflowing into the
manholes towards the water resource.
VN said that ES had raised a complaint regarding the water quality at the end of the one
meter pipeline, as there was a smell of sewage and sludge. VN said that the one metre
pipeline was a closed system but that there were WWTWs upstream that were allowed to
discharge into the one meter pipeline. The WWTW at the end of the one meter pipeline
was Hannes Van Niekerk. VN said that Hannes Van Niekerk WWTW had been
vandalised in April-May 2019 and the WWTW was therefore only partial treating the
waste water, as most of the units at the WWTW were not operating due to stolen
electrical cables at the plant. The WWTW has since been repaired but in terms of
recovery of the processes at the WWTW, there were certain unit systems that were still
not operational, which may have resulted in sewage pollution occurring within the one
meter pipeline. VN said that the DWS monitored the end of the one metre pipeline on a
monthly basis and the results would be presented under agenda item 7.4.
ML asked why Living Gold Rose Farm had been liquidated since it was part of Sibanye
Gold Limited (SGL). ML also asked what the impact to the ecosystem was, as a result of
the pollution, since the pollution had been on-going for many years. ML asked what the
quality of the associated water was.
VN said that DWS met with the liquidator representative on 07 November 2019, and he
had reported that there had been a labour relation dispute at Living Gold Rose Farm after
the SGL strike/protest had been resolved. The farm workers requested that they get the
same increase that the miners had been offered, following the SGL settlement. VN said
that when Living Gold Rose Farm responded to the workers that they could not afford the
increase the workers had sabotaged the rose farm by poisoning the water that irrigated
the roses and all the roses had died. Following that the Living Gold Rose Farm had not
13
operated and applied for court-mandated liquidation. VN said that the issue of the dams
was that they were historical and were used for other purposes and did not belonging to
Living Gold Rose Farm. During profitable operation at the rose farm there had been an
option to bypass the farm and dispose the water into the dams. VN said that the dams
did not having pre-exisiting aquatic ecosystems, and were only full due to the rose farm
directing the effluent of Oberholzer WWTW to the dams.
ML asked which Catchment Management Agency (CMA) the Harmony Doornkop Mine
operations fell within VN said that it fell within the Klipspruit.
ML said that in the Bekkersdal area there was formal and informal settlements
downstream of Donaldson Dam and at the beginning of the one meter pipeline. ML noted
ponding water at the beginning of one meter pipeline, which she said may accelerate
sinkhole formation because the area was dolomitic. In that area the water was piped into
the one meter pipeline to prevent the acceleration of sinkhole formation. However, even
though it was the dry season there was ponding of water before the pipeline. ML asked
what the source of water was. VN said that the DWS would have to investigate further.
VN said that when there was flooding, the water flowing from Donaldson Dam could not
be accommodated at the start of the pipeline and it would therefore overflow through the
spill way of the dam, into a stormwater channel to the beginning of one meter pipeline,
where it would pool.
7.3 Update Report from Stakeholders
Nothing reported.
7.4 Water Quality Results Reporting
PC presented the water quality report for Wonderfonteinspruit for August-October 2019.
The colour coding was explained as follows: blue was ideal, green was acceptable,
yellow was tolerable and red was unacceptable. The monitoring points were sampled
monthly and included water resources, mine discharges and municipality discharges.
There were also two eyes (Upper Turffontein eye and Gerhard Minnebron) that were
monitored/sampled every quarter. The limits used were WUL limits, general authorisation
limits, and Instream Water Quality Objectives (WQO). Uranium sampling was conducted
every quarter.
The first point was WFS downstream of Lancaster Dam. This was where historical mining
operations were located and denoted the origin of the WFS. This point had a challenge
with regard to manganese, and the source of the manganese was still unknown.
Ammonia and Ecoli were also high due to sewage spillages in the area. PC said that ML
had indicated in the previous Forum meeting that there had been a manganese
company/dump that used to operate in that area. PC requested ML for the contact details
of a person who could assist DWS in terms of identifying the manganese source. ML said
that the Harsco Ilanga Company had sent their water quality report, which had indicated
a decrease in Manganese, which was an improvement. PC requested Harsco Ilanga to
present their water quality in the next Forum meeting of March 2020. PC reported that
14
the point at Wonderfonteinspruit Azaddville Bridge was impacted by the manganese at
the first point.
The water quality of Flip Human WWTW was not compliant as ammonia (NH3) and
faecal coliform count were elevated. The Flip Human WWTW was not chlorinating hence
the faecal coliform count being elevated. Wonderfonteinspruit at Luipaardsvlei point was
impacted by sewage as ammonia; orthophosphate (PO4) and faecal coliform count were
elevated. The Flip Human WWTW was also impacting this point due to its sewage
discharge.
PC said that Electrical Conductivity (EC), sulphate, uranium and manganese were
elevated at Sibanye Gold Limited: Cooke shaft 1 discharge sampling point. PC said that
Sibanye Gold Limited: Cooke Operation should provide a plan to DWS, which would
address the variables of concern. PC said that the mine should also investigate the
source of manganese as this was the first time it was found to be elevated at their
sampling point.
PC said that Donaldson Dam and Gemspost sampling points were impacted by sewage
spillages, mines and illegal mining. PC corrected the mistake of 0 faecal coliform count
for August 2019 at Gemspost sampling point, which was highlighted in red
(unacceptable), but should have been green (acceptable). The water quality of Hannes
van Niekerk WWTW was not compliant as ammonia, faecal coliform count and Chemical
Oxygen Demand (COD) were elevated and the WWTW was not operational as a result of
vandalism (cable theft). During September 2019 sampling, there was no access at the
WWTW as they had installed electric fencing on the gate and it was locked. However,
recently they have managed to open an alternative access road for sampling.
PC said that the water quality of Sibanye Gold Limited: Driefontein Mine points was of
good quality except in September and October 2019 where EC at West Driefontein Gold
Mine fissure water was elevated. PC further stated that at the end of the one meter
pipeline sampling point the faecal coliform count, ammonia and orthophosphate were
elevated due to Hannes van Niekerk WWTW, which was partial operational as a result of
vandalism (cable theft).
PC said that most of the variables at Merafong City Local Municipality’s WWTW:
Oberholzer, Khutsong, Welverdiend and Wedela were not complaint. PC said that most
of the WWTWs were not fully operational. At Khutsong WWTW raw sewage was entering
and exiting the plant without any treatment due to vandalism (cable theft). There was no
flow at the Wedela WWTW at this point because a transformer had been vandalised and
the WWTW was not operational. Raw sewage was no longer entering the Wedela
WWTW as “zama-zamas” had vandalised the sewer line and currently raw sewage was
flowing into the environment towards Wedela stream, which joined the Loopspruit.
Doorfontein Canal at Blaaubank point was compliant except for August 2019 where EC,
sulphate and uranium were elevated. Mooi River Loop at Blauubank point was compliant
except for uranium in August 2019 and faecal coliform count for September and October,
which were elevated due to the impact from Doorfontein Canal at Blaaubank point and
15
the Welverdiend WWTW, respectively. PC said that the water quality from Mooi River at
Klerkskraal Dam–Rysmiesbult road bridge U/S of Boskop Dam point was good.
EM asked PC if there was an improvement between the recent and previous water
quality reports. PC replied and said that there was an improvement except for the
WWTWs.
GG said that next to Lancaster Dam, there was an old manganese dump for MMC which
had not been rehabilitated. EM said that the party who was contributing manganese
pollution to the Wonderfonteinspruit should be investigated and should pay for this
action. PN said that the EC at Khutsong WWTW was complaint as it was 120mS/m in
terms of the WUL, not in the eighty’s. PC asked PN if they had amended their WUL as
she had used the limits from Khutsong WUL. PC said that if they had not amended their
WUL then there would be no changes.
AL asked if there was a reason for the DWS not monitoring the private WWTWs. VN said
that the DWS was following a prescribed monitoring programme and private WWTW’s
that AL asked about were not part of Departmental monitoring programme. VN said that
perhaps on an adhoc basis DWS would need to monitor those WWTWs that were
discharging into the water resource. EM asked if the WWTWs was privately owned and
where it discharged. VN said that it was privately owned by Morgan Greek and the mines
and that it discharged into the water resource. PC said that there was no access to those
areas. EM said that the DWS needed to investigate those privately owned WWTWs and
to try to obtain access. PC suggested that they first investigate the water resource that
the WWTWs were discharging into, followed by trying to obtain access to the WWTWs.
VN said that their focus was on Local Government WWTWs monitoring and monitoring of
WWTWs was not conducted at the mines. EM requested the DWS official to sample the
WWTWs that were discharging into the water resource. NG said that the mines were
sampling for them. EM said to NG that their samples would need to be audited by DWS.
AL said that it was very embarrassing for MCLM to request the DWS to monitor the
private WWTWs, when the municipality were not compliant themselves. AL said that
industries within the municipality that were discharging to sewer were supposed to
provide their discharge monitoring results to the municipality but the municipality was not
receiving them. AL shared his concern and said that the municipality was flooded with
polluted water. EM suggested that MCLM get funds to conduct monitoring from other
industries through municipal by-laws. AL said that the DWS could assist but would not be
able to implement monitoring on behalf of the municipality.
No Action Progress Responsible Person
7.4.1 DWS officials to investigate the private WWTWs that are discharging into the water resource and to try to obtain access to those WWTWs.
Feedback would be given in the next meeting
DWS
16
7.5 Compliance Monitoring and Enforcement (CME)
LN reported that CM had undertaken a compliance audit at Harsco on 05 September
2019, the report was sent to the facility and the facility had been asked to provide an
action plan to address the audit findings. LN said that Harsco had sent an action plan on
the 08 November 2019, which was still under review by DWS. Following which, a follow
up inspection would be undertaken. LN said that another compliance audit was
undertaken on 12-15 November 2019 at Anglo Gold Ashanti and that CM was in the
process of compiling the report.
TM (Harmony Gold) asked why they had not received their feedback report from the CM
team since the compliance audit was conducted at Harmony Gold on the 07 September
2019. LN asked who had conducting the audit. TM said that it was Ms Mokgadi Thema.
LN said he would follow up with her regarding their report.
TM presented Enforcement (See presentation attached)
TM explained that at the last Forum meeting it had been requested that Enforcement
provide a summary detailing what activities and responsibilities Enforcement undertaken
within the catchment. TM said that Enforcement monitor 11 sub-catchments within the
Upper Vaal Water Management Area (WMA). They use an Enforcement Management
System (EMS) in the office to manage their cases that they carry out within the whole
Upper Vaal WMA e.g. if a request about a certain case in the catchment was received
Enforcement officials could abstract the information through the EMS. The EMS assists
them to manage their cases, record keeping, data collating, identifying repeat offenders
and identifying hot spots within the WMA.
ML said that there had been 6 pre-directives issued, 1 directive issued and 1 that had
become a criminal case (SAPS). ML said that she was aware that 14% of cases had
been registered with SAPS, but the presentation listed only one case that had been
reported and she wanted to know who the offender was that was being criminally
investigated.
LN says that DWS cannot release the case information, name of the offender etc. until
the case has gone to court. Further to this, EM said that when the person was not yet
taken to court their name was not allowed to be disclosed until they were charged and
appeared in court.
No Action Progress Responsible Person
7.5.1 LN to follow up on the compliance audit report for Harmony Gold.
Feedback would be given in the next meeting
LN
17
7.6 Regulations
AM presented on the Water Services Regulations, which was supposed to be presented
at the previous Wonderfonteinspruit Forum meeting dated 03 September 2019, (see the
presentation attached).
AM explained that water service regulations enforced compliance with the Water Service
Act 108 of 1997. They regulate provincial water services through programmes such as
green and blue drop. The green drop regulation programme was an incentive based
regulation that seeks to identify and develop the core competencies required for the
sector that if strengthened would gradually and sustainably improve the level of waste
water management in South Africa.
ML said that the DWS team was doing a wonderful job of inspecting the WWTWs, but
she asked why there had been no green drop reports since 2014. NM replied and said
that the DWS had not been publishing the national green drop assessments. Gauteng
provincial office saw a need to continue do a green drop assessment within the Gauteng
provincial office to try and assess the progress being made by Municipalities so that
when a full green drop assessment was undertaken by Head Office the DWS would be
able to determine compliance in terms of what would be required for the Key Results
Area (KRA) assessment.
EM added and said that the National green drop was the competency of the Minister. In
other words Gauteng Region was not able to share green drop information that they were
doing with the public. EM said that in the recent past there had been a large housing
development which put pressure on the existing infrastructure. EM said that when
coming to the designed and operational capacity of WWTW’s, the operational capacity
was always exceeded. Further to this, NM said that due to the spillages not all sewage
was reaching the WWTWs and as a result, it appeared as though WWTWs were still
operating within their designed capacity, even when that was not the case.
NM answered and said that when they do an assessment they communicate with the
Municipality but when they do the report they write the report based on the information
that was available on the IRIS system because the Municipality was expected to update
the information on a regular basis. NM said that the IRIS system should be updated
regularly and people with relevant skills should be employed at the Municipality to do
this. PC asked why Hannes Van Niekerk WWTW’s was not part of the presentation,
because it discharged to Wonderfonteinspruit. AM replied and said that it would be on
the report in February 2020. EM advised AM to circulate the presentation to all Forum
members.
7.7 Update from Non-Government Organisations
ML said that South Africa was facing a significance water crisis, 56% of waste water
treatment and 40% of water treatment works were in the poor condition and 11% were
18
not functional. ML said that more that 50% of water was being lost and 33% of rivers
were in a poor ecological condition. ML said that between 1999 and 2011 the 9
catchment rivers in South Africa were classified as being in a poor ecological condition,
this had increased by 500% with some rivers being pushed beyond the point of recovery.
Further to this, ML said that 35% of municipal water was lost through leakages.
ML said that the Municipalities were losing 1660 million cubic metres of water per year
through non-revenue water. At the cost of R6.00 per cubic metre this amounted to R9.9
billion per annum. ML explained that R33 billion was needed each year for the next ten
years to achieve water security. ML said that the reality was that water would become
more expensive; ML said that everyone except those without access to water should be
using less water for the day-to-day activities. ML said that everyone except for indigent
peoples must pay for water and sanitation services. Lastly ML said that South Africa
would 70% of available of service and ground water by 2030.
With regards to AMD, the treated AMD should be used to supplement water supply and
must be extended considerably. The delay in the implementation of phase 2 of the
Lesotho highlands water project has significantly impacted on water security resulting in
social economic impact conditions in affected areas. ML said that by 2040, treated AMD
and desalinated sea water would be added to South African water supply. Further to this,
ML said that if targets were achieved in terms of reducing physical loses in municipal
systems, as well as reduction in per capital consumption in the global average, in
addition to inclusion of desalinated and treated AMD water there would be a surplus in
2030.
The CMAs should be put in place by 2023 and by 2020 identification and prosecution of
big polluters across the country, including municipalities, should be undertaken, with a
national communication campaign to accompany the action. ML explained that what she
had presented has been taken from launch of the master plan. ML also noted that many
of the DWS officials had stated that they had not seen the master plan, which ML thought
was shameful. Further to this, ML said that she wasn’t able to speak on behalf of the
DWS, but she said that she did not understand why DWS officials did not have access to
the master plan, where civil society already did. LN asked where ML got all the
information from. EM said that there should be further investigation as to why the
information was not in possession of all DWS officials. ML replied and said that she was
invited by the Minister to the budget speech that was how she had obtained the
information. EM said that for effective planning a bottom up approach was always
effective and not vice-versa. ML said that the plan was well put together, however there
was no budget to implement the plan.
PC requested ML to summarise and circulate the information she presented. ML said
that she would draft a summary and circulate it to the Forum stakeholders. ML
requested to present on Sustainable Development Goal 6. FML said that the Sustainable
Development Goal 6, “availability and sustainable water management for all” must be
achieved by 2030. ML noted that there were different targets within Sustainable
19
Development Goal 6. She stated that 6.3 dealt with waste water, stating that waste water
must be effectively treated and should be re-used by 2030. ML indicated that by 2032, all
ecosystems and the ecosystem infrastructure must be maintained responsibly and
sustainably. South Africa was a signatory of the United Nations (UN) Sustainable
Development Goals; however none of them could be implemented effectively if there was
no budget. ML said that this was part of the responsibility of the water and sanitation
sector leadership group, which were the highest decision-making team in DWS. In terms
of all the 17 Sustainable Development Goals, which should be achieved by 2050, water
was key to all the other Sustainable Development Goals. ML then committed to email the
presentation that was done by the Department Chief Engineer Mr Mark Banister to the
Forum stakeholders. EM stated that he missed the presentation internally due to his tight
schedule.
8. Acid Mine Drainage (AMD): Western Basin Area
DV was not present but sent an apology, PC reported on his behalf. PC said that TCTA
was currently pumping 30ML/d, and that the plant had started to operate again on 20
August 2019 after vandalism forced operations to cease temporarily. The water quality
was a follows: pH 8.6, SO4 2.9 mg, Iron <0.1, Manganese 1.3, EC 406 mS/m and water
level was 5.83 meters below ground level (mbgl).
ST said that in terms of the long term solution, the process was no longer with TCTA but
now with the DWS. Previously, the TCTA had reached the point of appointing Engineers
but the DWS stopped the process and recommended that further research be done into
alternative more affordable treatment options. ST said that the best sustainable method
that should be used for long term treatment was under investigation, there was a
suspicion that the proposed method of study and the investigation that followed had
revealed that there might be other options that might be more affordable.
ML said that JVW has proposed that a salinity and hydrological model or study be
undertaken with urgency prior to the investigation and implementation of a long term
solution option. ST noted that there was a task team established to look at the long term
solution.
9. General
9.1 Catchment Management Agency (CMA)
EM said that there were no changes in terms of CMA establishment, he reported that
there was an advisory committee that has been appointed by the previous Minister, but
before the advisory committee had a chance to conduct their work the administration has
No Action Progress Responsible Person
7.7.1 ML to send master plan presentation and summary of the United Nations Sustainable Development Goal 6 presentation.
Feedback would be given in the next meeting
ML
20
changed. DWS had therefore made a submission to the current Minister requested that
the existing advisory committee remain in place to commence with their work on moving
the CMA forward. No response to the submission had yet been received.
9.2 Minutes
Prof EN stated that SL mentioned the issues regarding item 6.2 bottom of page 8 for
Sibanye discharge. It reads as follows: “All Sibanye Stillwater mines have approved
WULs which set out limits for discharges. SL said that they did not discharge directly into
Mooi River but rather into tributaries of the Mooi River”. Prof EN said that since DWS had
changed to the Department of Human Settlement and Water and Sanitation, and
because the WFS Forum and the Mooi river Forum fell within separate Provinces, who
was monitoring and coordinating a large scale assessment of the greater area to ensure
that the pollution from the WFS catchment didn’t flow into the Mooi River and end up in
the Boskop dam, which was the water reservoir for Potchefstroom. EM said that people
in the upper WFS weren’t able to drink the water in the WFS due to pollution.
Prof EN asked who at DWS could provide UNISA-Department of Public Administration
with an overall assessment of the greater WFS and Mooi River water management
areas, especially since the WFS and Mooi River Forums were located in different
provinces. Prof EN also noted that the Municipalities were not well represented in the
Forums. Further to this, Prof EN noted that the stakeholders were not well informed
about the different resource features within the catchment. In that regard UNISA was
offering to do an informative introductory document for various Forum stakeholders to
better understand these catchments.
EM said that there were different Government Departments, which all had different
mandates. The mandate of the DWS was the protection of water resources. EM said that
the DWS knows that there were various impacts on the water resources such as, human
settlements, mining, local Government etc, EM indicated that DWS was not able to solve
all the problems associated with those various entities, as they were the mandate of
other Departments i.e. the DMRE. EM said the DWS could only make sure that the other
Departments ensure that their mandated entities did not impact on the water resources.
9.3 Terms of Reference
Prof EN asked if the Forum had Terms of Reference and when they were drafted. Prof
EN said that he only observed mine representatives attending the Forum meeting; why
were other Departments (i.e. COGTA, Department of Housing etc.) not represented at
the Forum meetings. EM said that they should be present at these meetings. Prof EN
said that he also wanted to see local residents in the Forums raising their issues relating
to sinkholes etc. Pro EN said that the residents would be interested to understand what
Municipalities were doing to resolve issues relating to WWTWs.
21
9.4 Locality Map
Prof EN said that residents weren’t aware of what the Forum was all about; they also
weren’t aware and/or didn’t understand where monitoring points were located, where
Lancaster dam was, or where the one meter pipeline was and why it was there. Prof EN
said the residents should know more of what the Municipality was doing in the area. The
UNISA delegation wanted to offer their services to draw up introductory documents,
including a location map to help people understand what the Forum was about. Prof EN
suggested that at least 2 or 3 representatives from the Municipalities should attend and
participate in the Forum, in order to assist the residents in understanding what the Forum
was all about.
EM said that the reason they invited COGTA and various other government Departments
to the Forum was so that these Departments would be able to respond to community
questions, however it was often the case that only the DWS and DMRE were present at
Forum meetings. In terms of the Water Resource Management in the country, it was
strictly WMA based and not provincially bound. EM explained that the Upper Vaal
Catchment extended from Ermelo to Kimberley. EM said that the Water Services units
were provincially bound such as: water supply, sanitation etc. EM said that if there was
sewage discharge that was not compliant in Mpumalanga (Ermelo), then his office was
responsible in terms of water resource management (protection of water resources).
However, EM said that he couldn’t resolve the discharge pollution from Pretoria DWS
and that in that case Mpumalanga Provincial office should rather be approached. EM
said that the DWS demarcated catchments through quaternaries. e.g C20, C22 etc.
AL asked that what would be done after the meeting and at the next coming Forum
meeting because when they (Merafong) give an explanation of non-complaint reports,
the incorrect levels of individuals are requested to give information. AL said that even if
solutions were discussed at a Forum level, on a Municipality level they were inadequately
represented (i.e. without Municipal decision-makers (managers) present at the Forum,
decisions made at the Forum could not be implemented). AL appreciated all the
representatives of Merafong for their presence, input and commitment. Further to this, AL
said that all the representatives of Merafong who attended the Forums did not have all
the answers that the Forum members or community expected/required. AL said that he
would highly appreciate if CFO’s and the Municipality Managers would attend the Forum
meetings. AL said that they were relying on higher level DWS officials to interact with
higher level local Government officials. Al noted that the Merafong representatives that
were present at the forum were lower level officials who were not able to make decisions.
EM replied and said that as officials of the DWS, when problems from Municipalities were
encountered, they immediately informed their political principals. EM said that the
principals then met with MENDMAC in order to determine a solution for the problem. EM
said that in emergencies it was possible for some of the DWS budget to be used directly
to implement solutions. e.g allowing Eskom to take allocations from National Treasury, if
you owe the electricity they would take it directly from there.
22
DH stated that there were dangerous dolomitic and sinkholes areas in the West Rand
and nothing had been done to remedy the situation. Developers were developing houses
in areas where there were dangerous sinkhole formations. Further to this DH, shared his
concern and said that there were large double-story houses in some of the settlements
that were extremely dangerous considering the dolomitic area and nothing had been
done to ensure that these types of structures were not built over dangerous dolomitic
areas. EM said that Local Government needed to work with Provincial government and
indicate to Provincial government where studies were required to map sensitive areas
where building of large houses was not feasible.
10. Way Forward All actions would be addressed in the next Forum Meeting. 11. Venue Harmony Gold Mine 12. Acknowledgement and closure EM thanked the attendees for a productive meeting. EM said that the next meeting would be held first Tuesday of March 2020. The meeting was adjourned at 13H10.
March 2020 19121900-330348-15
APPENDIX C
Document Limitations
DOCUMENT LIMITATIONS
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Document is uncontrolled if downloaded or printed Page 1 of 1
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iii) Conditions may exist which were undetectable given the limited nature of the enquiry Golder was retained to undertake with respect to the site. Variations in conditions may occur between investigatory locations, and there may be special conditions pertaining to the site which have not been revealed by the investigation and which have not therefore been taken into account in the Document. Accordingly, additional studies and actions may be required.
iv) In addition, it is recognised that the passage of time affects the information and assessment provided in this Document. Golder’s opinions are based upon information that existed at the time of the production of the Document. It is understood that the Services provided allowed Golder to form no more than an opinion of the actual conditions of the site at the time the site was visited and cannot be used to assess the effect of any subsequent changes in the quality of the site, or its surroundings, or any laws or regulations.
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March 2020 19121900-328397-9
APPENDIX O
Screening Tool
Page 1 of 19 Disclaimer applies 08/10/2019
SCREENING REPORT FOR AN ENVIRONMENTAL AUTHORIZATION OR FOR A PART TWO AMENDMENT OF AN ENVIRONMENTAL AUTHORISATION AS REQUIRED BY THE 2014 EIA REGULATIONS – PROPOSED DEVELOPMENT
FOOTPRINT ENVIRONMENTAL SENSITIVITY
EIA Reference number:
Project name: AGA
Project title: Proposed Surface Pipeline and Associated Infrastructure
Date screening report generated: 08/10/2019 16:08:08
Applicant: AngloGold Ashanti (Pty) Ltd
Compiler: A. Bennett
Compiler signature: .....................................................................................................
Page 2 of 19 Disclaimer applies 08/10/2019
Table of Contents
Proposed Project Location .................................................................................................................... 3
Orientation map 1: General location .................................................................................................. 3
Map of proposed site and relevant area(s) ........................................................................................... 4
Cadastral details of the proposed site ................................................................................................ 4
Wind and Solar developments with an approved Environmental Authorisation or applications under consideration within 30 km of the proposed area ................................................................... 9
Environmental Management Frameworks relevant to the application ............................................. 9
Environmental screening results and assessment outcomes ............................................................. 10
Relevant development incentives, restrictions, exclusions or prohibitions ..................................... 10
Map indicating proposed development footprint within applicable development incentive, restriction, exclusion or prohibition zones .......................................................................................... 11
Proposed Development Area Environmental Sensitivity .................................................................. 11
Specialist assessments identified ...................................................................................................... 12
Results of the environmental sensitivity of the proposed area. ......................................................... 13
MAP OF RELATIVE AGRICULTURE THEME SENSITIVITY .................................................................... 13
MAP OF RELATIVE AQUATIC BIODIVERSITY THEME SENSITIVITY ..................................................... 14
MAP OF RELATIVE ARCHAEOLOGICAL AND CULTURAL HERITAGE THEME SENSITIVITY .................. 15
MAP OF RELATIVE CIVIL AVIATION THEME SENSITIVITY .................................................................. 16
MAP OF RELATIVE PLANT SPECIES THEME SENSITIVITY ................................................................... 17
MAP OF RELATIVE DEFENCE THEME SENSITIVITY ............................................................................. 18
MAP OF RELATIVE TERRESTRIAL BIODIVERSITY THEME SENSITIVITY ............................................... 19
Page 3 of 19 Disclaimer applies 08/10/2019
Proposed Project Location
Orientation map 1: General location
General Orientation: AGA
Page 4 of 19 Disclaimer applies 08/10/2019
Map of proposed site and relevant area(s)
Cadastral details of the proposed site Property details:
No Farm Name Farm/ Erf No
Portion Latitude Longitude Property Type
1 BLYVOORUITZICHT 116 0 26°24'12.17S 27°23'27.22E Farm 2 BLYVOORUITZICHT 116 10 26°24'4.85S 27°23'53.63E Farm Portion 3 BLYVOORUITZICHT 116 66 26°24'6.7S 27°23'21.05E Farm Portion 4 BLYVOORUITZICHT 116 15 26°22'33.91S 27°23'9.34E Farm Portion 5 BLYVOORUITZICHT 116 89 26°23'17.22S 27°23'53.2E Farm Portion 6 BLYVOORUITZICHT 116 98 26°24'42.63S 27°24'21.31E Farm Portion 7 BLYVOORUITZICHT 116 13 26°24'27.15S 27°24'12.37E Farm Portion 8 BLYVOORUITZICHT 116 3 26°25'15.98S 27°24'7.41E Farm Portion 9 BLYVOORUITZICHT 116 51 26°23'4.26S 27°22'40.27E Farm Portion 10 BLYVOORUITZICHT 116 26 26°22'58.58S 27°23'20.66E Farm Portion Development footprint1 vertices:
Footprint Latitude Longitude 1 26°24'44.83S 27°24'20.76E 1 26°24'44.82S 27°24'20.55E 1 26°24'44.78S 27°24'20.34E 1 26°24'44.73S 27°24'20.14E 1 26°24'44.65S 27°24'19.95E 1 26°24'44.56S 27°24'19.77E 1 26°24'44.45S 27°24'19.6E 1 26°24'44.32S 27°24'19.45E
1 “development footprint”, means the area within the site on which the development will take place and incudes all ancillary developments for example roads, power lines, boundary walls, paving etc. which require vegetation clearance or which will be disturbed and for which the application has been submitted.
Page 5 of 19 Disclaimer applies 08/10/2019
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1 26°23'1.11S 27°22'53.7E 1 26°23'1.18S 27°22'53.89E 1 26°23'1.28S 27°22'54.07E 1 26°23'1.39S 27°22'54.24E 1 26°23'1.52S 27°22'54.39E 1 26°23'1.67S 27°22'54.53E 1 26°23'1.82S 27°22'54.64E 1 26°23'2S 27°22'54.74E 1 26°23'2.17S 27°22'54.81E 1 26°23'2.35S 27°22'54.86E 1 26°23'2.55S 27°22'54.88E 1 26°23'2.73S 27°22'54.88E 1 26°23'2.84S 27°22'54.87E 1 26°23'6.08S 27°22'54.43E 1 26°23'7.69S 27°22'54.21E 1 26°23'7.59S 27°23'4.44E 1 26°23'7.46S 27°23'9.51E 1 26°23'6.4S 27°23'10.75E 1 26°23'5.34S 27°23'12.02E 1 26°23'3.6S 27°23'12.9E 1 26°23'3.46S 27°23'12.98E 1 26°23'3.41S 27°23'13.02E 1 26°23'1.46S 27°23'14.38E 1 26°23'1.36S 27°23'14.45E 1 26°23'1.21S 27°23'14.58E 1 26°23'1.08S 27°23'14.74E 1 26°23'0.97S 27°23'14.91E 1 26°23'0.87S 27°23'15.09E 1 26°23'0.83S 27°23'15.21E 1 26°23'0.26S 27°23'16.69E 1 26°23'0.24S 27°23'16.77E 1 26°23'0.18S 27°23'16.97E 1 26°23'0.16S 27°23'17.17E 1 26°23'0.15S 27°23'17.28E 1 26°23'0.07S 27°23'18.77E 1 26°23'0.06S 27°23'18.87E 1 26°23'0.08S 27°23'19.08E 1 26°23'0.1S 27°23'19.23E 1 26°23'0.49S 27°23'21.42E 1 26°23'0.53S 27°23'21.59E 1 26°23'2.38S 27°23'28.3E 1 26°23'5.04S 27°23'37.28E 1 26°23'6.32S 27°23'41.61E 1 26°23'6.33S 27°23'41.67E 1 26°23'6.41S 27°23'41.86E 1 26°23'6.5S 27°23'42.05E 1 26°23'6.61S 27°23'42.21E 1 26°23'6.74S 27°23'42.37E 1 26°23'6.89S 27°23'42.5E 1 26°23'7S 27°23'42.59E 1 26°23'13.65S 27°23'47.19E 1 26°23'26.61S 27°23'56.13E 1 26°23'26.66S 27°23'56.16E 1 26°23'26.67S 27°23'56.17E 1 26°23'28.73S 27°23'57.45E 1 26°23'28.83S 27°23'57.51E 1 26°23'35.27S 27°24'0.85E 1 26°23'35.31S 27°24'0.87E 1 26°23'35.48S 27°24'0.94E 1 26°23'38.09S 27°24'1.83E
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1 26°23'47.16S 27°24'4.95E 1 26°23'49.43S 27°24'5.86E 1 26°23'49.52S 27°24'5.89E 1 26°23'49.7S 27°24'5.93E 1 26°23'49.82S 27°24'5.96E 1 26°23'51.83S 27°24'6.18E 1 26°23'52.34S 27°24'6.26E 1 26°23'55.65S 27°24'6.85E 1 26°23'56.2S 27°24'7.53E 1 26°23'56.28S 27°24'7.62E 1 26°23'56.43S 27°24'7.75E 1 26°23'56.59S 27°24'7.87E 1 26°23'56.72S 27°24'7.94E 1 26°23'58.49S 27°24'8.84E 1 26°23'58.67S 27°24'8.93E 1 26°24'1.18S 27°24'9.82E 1 26°24'1.34S 27°24'9.87E 1 26°24'4.22S 27°24'10.57E 1 26°24'4.28S 27°24'10.57E 1 26°24'4.32S 27°24'10.58E 1 26°24'6.05S 27°24'10.88E 1 26°24'6.2S 27°24'10.89E 1 26°24'6.38S 27°24'10.89E 1 26°24'6.54S 27°24'10.88E 1 26°24'9.95S 27°24'10.29E 1 26°24'12.43S 27°24'11.43E 1 26°24'17.16S 27°24'13.38E 1 26°24'20.68S 27°24'15.09E 1 26°24'20.69S 27°24'15.09E 1 26°24'20.86S 27°24'15.17E 1 26°24'21.03S 27°24'15.21E 1 26°24'25.93S 27°24'16.21E 1 26°24'30.53S 27°24'16.88E 1 26°24'30.66S 27°24'16.9E 1 26°24'30.84S 27°24'16.9E 1 26°24'31.04S 27°24'16.87E 1 26°24'31.1S 27°24'16.86E 1 26°24'37.12S 27°24'15.37E 1 26°24'40.48S 27°24'16.9E 1 26°24'39.73S 27°24'18.52E 1 26°24'39.67S 27°24'18.72E 1 26°24'39.61S 27°24'18.92E 1 26°24'39.58S 27°24'19.12E 1 26°24'39.57S 27°24'19.33E 1 26°24'39.58S 27°24'19.54E 1 26°24'39.61S 27°24'19.75E 1 26°24'39.67S 27°24'19.95E 1 26°24'39.73S 27°24'20.14E 1 26°24'39.83S 27°24'20.32E 1 26°24'39.95S 27°24'20.49E 1 26°24'40.08S 27°24'20.65E 1 26°24'40.22S 27°24'20.78E 1 26°24'40.32S 27°24'20.85E 1 26°24'41.31S 27°24'21.55E 1 26°24'42.33S 27°24'22.28E 1 26°24'42.39S 27°24'22.32E 1 26°24'42.56S 27°24'22.42E 1 26°24'42.74S 27°24'22.49E 1 26°24'42.92S 27°24'22.54E 1 26°24'43.11S 27°24'22.56E
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1 26°24'43.3S 27°24'22.56E 1 26°24'43.49S 27°24'22.54E 1 26°24'43.67S 27°24'22.49E 1 26°24'43.85S 27°24'22.42E 1 26°24'44.02S 27°24'22.32E 1 26°24'44.18S 27°24'22.2E 1 26°24'44.32S 27°24'22.07E 1 26°24'44.45S 27°24'21.92E 1 26°24'44.56S 27°24'21.75E 1 26°24'44.65S 27°24'21.57E 1 26°24'44.73S 27°24'21.37E 1 26°24'44.78S 27°24'21.17E 1 26°24'44.82S 27°24'20.97E 1 26°24'44.83S 27°24'20.76E
Wind and Solar developments with an approved Environmental Authorisation or applications under consideration within 30 km of the proposed area No nearby wind or solar developments found.
Environmental Management Frameworks relevant to the application
Environmental Management Framework
LINK
Gauteng EMF
https://screening.environment.gov.za/ScreeningDownloads/EMF/Zone_1,_Zone_2,_Zone_3,_Zone_4,_Zone_5.pdf
Page 10 of 19 Disclaimer applies 08/10/2019
Environmental screening results and assessment outcomes
The following sections contain a summary of any development incentives, restrictions, exclusions or prohibitions that apply to the proposed development footprint as well as the most environmental sensitive features on the footprint based on the footprint sensitivity screening results for the application classification that was selected. The application classification selected for this report is: Utilities Infrastructure|Pipelines|Water|Waste Water|General.
Relevant development incentives, restrictions, exclusions or prohibitions The following development incentives, restrictions, exclusions or prohibitions and their implications that apply to this footprint are indicated below.
Incentive, restriction or prohibition
Implication
Strategic Transmission Corridor-Central corridor
https://screening.environment.gov.za/ScreeningDownloads/DevelopmentZones/GNR_350_of_13_April_2017.pdf
Gauteng EMF-Urban development zone 1
https://screening.environment.gov.za/ScreeningDownloads/DevelopmentZones/Zone_1.pdf
Gauteng EMF-Industrial and large commercial focus zone 5
https://screening.environment.gov.za/ScreeningDownloads/DevelopmentZones/Zone_2.pdf
Page 11 of 19 Disclaimer applies 08/10/2019
Map indicating proposed development footprint within applicable development incentive, restriction, exclusion or prohibition zones
Project Location: AGA
Proposed Development Area Environmental Sensitivity The following summary of the development footprint environmental sensitivities is identified. Only the highest environmental sensitivity is indicated. The footprint environmental sensitivities for the proposed development footprint as identified, are indicative only and must be verified on site by a suitably qualified person before the specialist assessments identified below can be confirmed.
Theme Very High sensitivity
High sensitivity
Medium sensitivity
Low sensitivity
Agriculture Theme X
Aquatic Biodiversity Theme X
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Archaeological and Cultural Heritage Theme
X
Civil Aviation Theme X
Plant Species Theme X
Defence Theme X Terrestrial Biodiversity Theme X
Specialist assessments identified Based on the selected classification, and the environmental sensitivities of the proposed development footprint, the following list of specialist assessments have been identified for inclusion in the assessment report. It is the responsibility of the EAP to confirm this list and to motivate in the assessment report, the reason for not including any of the identified specialist study including the provision of photographic evidence of the footprint situation.
No
Specialist assessment
Assessment Protocol
1 Plant Species Assessment
https://screening.environment.gov.za/ScreeningDownloads/AssessmentProtocols/DraftGazetted_General_Requirement_Assessment_Protocols.pdf
2 Animal Species Assessment
https://screening.environment.gov.za/ScreeningDownloads/AssessmentProtocols/DraftGazetted_General_Requirement_Assessment_Protocols.pdf
Page 13 of 19 Disclaimer applies 08/10/2019
Results of the environmental sensitivity of the proposed area.
The following section represents the results of the screening for environmental sensitivity of the proposed footprint for relevant environmental themes associated with the project classification. It is the duty of the EAP to ensure that the environmental themes provided by the screening tool are comprehensive and complete for the project. Refer to the disclaimer.
MAP OF RELATIVE AGRICULTURE THEME SENSITIVITY
Very High sensitivity High sensitivity Medium sensitivity Low sensitivity X
Sensitivity Features:
Sensitivity Feature(s) High Land capability;09. Moderate-High/10. Moderate-High Medium Land capability;06. Low-Moderate/07. Low-Moderate/08. Moderate
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MAP OF RELATIVE AQUATIC BIODIVERSITY THEME SENSITIVITY
Very High sensitivity High sensitivity Medium sensitivity Low sensitivity X
Sensitivity Features:
Sensitivity Feature(s) Low Low Sensitivity Areas Very High River,Ecological support area
Page 15 of 19 Disclaimer applies 08/10/2019
MAP OF RELATIVE ARCHAEOLOGICAL AND CULTURAL HERITAGE THEME SENSITIVITY
Very High sensitivity High sensitivity Medium sensitivity Low sensitivity X
Sensitivity Features:
Sensitivity Feature(s) Medium Mountain or ridge
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MAP OF RELATIVE CIVIL AVIATION THEME SENSITIVITY
Very High sensitivity High sensitivity Medium sensitivity Low sensitivity X
Sensitivity Features:
Sensitivity Feature(s) High Within 8 km of other civil aviation aerodrome
Page 17 of 19 Disclaimer applies 08/10/2019
MAP OF RELATIVE PLANT SPECIES THEME SENSITIVITY
Very High sensitivity High sensitivity Medium sensitivity Low sensitivity X
Sensitivity Features:
Sensitivity Feature(s) Medium Sensitive species 470 Medium Khadia beswickii
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MAP OF RELATIVE DEFENCE THEME SENSITIVITY
Very High sensitivity High sensitivity Medium sensitivity Low sensitivity X Sensitivity Features:
Sensitivity Feature(s) Low Low sensitivity
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MAP OF RELATIVE TERRESTRIAL BIODIVERSITY THEME SENSITIVITY
Very High sensitivity High sensitivity Medium sensitivity Low sensitivity X
Sensitivity Features:
Sensitivity Feature(s) Low None Very High Ecological Support Area 1
March 2020 19121900-328397-9
APPENDIX P
Proof of Application Fee Payment
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1 of 1 2020/03/02 13:18
March 2020 19121900-328397-9
APPENDIX Q
Document Limitations
DOCUMENT LIMITATIONS
GAA GAIMS Form 10, Version 4, August 2018 Golder and the G logo are trademarks of Golder Associates Corporation
Document is uncontrolled if downloaded or printed Page 1 of 1
C:\Users\JePretorius\Desktop\2019\Working File\DocLim_Rev 4.docx
This document has been provided by Golder Associates Africa Pty Ltd (“Golder”) subject to the following limitations:
i) This Document has been prepared for the particular purpose outlined in Golder’s proposal and no responsibility is accepted for the use of this Document, in whole or in part, in other contexts or for any other purpose.
ii) The scope and the period of Golder’s Services are as described in Golder’s proposal, and are subject to restrictions and limitations. Golder did not perform a complete assessment of all possible conditions or circumstances that may exist at the site referenced in the Document. If a service is not expressly indicated, do not assume it has been provided. If a matter is not addressed, do not assume that any determination has been made by Golder in regard to it.
iii) Conditions may exist which were undetectable given the limited nature of the enquiry Golder was retained to undertake with respect to the site. Variations in conditions may occur between investigatory locations, and there may be special conditions pertaining to the site which have not been revealed by the investigation and which have not therefore been taken into account in the Document. Accordingly, additional studies and actions may be required.
iv) In addition, it is recognised that the passage of time affects the information and assessment provided in this Document. Golder’s opinions are based upon information that existed at the time of the production of the Document. It is understood that the Services provided allowed Golder to form no more than an opinion of the actual conditions of the site at the time the site was visited and cannot be used to assess the effect of any subsequent changes in the quality of the site, or its surroundings, or any laws or regulations.
v) Any assessments made in this Document are based on the conditions indicated from published sources and the investigation described. No warranty is included, either express or implied, that the actual conditions will conform exactly to the assessments contained in this Document.
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