re: new largo colliery (mine plan alternatives 6 and 7 ...zitholele.co.za/projects/12639 -...

Stonecap Trading 14 (Pty) Ltd

EARTH SCIENCE AND ENVIRONMENTAL CONSULTANTS _______________________________________________ REG No. 2005/021338/07_____________________________________________

Our Ref:

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17th July 2012 Synergistics Environmental Services P.O. Box 1822 Rivonia 2128 Gauteng South Africa Tel: Tel: 011 807 8225 Fax: 011 807 8226 Email: [email protected], [email protected] Attention: Ms. Mari Wolmarans (Project Co-ordinator) Dear Mari,

Re: NEW LARGO COLLIERY (MINE PLAN ALTERNATIVES 6 AND 7) SPECIALIST SOIL AND LAND CAPABILITY IMPACT ASSESSMENT AND

MANAGEMENT PROGRAMME

Dear Mari/Marline, In line with the revised Terms of Reference supplied, and discussions had with yourself the project team regarding the soils and land capability assessments required and proposed for the New Largo Colliery (Mine Plan Alternatives 6 and 7), herewith is the final report detailing the findings of the soil and land capability impact assessment. Should you require any additional information in this regard, please do not hesitate to contact us. Yours faithfully Earth Science Solutions (Pty) Ltd

Ian Jones B.Sc. (Geol) Pr.Sci.Nat (400040/08), EAP Certified

Director

mailto:[email protected]



ANGLO AMERICAN INYOSI COAL (PTY) LTD

NEW LARGO COLLIERY

SPECIALIST

SOILS AND LAND CAPABILITY ASSESSMENT (EIA Report: S0403-NLC-SOI-00-Soil-Specialist-Assessment)

Compiled on Behalf of

July 2012

Sustaining the Environment

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CLIENT: Synergistics Environmental Services (Pty) Ltd P.O. Box 1822 Rivonia 2128

Gauteng South Africa

Tel: Tel: 011 807 8225 Fax: 011 807 8226 Email: [email protected]

[email protected]

Proposal Number: SG.NL.S.10.03.033 Client: Synergistics Environmental Services Attention: Marline/Mari

DOCUMENT ISSUE STATUS

Report/Proposal Name

New Largo Mining Plan - Pedological and Land Capability Studies

Report/Proposal Number

SG.NL.S.10.03.033

Report Status Final Report

Carried Out By Earth Science Solutions (Pty) Ltd

Commissioned By Synergistics Environmental Services

Copyright ESS (Pty) Ltd.

Title Name Capacity Signature Date

Author Ian Jones Director

July 2012

Project Director Marline Medallie

Technical Review Mari Wolmarans

* This report is not to be used for contractual or engineering purposes unless permissions are obtained from the authors.


Declaration This specialist report (SG.NL.S.10.03.033) has been compiled in terms of the South African Environmental legislation (GNR 543 Section 32), and forms part of the overall impact assessment, both as a standalone document and as supporting information to the overall impact assessment and management programme for the proposed development. The specialist Soil and Land Capability studies were managed and signed off by Ian Jones (Pr. Sci Nat 400040/08), an Earth Scientist with 34 years of experience in these fields of study and a registered and certified Environmental Assessment Practitioner. I declare that both, Ian Jones, and Earth Science Solutions (Pty) Ltd are totally independent in this process, and have no vested interest in the project. The objectives of the studies were to:

Provide a permanent record of the present soil resources in the area that are potentially going to be affected by the proposed development and mining related activities;

Assess the nature of the site in relation to the overall environment and its present and proposed utilization, and determine the capability of the land in terms of its arable potential; and

Provide a base plan from which long-term ecological and environmental decisions can be made, impacts of the proposed development can be determined, and mitigation and rehabilitation management plans can be formulated.

The Taxonomic Soil Classification System and a combination of the Canadian Land Inventory System and Chamber of Mines Land Capability Rating Systems were used as the basis for the soils and land capability investigations respectively. These systems are recognized nationally and internationally. Signed: July 2012 at Nelspruit

Ian Jones B.Sc. (Geol) Pr.Sci.Nat 400040/08, EAP Certified Director – Earth Science Solutions (Pty) Ltd

New Largo Colliery

Specialist Soils and Land Capability Assessment

Final Report iii

Earth Science Solutions (Pty) Ltd July 2012 SG.NL.S.10.03.033

TABLE OF CONTENTS

GLOSSARY OF TERMS 1 EXECUTIVE SUMMARY 4 1. INTRODUCTION AND METHODOLOGY 21

1.1 Introduction 21 1.2 Methodology 22 1.2 Legal Considerations 26 1.3 Summary of Baseline Findings 28 1.4 Study Team and Qualifications 32 1.5 Assumptions, Exclusions and Limitations 32

2. IMPACT ASSESSMENT 33 2.1 Impact Philosophy 33 2.2 Impact Assessment Variables 37 2.3 Impact Drivers 38 2.4 Analyses of Impacts 39 2.5 Cumulative Impacts 45

3. ENVIRONMENTAL MANAGEMENT PLAN 46 3.1 Construction Phase 48 3.2 Operational Phase 49 3.3 Decommissioning and Closure 50

4 MONITORING AND MAINTENANCE 52 5 CONCLUSIONS AND KEY FINDINGS 53 6 RECOMMENDATIONS 54 LIST OF REFERENCES 56

LIST OF FIGURES

Figure 1a - Locality Plan 24 Figure 2.1a – Plan of Mining (Option 6) 35 Figure 2.1b – Alternative Plan of Mining (Option 7) 36

LIST OF TABLES

Table 2.1 – Significance Rating System 34 Table 3.1 – Construction Phase – Soil Utilization Plan 49 Table 3.2– Operational Phase – Soil Conservation Plan 50 Table 3.3 – Decommissioning and Closure Phase – Soil Conservation Plan 51

LIST OF APPENDICIES

Appendix 1 Vetiver Grass

Appendix 2 Study Maps

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GLOSSARY OF TERMS Alluvium: Refers to detrital deposits resulting from the operation of modern

streams and rivers. Base status: A qualitative expression of base saturation. See base saturation

percentage. Base Saturation Base saturation refers to the proportion of the cation exchange sites in

the soil that are occupied by the various cations (hydrogen, calcium, magnesium, potassium). The surfaces of soil minerals and organic matter have negative charges that attract and hold the positively charged cations. Cations with one positive charge (hydrogen, potassium, sodium) will occupy one negatively charged site. Cations with two positive charges (calcium, magnesium) will occupy two sites.

Buffer capacity: The ability of soil to resist an induced change in pH. Calcareous: Containing calcium carbonate (ferricrete). Catena: A sequence of soils of similar age, derived from similar parent material,

and occurring under similar macroclimatic conditions, but having different characteristics due to variation in relief and drainage.

Clast: An individual constituent, grain or fragment of a sediment or

sedimentary rock produced by the physical disintegration of a larger rock mass.

Cohesion: The molecular force of attraction between similar substances. The

capacity of sticking together. The cohesion of soil is that part of its shear strength which does not depend upon inter-particle friction. Attraction within a soil structural unit or through the whole soil in apedal soils.

Concretion: A nodule made up of concentric accretions. Crumb: A soft, porous more or less rounded ped from one to five millimetres in

diameter. See structure, soil. Cutan: Cutans occur on the surfaces of peds or individual particles (sand

grains, stones). They consist of material which is usually finer than, and that has an organisation different to the material that makes up the surface on which they occur. They originate through deposition, diffusion or stress. Synonymous with clayskin, clay film, argillan.

Desert Plain: The undulating topography outside of the major river valleys that is

impacted by low rainfall (<25cm) and strong winds. Denitrification: The biochemical reduction of nitrate or nitrite to gaseous nitrogen, either

as molecular nitrogen or as an oxide of nitrogen. Erosion: The group of processes whereby soil or rock material is loosened or

dissolved and removed from any part of the earth’s surface.

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Fertilizer: An organic or inorganic material, natural or synthetic, which can supply

one or more of the nutrient elements essential for the growth and reproduction of plants.

Fine sand: (1) A soil separate consisting of particles 0,25-0,1mm in diameter.

(2) A soil texture class (see texture) with fine sand plus very fine sand (i.e. 0,25-0,05mm in diameter) more than 60% of the sand fraction.

Fine textured soils: Soils with a texture of sandy clay, silty clay or clay. Hardpan: A massive material enriched with and strongly cemented by

sesquioxides, chiefly iron oxides (known as ferricrete, diagnostic hard plinthite, ironpan, ngubane, ouklip, laterite hardpan), silica (silcrete, dorbank) or lime (diagnostic hardpan carbonate-horizon, ferricrete). Ortstein hardpans are cemented by iron oxides and organic matter.

Land capability: The ability of land to meet the needs of one or more uses under defined

conditions of management. Land type: (1) A class of land with specified characteristics. (2) In South Africa it

has been used as a map unit denoting land, mapable at 1:250,000 scale, over which there is a marked uniformity of climate, terrain form and soil pattern.

Land use: The use to which land is put. Mottling: A mottled or variegated pattern of colours is common in many soil

horizons. It may be the result of various processes inter alia hydromorphy, illuviation, biological activity, and rock weathering in freely drained conditions (i.e. saprolite). It is described by noting (i) the colour of the matrix and colour or colours of the principal mottles, and (ii) the pattern of the mottling.

The latter is given in terms of abundance (few, common 2 to 20% of the exposed surface, or many), size (fine, medium 5 to 15mm in diameter along the greatest dimension, or coarse), contrast (faint, distinct or prominent), form (circular, elongated-vesicular, or streaky) and the nature of the boundaries of the mottles (sharp, clear or diffuse); of these, abundance, size and contrast are the most important.

Nodule: Bodies of various shapes, sizes and colour that have been hardened to a greater or lesser extent by chemical compounds such as lime, sesquioxides, animal excreta and silica.

These may be described in terms of kind (durinodes, gypsum, insect casts, ortstein, iron, manganese, lime, lime-silica, plinthite, salts), abundance (few, less than 20% by volume percentage; common, 20 – 50%; many, more than 50%), hardness (soft, hard meaning barely crushable between thumb and forefinger, indurated) and size (threadlike, fine, medium 2 – 5mm in diameter, coarse).

Overburden: A material which overlies another material difference in a specified

respect, but mainly referred to in this document as materials overlying weathered rock.

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Ped: Individual natural soil aggregate (e.g. block, prism) as contrasted with a

clod produced by artificial disturbance. Pedocutanic, diagnostic B-horizon: The concept embraces B-horizons that have become

enriched in clay, presumably by illuviation (an important pedogenic process which involves downward movement of fine materials by, and deposition from, water to give rise to cutanic character) and that have developed moderate or strong blocky structure. In the case of a red pedocutanic B-horizon, the transition to the overlying A-horizon is clear or abrupt.

Pedology: The branch of soil science that treats soils as natural phenomena,

including their morphological, physical, chemical, mineralogical and biological properties, their genesis, their classification and their geographical distribution.

Slickensides: In soils, these are polished or grooved surfaces within the soil resulting

from part of the soil mass sliding against adjacent material along a plane which defines the extent of the slickensides. They occur in clayey materials with a high smectite content.

Sodic soil: Soil with a low soluble salt content and a high exchangeable sodium

percentage (usually EST > 15). Swelling clay: Clay minerals such as the smectites that exhibit interlayer swelling

when wetted, or clayey soils which, on account of the presence of swelling clay minerals, swell when wetted and shrink with cracking when dried. The latter are also known as heaving soils.

Texture, soil: The relative proportions of the various size separates in the soil as

described by the classes of soil texture shown in the soil texture chart (see diagram on next page). The pure sand, sand, loamy sand, sandy loam and sandy clay loam classes are further subdivided (see diagram) according to the relative percentages of the coarse, medium and fine sand subseparates.

Vertic, diagnostic A-horizon: A-horizons that have both, high clay content and a

predominance of smectitic clay minerals possess the capacity to shrink and swell markedly in response to moisture changes. Such expansive materials have a characteristic appearance: structure is strongly developed, ped faces are shiny, and consistence is highly plastic when moist and sticky when wet.

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EXECUTIVE SUMMARY

The New Largo open cast mining project (New Largo Colliery) is planned as a long-term open pit coal mining development that will primarily supplied the Kusile Power Station. The coal will be transported via a conveyor system to Kusile, which located immediately west of New Largo Colliery. The project will utilize proven mining technology, with open cast dragline and the roll over truck and shovel methodology being proposed. The mining plans tabled (Version 6 and 7) include the mining layout and schedule, and details of support infrastructure.

It is important to note that at the time of the optimisation of the mine plan and the tabling of Mine Plan 7D the outcomes and impacts on the soils and land capability were reviewed. No material differences are expected as a result of the change in mining developments, and as such no changes have been made to the impact assessment or management planning.

STUDY APPROACH Study Methodology The mining development is being assessed as a stand-alone project with specialist inputs to the EIA. Close liaison with the lead consultants and the aligned specialists involved on the earth science aspects of the project has been on-going throughout the process of the soil impact assessment Each of the separate baseline studies and assessments will feed into the larger environmental assessment. This document deals exclusively with the Open Cast Coal Mining Project. The results for the specialist soils and land capability studies for the O/C Project are described in terms of the baseline assessment (as described in the guideline documentation – SA Taxonomic Soil Classification and Chamber of Mines Land Capability Rating Systems) and recorded as the pre-development or existing environment. This information forms the basis for End Land Use Planning and talks to the philosophy utilized in developing the rehabilitation strategy and soil utilization plan. In addition, and as part of the impact assessment the baseline information has been used to better understand the soil and land capability sensitivities and vulnerabilities as a function of the proposed change in land use proposed (open cast mining). The soils and land capability studies were assessed in terms of the nationally accepted and accredited “S.A. Taxonomic Soil Classification System” and a combination of the Canadian Land Inventory System and the S.A. Chamber of Mines Land Capability Rating System, all of which are considered guidelines in best practise and are recommended as the minimum requirements in terms of the legislation being followed for EIA (NEMA). The area of concern was covered on a comprehensive reconnaissance grid base as part of the 2007 baseline survey, with a re-assessment of the sensitive areas as part of the impact assessment undertaken in 2011.

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The soils were characterised and classified in terms of the Taxonomic System of classification, and these findings in conjunction with the geomorphological characteristics of the site were used to rate the land capability. The baseline of information was then used in conjunction with the mine planning proposed to assess the possible/potential impacts of the mining venture as proposed for the two alternatives recommendation by the client. The outcomes of the alternatives, Option 6 and Option 7 were then compared in terms of their significance rating (Impact Assessment) and recommendations made based on these outcomes. Study Team and Qualifications The team of specialists employed included a qualified soil scientist (pedologist) with a B.Sc. degree in the Earth Sciences, and a technical assistant with a diploma in soil science (a total of 56 years of expertise between them), while the project was signed off by a professional Earth Scientist (Pr. Sci. Nat 400040/08). All laboratory analysis was undertaken by an accredited laboratory. The mapping and compilation of the findings of the site evaluation was compiled by a qualified GIS specialist. Assumptions, Exclusions and Limitations The basis for these studies was the 2007 baseline information, with limitations to the accuracy of the field mapping based on the reconnaissance nature of the scale of mapping undertaken. Limitations in terms of the changes that might have occurred since 2007 are regarded as slight, with the exception of the sand mining that has occurred in the northern portions of the site. These activities will have had an impact on the cumulative impacts, but will have had little effect on the baseline soil forms present or the inherent capability of the land. These changes were not mapped or investigated in any detail. The alternatives assessment findings tabled by the client (Mining Plan Options 6 and 7) were used as the basis for the impact assessment. The wetland delineation as presented by the wetlands specialist was used as the basis for the identification of the highly sensitive and potential No Go areas, albeit that the soils mapping were used in the wetland delineation exercise. The limitations are associated with the scale of mapping used and the base map imagery available at the time of mapping (2007). Uncertainties and Knowledge Gaps The uncertainties are associated with the brownfields nature of a large portion of the site (cultivated agriculture) which has altered the natural conditions. The soils have been impacted by both tillage as well as the addition of fertilizers and probably/possibly lime and organic matter.

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The chemistry of many of the soils must be considered to have been altered, albeit that some of the lands have been left fallow for periods. In addition, the detail of soil characterisation and classification at the reconnaissance level is not sufficient for a detailed understanding of the underlying lithologies (saprolite and plinthite) and the weathered/decomposed nature of the geology and the association of the soil environment to the biological and ecological status. This knowledge gap is believed to be important in better understanding the impacts of a mining venture of this nature on the soil water and more sensitive soil environmental aspects. Outstanding Issues Further research and soil studies will be needed if the significance of the sensitive areas and wetlands in particular are to be understood. The contribution of the soils, and the soil water in particular, is a relative unknown in scientific terms, and a detailed investigation of the major soil forms that surround the wetlands (pans, streams, rivers and waterways) is recommended as part of the sustainable development outcomes needed in better understanding the potential for offsetting the Northern Pan System as a balance to the mining of the sensitive areas to the south. DESCRIPTION OF BASELINE ENVIRONMENT Existing Impact Sources The survey area is characterised by a variety of robust and sensitive, to highly sensitive soils that vary from extremes of moderate to very deep sandy loams and sandy clay loamy textures with moderate clay contents, good soil water storage ability, a moderate to low erosion index, moderate to poor nutrient stores and apedel to weak crumby structure. These characteristics are in contrast to the extreme of much shallower rooted soils and rocky outcrop areas that returned little to no rooting depth. These soils returned fine to medium grained sandy texture (resistant sandstones) and poor water holding capabilities that are more sensitive to erosion, while the highly sensitive wet based soils and wetland areas associated with the pan structures, streams and riverine environs, are regarded as the more sensitive soils mapped. This complex of soils is modified and characterised by the range of sediments and geological structures that influence the topography and control the pedogenetic processes at work. The existing environmental considerations (physical and socio economic) and impact sources identified during the baseline investigation that could have an effect on the soils and land capability include:

The “Brownfields” nature of the majority of the project area (Economic Agriculture and commercial grazing;

The construction of the Kusile Operations albeit to the north and west of the site and off the coal mining area;

The construction and operation of the Phola-Kusile Coal Conveyor

The presence and use of existing public roads;

A number of commercial shops and farm stores;

Numerous farm dams and water retention facilities;

Irrigation of farm land and the effects of added water to the soils;

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Synthesis of Baseline/Existing Impacts The baseline investigation of the soils and land capability identified a number of existing impacts that are of consequence to the pre-construction/existing conditions that could/will be impacted. These include:

The modified nature of a large proportion of the soils that are planned to be disturbed. These soils have been effected by commercial farming activities (cultivated cropping and livestock grazing);

The irrigation of some of the soils for commercial crop production;

The commercial mining and sale of sand (sand mining) to the building industry;

Clay mining and the production of bricks (close to the area of concern);

Drainage of a number of the wetland environs due to cultivation practices and the modification of the temporal zone around the wetlands;

The confining/impoundment of surface water in farm dams and the saturation of otherwise temporal wet based soils;

Generation of dust from cultivation and exposure of soils while left fallow to wind erosion – loss of the resource;

Increased loss of soil resource due to water erosion of unprotected soils (removal of vegetative cover);

Possible contamination of soils and loss of land capability due to farming activities and commercial and mining use of sections of the proposed mining site;

Loss of soil resource due to compaction of areas being utilized for commercial or private dwellings and farm businesses;

Loss of soil water resource (soil water) due to disturbance of soil profile (compaction – reduced infiltration) and

The effects of dust generated by the construction activities (inclusive of transport) from the Kusile construction site and the building of the conveyer system.

An understanding of the baseline conditions is paramount to any operation if rehabilitation is to meet the minimum criteria and obtain a stable and standalone state at closure with a sustainable end land use. The reinstatement of materials in closing any project will require that the materials balance is available and the management plan has been complied with, and if the soils are to be available at the time of rehabilitation. This is specifically important to the New Largo situation were a sensitive balance in the ecological systems (water, soil, vegetation and their potential effect on the overall ecological balance) is apparent (Northern Pan System). The soil environment and its position in the earth’s life cycle is important to the completeness of any environmental assessment study and should be read as part of the overall biodiversity statement (ecology, surface water, wetlands and groundwater). The dominant soil and land capability characteristics that are prevalent in the study area include the following:

The survey area is characterised by a variety of soil textures, structures, depths and chemical composition, varying from moderately shallow to shallow and highly sensitive soils that directly overlie a ferricrete layer of varying thickness and density (hard plinthite/laterite), to deep sandy soils that are of colluvial or in-situ origin, are moderate to low in clay (4% to 18% - utilisable zone), returned low water holding capabilities and a moderate to high erosion index.

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These two extremes are associated with a range of transition states, with soils of varying clay contents, a range of effective rooting depths and structural characteristics. These variations result in a range of soil forms and land capabilities that are directly related to the sensitivity and vulnerabilities of the materials that are to be disturbed.

The ferricrete layer mapped is of importance to both the sensitivities and vulnerabilities of the materials described, with this layer forming a distinctive surface between the underlying host rocks and the more recent alluvial/colluvial deposits mapped. The restrictive layer will inhibit the vertical infiltration of surface and soil water and hold the moisture close to surface where it is useful to the ecology of the area.

The in-situ soils derived from the host rock (sedimentary) lithologies are intricately interspersed with colluvial derived soils comprising stratified structures typical of depositional environments, with areas of alluvial (water deposition) soils associated with the bottomlands and alluvial flood plains. This range of different depositional agents and environments, coupled with the climatic and mechanical weathering typical of the area (hot and cold, rain and drought) results in a set of soil forms which are unique to these environments, and which produce a unique set of sensitivities and vulnerabilities. These will require a unique set of site specific management measures at closure.

The current land capability is rated as “grazing land” or “wilderness/conservation land” with a low intensity (stocking) status for the most part (S.A. Chamber of Mines Guidelines (1991) Rating System). The term conservation is used to convey the broad group of land capability that is neither arable land nor grazing land, and which does not fit the wetland status. The rating implies the need for “careful” utilization of, or on these areas.

The distribution and character of the soils are further influenced by the complex geological structure (faulting and fracturing) that has influenced the host lithologies. The presence of coal close to surface has determining the position of the mining venture and its support infrastructure (conveyer and beneficiation plant) and market (Kusile power Station).

The major/dominant soil forms mapped include the Hutton, Clovelly, Griffin, Glencoe and Mispah along with some hydromorphic forms, including the Pinedene, Avalon, Bloemdal, Fernwood, Longlands, Westleigh, Kroonstad, Rensburg and Katspruit.

Physical Characteristics The physical characteristics of the soils include:

Topsoil clay percentages that range from as low as 4% to 18%, and as high as 12% to 35% depending on the host geology from which they are derived,

Subsoil clays that range from 16% to 57%,

High infiltration/permeability rates are associated with the sandy loams and well sorted alluvial materials associated with the riverine deposits and some of the more sandy Forms associated with the quartzite deposits in the north;

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Moderate to high in-situ permeability rates (0.74m/day to 2.15m/day) on the more clay rich loams and sandy clay loams associated with the shallower soils (600mm to 900mm) and materials associated with the ferricrete and/or the deposition of flood plain materials;

A significant and impermeable ferricrete (hard plinthite) as the “C” horizon to many of the pedological profiles mapped either in the lower lying areas associated with wetlands and their transition zone or as relic land forms within the topography;

Moderate to good intake (infiltration) rates (5mm/hr to 12mm/hr), depending on the type of clay present;

Moderate to poor water holding capacities for all but the more clay rich materials (80mm/m to 120mm/m).

The physical characteristics are highly influenced by the parent materials from which they are derived, as well as their position in the topography. The structure of the soils varies from those with a fine-grained apedel composition with occasional single grained structure within the very silty soils, to weak crumby structure where the soils are colluvial derived, and/or associated with the wetland bottom slope positions. A significant percentage of the soils that are likely to be disturbed are associated with the flat to undulating highveld plains and relatively wide colluvial deposits within the open non-perennial waterways. While compaction is a concern to be noted and managed in the natural environment, it is of greater consequence to the successful implementation of any rehabilitation plan. The variable grain size of the materials will, when mixed and/or disturbed, result in a compaction index that is significantly altered form the natural conditions. The land capability (soils, climate, ground roughness etc.) ranges from very low intensity (poor quality) grazing lands with little to no significant economic potential, to highly sensitive wilderness or conservation status lands that by definition requires better than average management and areas that are rated as poor agricultural potential land. The presence of wetlands as defined by the wetland delineation guidelines are relativily limited (<15% of area), but of high significance to the ecological stability of the area. Chemical Characteristics The chemistry of the soils is typical of the weathered product of the underlying (in-situ) geology (sediments), which contrasts with the transported colluvial and alluvial materials typical of the upstream environs from which they are derived. The mix of colluvial derived materials that are part of the active outwash environs, and the alluvial derived stratified deposits that comprise the recent sediments and which exhibit poor nutrient stores (highly leached, well sorted, low clay and little to no organic carbon), contrast with the in-situ derived materials that have a better nutrient pool and organic composition (albeit low),.

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The results of the laboratory analysis indicate the following general trends:

A pH range of between 4.85 and 7.10 (slightly acid)

Zinc, Magnesium, Phosphorous and Sodium ratios are average to slightly higher than average, while

Potassium and Calcium values that are generally moderate to slightly low, and

An organic carbon matter content (0.03 – 0.69 C%) that is generally low. It is important to note that a fair proportion of the soils mapped, and analysed have been cultivated, and therefore fertilised at some time. This will have an effect on the analytical results returned, and will not necessarily be representative of the in-situ fertility of the soils in their natural state. As a result, these soils require significant amounts of essential nutrients as additives/input if they are to be used as a growing medium (rehabilitation). IMPACT ASSESSMENT The National Environmental legislation in its guidelines reflects the need for the removal and storage of all utilizable soil as a basic necessity in all project development and construction, prior to the initiation of building or mining. The concept of “utilizable” soil has been introduced as a practical way of describing the soils that should be retained and stored. These norms have been used to classify and characterised the soils as part of the baseline study, while the management criteria (stripping volumes and stockpiling heights and methods) for these materials have been prescribed as part of the management and mitigation planning (soil utilization plan). The soil characteristics and associated sensitivities have informed the management methodologies prescribed. Project Impacts The sources of impact that will potentially affect the soils environment are related to the following:

The extremes of area that will be disturbed by the open cast mining – potentially large loss of resource;

The size and weight of machinery that will be used to mine the commodity;

The depth of impact due to the open cast nature of the mining and the need for deep foundations for the larger infrastructure and support activities will result in the disturbance of the complete soil profile;

The length of time that some of the soils will need to be stored and managed (30 years plus);

The sequence of mining and the extent of open void that exists at any moment in time (Roll over method proposed);

The sensitive ecological and biodiversity aspects that are to be impacted – wet based soils and transition zone landscapes;

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Description of Project Impacts Mine Plan Option 6 and R545 route Option 1A The activities that will take place during the LoM of the project and which will impact the soil environment have been dealt with using a phased approach. The Option 6 Mine Plan considers the mining of the complete “resource”, inclusive of the Northern Pan System and considers the rerouting of the R545 to the north and east of the mining area. Construction Phase

The stripping of all utilisable soil (Top 150mm to 500mm depending on activity);

The preparation (levelling and compaction) of lay-down areas, foundations and pad footprint areas for stockpiling of utilisable soil removed from the footprint of the open cast mining area, the soft overburden stockpile and the construction of the storm water control facility(s) inclusive of berms and trenches to divert clean water around the mine workings;

The clearing, stripping and stockpiling from the construction of all access and haulage roads, water supply, alternative provincial road routes (R545) and linear infrastructure;

The use of heavy machinery over unprotected soils;

The creation of dust and loss of materials to wind and water erosion (loss of resource), and

The possible contamination of the soils by coal product, chemical and hydrocarbons spills (dust and dirty water runoff);

Operational Phase

The sterilisation of the soil resource under which the coal is mined and the where the support facilities are constructed. This will be an on-going loss for the duration of the operation;

The creation of dust and the possible loss (erosion) of utilisable soil down-wind and/or downstream, and the siltation of the local streams and waterways;

The compaction of the in-situ and stored soils and the potential loss of utilisable materials from the system;

The mining of wet based soils and wetlands (pans):

The contamination of the in-situ and stored soils by dirty water run-off and or spillage of hydrocarbons from vehicle and machinery or from dust and emissions from the process of mining (blasting dust etc.) and hauling of coal;

The contamination and impact of sensitive materials located on or in close proximity (bordering) to the mining venture and their loss from the system;

Contamination of soils by use of dirty water for road wetting (dust suppression) and irrigation of the stockpile vegetation;

Contamination of soil resource by emission fallout;

Sterilisation and the loss of the soil nutrient pool, organic carbon stores and fertility of stored soils;

Impact on soil structure and soil water balance and the impact on the base flow to the local catchment due the mining of the wet based soils.

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Decommission and Closure

The loss of the soils original nutrient store and organic carbon by leaching of the soils while in storage;

Erosion and de-oxygenation of materials while stockpiled;

Compaction and dust contamination due to vehicle movement while rehabilitating the area;

Erosion due to the lack of slope stabilization and re-vegetation of disturbed areas;

Contamination of replaced soils by use of dirty water for plant watering and dust suppression on roads and haulage ways;

Hydrocarbon, chemical and coal product spillage from contractor and supply vehicles on roads and haulage ways;

An improvement (positive impacts) due to the reduction in areas of disturbance and return of soil utilisation potential, uncovering of areas of storage and rehabilitation of compacted materials.

Alternative Mine Plan Mine Plan 7, with south-western R545 route (route to south of the pan on farm Honingkranz route option 1B

The alternative to Mine Plan Option 6 is Mine Plan Option 7. This involves the sterilization of the

coal under the “Northern Pan System” and its surrounds. The differences in the impacts that will

be felt are site specific and of consequence to the specific system involved.

Again, the impacts have been described in terms of the different phases of the project.

Construction Phase

The stripping of all utilisable soil (Top 150mm to 500mm depending on activity);

The preparation (levelling and compaction) of lay-down areas, foundations and pad footprint areas for stockpiling of utilisable soil removed from the footprint of the planned open cast mining area, the soft overburden stockpile and the construction of the storm water control facility(s) inclusive of berms and trenches to divert clean water around the mine workings;

The clearing, stripping and stockpiling from the construction of all access and haulage roads, water supply, alternative provincial road routes (R545) and electrical power supply servitudes (linear infrastructure);

The use of heavy machinery over unprotected soils;

The creation of dust and loss of materials to wind and water erosion (loss of resource), and

The possible contamination of the soils by chemical and hydrocarbons spills (dust and dirty water runoff);

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Operational Phase

The sterilisation of the soil resource under which the coal is mined and the facilities are constructed. This will be an on-going loss for the duration of the operation;

The creation of dust and the possible loss (erosion) of utilisable soil down-wind and/or downstream and the siltation of the local streams and waterways;


The mining of wet based soils and wetlands within the proposed mining area (option 7 - excluding the whole of the northern pan system);

The contamination of the in-situ and stored soils by dirty water run-off and or spillage of hydrocarbons from vehicle and machinery or from dust and emissions from the process of mining (blasting dust etc.);

The contamination and impact of sensitive materials located on or in close proximity (bordering) the mining venture and their loss from the system;


Contamination of soil resource by emission fallout;

Sterilisation and loss of soil nutrient pool, organic carbon stores and fertility of stored soils;

Impact on soil structure and soil water balance and the impact on the base flow to the local catchment due the mining of the wet based soils within the mining area.

Decommission and Closure


Erosion and de-oxygenation of materials while stockpiled;

Compaction and dust contamination due to vehicle movement while rehabilitating the area;

Erosion due to slope stabilization and re-vegetation of disturbed areas;

Contamination of replaced soils by use of dirty water for plant watering and dust suppression on roads and haulage ways;

Hydrocarbon or chemical spillage from contractor and supply vehicles on roads and haulage ways;

An improvement (positive impacts) due to the reduction in areas of disturbance and return of soil utilisation potential, uncovering of areas of storage and rehabilitation of compacted materials.

Synthesis and Comparison of Base Case Mine Plan (6) and Alternative Mine Plan (7) In assessing the impacts that are likely to affect the soil environment for the two mining options tabled (Options 6 and 7), it is important that the site specific nature of the activities are understood, but it is also important to understand that the impacts will potentially be felt some distance downstream/gradient of the operation. The effects on soil water will ultimately influence and affect the base flow to the rivers.

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Construction Phase During the construction phase, the impacts will be very similar for the two options, with the majority of the mining infrastructure and early mining taking place on areas with less sensitive soils (No major wetlands). The mining sequence is planned to start in the south and progress northwards and there is no major infrastructure planned in and around the northern pan system. The significance of the impacts will be limited, albeit that the area will be restricted and all existing activities (sand mining etc.) will stop. Operational Phase During the operational phase, the mining will gradually progress northwards into the northern pan area some time into the 2030’s and early 2040’s. Again little effect will be felt on the major pan system until this time. However, once mining is started, the impacts as described in mine plan Option 6 will occur and the system will be lost, with all of the contributing factors that are associated with the soil water and its contribution to the ecology and biodiversity of the area. Decommission and Closure

The closure scenario will be similar for the two mining options with the very striking difference,

that the recreation and restoration or rehabilitation of the northern pan system will not be

possible.

The system will have been lost with all the positive contributions of the deep soils and soil water

that is inherently part of the pan system along with its potential contribution to the base flow of

the river.

The impacts on the soil resource will affect the soil water balance, the contribution of the soils to the downslope catchments and the storage zones within the soil catena (seep zones, pans) and this will ultimately have an impact on the base flow of the streams and rivers. CUMULATIVE IMPACTS Currently, there are potential sources of similar impact from other coal mines operating or planned to the south and east of New Largo, as well as the beneficiation plant to the south of the proposed operation, and the planned transportation of the coal from the process plant to the power station via a conveyor system (Phola –Kusile) that is to be constructed to the south and west of the mining area. These impacts are likely to occur as a result of the project and not as stand-alone activities, and as such will need to be considered as part of the overall impact that will occur if the mining project materialises. If the new Largo Mining Project does not materialise, these impacts will not be an issue. However, with Kusile Power Station at an advanced stage of construction the assumption is that the conveyencing of coal from the beneficiation plant in the south will happen even if the New Largo Project does not materialise (Coal will be found from another source). In addition, residential developments and existing power stations in the area supply sufficient data to undertake a risk assessment on the cumulative impacts.

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The cumulative impacts on the soils and land capability are confined mainly to the overall reduction in the availability of the resource and the potential loss of utilizable materials that have the ability to produce agricultural products. The overall loss of resource due to erosion, compaction and contamination is unlikely to be an issue in terms of cumulative effects as these constraints are site specific. Although soil resources are not limited in the region, the loss of land capability and a change in land use associated with other developments (Townlands, additional mining, power stations etc.) could result in a loss of livelihood for the present/existing communities. Further pressures could arise if there is an influx of job seekers to the region, with these job seekers potentially establishing informal settlements and resorting to subsistence type agricultural practices, all of which could further sterilising arable and economically viable soil resources. IMPACTS OF NO-GO / ALTERNATIVE DEVELOPMENT The impact of the project not materialising would result in the continuing of the status quo. The farming and small scale mining activities would continue and the soils would continue to be impacted by the operations that currently occur on the land. Soils would be affected by farming and the support activities associated with this existing practise, while the mining of the sands and clay would sterilise the soils and render the areas of little use other than as wilderness status at closure (surface materials are utilised). An alternative development would need to be better understood before any meaningful comment could be made regarding the impacts. However, the potential loss of income to the state and the loss of job opportunities if New Largo does not happen is likely to be greater than those afforded the people in the agricultural and small scale mining industries. The loss of soil resource from farming versus the mining option has not been calculated for any of the significant project of this size, but all indications are from smaller projects worked on, is that there is no significant difference in the loss of resource on the soils in this geographic area when comparing the “natural” land capability with that which is proposed for the rehabilitated area (grazing land potential rating) after mining is completed.

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MITIGATION, MANAGEMENT AND MONITORING MEASURES TO BE INCORPORATED INTO THE ENVIRONMENTAL MANAGEMENT PROGRAMME

Construction Phase Making provision for the retention of utilizable material for the decommissioning and/or during rehabilitation will not only save significant costs at closure, but will ensure that additional impacts to the environment do not occur. Table 1 is a summary of the soil utilization guide proposed to aid in soil management during the construction phase. Table 1 – Construction Phase – Soil Utilization Plan

Phase Step Factors to Consider Comments

Stripping will only occur where soils are to be disturbed by activities that are

described in the design report, and where a clearly defined end rehabilitation use

for the stripped soil has been identified.

It is recommened that all vegetation is stripped and stored as part of the utilizable

soil. However, the requirements for moving and preserving fauna and flora

according to the biodiversity action plan should be consulted.

Handling

Soils will be handled in dry weather conditions so as to cause as little compaction as

possible. Utilizable soil (Topsoil and upper portion of subsoil B2/1) must be

removed and stockpiled separately from the lower "B" horizon, with the ferricrete

layer being seperated from the soft/decomposed rock, and wet based soils

seperated from the dry soils if they are to be impacted.

Stripping

The "Utilizable" soil will be stripped to a depth of 700mm or until hard

rock/ferricrete is encountered. These soils will be stockpiled together with any

vegetation cover present (only large vegetation to be removed prior to stripping).

The total stripped depth should be 700mm, wherever possible.

Location

Stockpiling areas will be identified in close proximity to the source of the soil to

limit handling and to promote reuse of soils in the correct areas. All stockpiles will

be founded on stabilized and well engineered "pads"

Designation of AreasSoils stockpiles will be demarcated, and clearly marked to identify both the soil

type and the intended area of rehabilitation.

Delineation of areas to be stripped

Reference to biodiversity action plan

Stripping and

Handling of soils

Delineation of

Stockpiling areas

Co

nst

ruct

ion

This “Soil Utilization Plan” is intimately linked to the “development plan”, and it should be understood that if the plan of construction changes, these recommendations will probably have to change as well.

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Operational Phase Maintenance and care of the soil and land resources will be the main management activity and objective required during the operational phase. Management of material loss, compaction and contamination are the main issues of consideration. Table 2 details recommendations for the care and maintenance of the resource during the operational phase.

Table 2– Operational Phase – Soil Conservation Plan


Vegetation

establishment and

erosion control

Enhanced growth of vegetation on the Soil Stockpiles and berms will be promoted

(e.g. by means of watering and/or fertilisation), or a system of rock cladding will be

employed. The purpose of this exercise will be to protect the soils and combat

erosion by water and wind.

Storm Water ControlStockpiles will be established/engineered with storm water diversion berms in

place to prevent run off erosion.

Stockpile Height and

Slope Stability

Soil stockpile and berm heights will be restricted where possible to <1.5m so as to

avoid compaction and damage to the soil seed pool. Where stockpiles higher than

1.5m cannot be avoided, these will be benched to a maximum height of 15m. Each

bench should ideally be 1.5m high and 2m wide. For storage periods greater than 3

years, vegetative (vetiver hedges and native grass species - refer to Appendix 1) or

rock cover will be essential, and should be encouraged using fertilization and

induced seeding with water and/or the placement of waste rock. The stockpile side

slopes should be stabilized at a slope of 1 in 6. This will promote vegetation growth

and reduce run-off related erosion.

Waste

Only inert waste rock material will be placed on the soil stockpiles if the vegetative

growth is impractical or not viable (due to lack of water for irrigation etc.). This will

aid in protecting the stockpiles from wind and water erosion until the natural

vegetative cover can take effect.

VehiclesEquipment, human and animal movement on the soil stockpiles will be limited to

avoid topsoil compaction and subsequent damage to the soils and seedbank.

Op

era

tio

n

Stockpile

management

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Decommissioning and Closure There will be an improvement on the soil and land capability environments as the area of disturbance is reduced and the soils are returned to a state that can support low intensity grazing (Highveld Grasslands). Table 3 is a summary of the proposed management and mitigation actions recommended

Table 3 – Decommissioning and Closure Phase – Soil Conservation Plan


Placement of Soils

Stockpiled soil will be used to rehabilitate disturbed sites either ongoing as

disturbed areas become available for rehabilitation and/or at closure. The utilizable

soil (500mm to 700mm) removed during the construction phase, must be

redistributed in a manner that achieves an approximate uniform stable thickness

consistent with the approved post development end land use (Conservation land

capability and/or Low intensity grazing), and will attain a free draining surface

profile. A minimum layer of 300mm of soil will be replaced.

Fertilization

A representative sampling of the stripped and stockpiled soils will be analysed to

determine the nutrient status and chemistry of the utilizable materials. As a

minimum the following elements will be tested for: EC, CEC, pH, Ca, Mg, K, Na, P,

Zn, Clay% and Organic Carbon. These elements provide the basis for determining

the fertility of soil. based on the analysis, fertilisers will be applied if necessary.

Erosion ControlErosion control measures will be implemented to ensure that the soil is not washed

away and that erosion gulleys do not develop prior to vegetation establishment.

Pollution of Soils In-situ Remediation

If soil (whether stockpiled or in its undisturbed natural state) is polluted, the first

management priority is to treat the pollution by means of in situ bioremediation.

The acceptability of this option must be verified by an appropriate soils expert and

by the local water authority on a case by case basis, before it is implemented.

Off site disposal of

soils.

If in situ treatment is not possible or acceptable then the polluted soil must be

classified according to the Minimum Requirements for the Handling, Classification

and Disposal of Hazardous Waste (Local Dept of Water Affairs) and disposed of at an

appropriate, permitted, off-site waste facility.

Rehabilitation of

Disturbed land &

Restoration of

Soil Utilization

Dec

omm

issi

onin

g &

Clo

sure

CONCLUSIONS AND KEY FINDINGS Baseline Conclusions and Observations The findings of the soil and land capability specialist studies conclude that:

There is a highly variable depth characteristic from significant areas of rocky outcrop and shallow saprolitic/ferricrete exposure to deeper in-situ derived soils and colluvial derived materials associated with the lower midslopes and lower slope positions;

Generally moderate clay content with low reserves of organic carbon and resultant moderate to high erodibility indices, albeit that these are tempered by the relative flatness of the terrain;

Lower than acceptable nutrient stores in association with moderate permeability rates in the upper soil horizons and moderate to low water holding characteristics;

In general, moderately sensitive soils that will require good management (erosion and compaction issues);

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Moderate to high significance ratings for the unmanaged impacts on the highly sensitive soils associated with the open cast mining area, materials stockpiles and associated support infrastructure;

Moderate impacts on the soils and land capability due to the loss in resource on the soils that will be effected by the construction and operation of the Open Pit mining area (dragline and truck and shovel – roll over mining) and its associated support infrastructure;

A moderate to low significance rating due to the potential for contamination, compaction and erosion of materials during the construction phase predominantly, with a lower significance during the operational phase and into the decommissioning and closure of the facilities.

The sensitivity of the soils mapped will require better than average management during the construction and operational phases if they are to be useful for rehabilitation during the later stages of the operation and into the closure phase of the project. The present land use and the land capability are two distinctly different issues. The land use is what the farmer or land owner has decided to grow and is not always the optimum for the soils or the climate, while the land capability is the rating given to the land based on the science and classification system (Chamber of Mines Land Classification Rating System). The soils are generally of a moderately good quality in terms of structure, water holding capability and texture etc., but are not capable of sustaining a commercial crop without significant inputs of fertilizers and other additives (chemistry). The natural, dryland capability rating for the majority of the areas mapped is “Grazing Lands” in terms of the Chamber of Mines Classification System. Almost all of the areas successfully cultivated have significant amounts of fertilizer and lime added for their successful production of an economically viable crop. This is not the case without the additives.

The current land capability is rated as grazing land or poor quality arable land with significant areas of both wilderness status and wet based soils. However, for successful rehabilitation to take place the site will require well developed and implemented management to stabilise and re-establish the natural soil components and obtain a self-sustaining and standalone land class unit, all of which will require that a soil depth of at least 500mm (Grazing Land Potential) is re-instated across the landscape. The pedological assessment revealed a strong correlation between the underlying lithologies and weathering of the in-situ materials, and the accumulation of depositional materials within the lower lying areas as colluvial and/or alluvial deposits. The result of these geomorphological interactions has resulted in a complex of soil Forms. The accumulation of colluvial materials in the transition zone are reflected in the sandy clays and clay loams that vary in depth, water holding capabilities and drainage characteristics. The pedogenisis and process are all important in better understanding the soil functionality of the soil within the greater life cycle of the area under study. The storage of water within the deeper soils and the movement of soil water within the profile are of importance to the wet soils status and the functionality of the ecology of the area. Successful rehabilitation of the sensitive and more structured soils will require significant management input if a sustainable vegetative cover is to be re-established and the project is to obtain a standalone status at closure.

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Significant economic gain can be achieved by getting the stripping and storage of utilisable materials correct as part of the overall mine planning early on, with successful rehabilitation and ease of closure being achieved if the materials are available and a conceptual plan developed early in the planning stages. The activities proposed for the mining development will definitely have a significant negative impact on the soil resource for the life of the construction, mining operation and rehabilitation operations, and will potentially be felt beyond the mining into the closure phases. The land capability of the open cast mining areas and the surface infrastructure associated with these activities will be altered from moderate to poor potential grazing and arable land status to that of “mining land” status for the life of the mining operation and beyond. SPECIALIST RECOMMENDATIONS It is the opinion of this study that additional studies and investigations into the movement of soil water (surface infiltration and perched groundwater) within the vadose zone are required. The correlation between the deep sandy soils and the ferricrete layer (relic land forms or “C” horizon) in the soil profile are important in better understanding the systems that are to be disturbed by open cast mining. The nature of the groundwater environment and its relationship to the soil water are in need of site specific knowledge, and the integral nature of the low transmissivity values returned for the weathered aquifer noted in the groundwater assessment need to be better understood in relation to the soil water. The movement of the soil water is the topic for further investigation, with the link to the water bodies inclusive of the wetlands (pans and stream environments) in need of further exploration.

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1. INTRODUCTION AND METHODOLOGY

1.1 Introduction The mining of coal at the New Largo Colliery has been realised as part of the development and operation of the new power station at Kusile, the alternatives for the mine area being a function of the socio economics, engineering and environmental concerns. Anglo American Inyosi Coal (Pty) Limited (AAIC) is proposing to develop a new opencast coal mine, the New Largo Colliery, to supply coal to Eskom’s new Kusile Power Station that is currently under construction, just south of the N4 highway between Bronkhorstspruit and Emalahleni (Witbank) in Nkangala District Municipality of Mpumalanga Province, to meet the future demand for coal at the Kusile Power Station. At full production, Kusile will require approximately 17 million tons (Mt) of coal per year, depending on the quality of the coal. AAIC intends to enter into a long-term agreement with Eskom to supply coal to the new Kusile Power Station. AAIC has committed, in a letter of intent, to supply the bulk of 17 Mt of coal over a period of 47 years to Kusile. The intention is for this coal to be sourced from the New Largo Colliery, with supporting production from AAIC’s Zibulu 2 seam and Zondagsfontein 4 seam operations. The New Largo Colliery coal reserve is located directly to the east of the new Kusile Power Station, between the N4 highway in the north and the N12 highway in the south, with a small portion of the coal reserve found to the south of the N12 highway (Refer to Figure 1a) The intention is not to mine through the N12 highway but to leave a buffer zone for the highway and other linear infrastructure running parallel to the N12 such as the Transnet petroleum pipeline. The soils and land capability are two of the specialist disciplines that have been considered important aspects of the physical environment, and which will definitely be affected by the proposed activities. With the baseline studies at hand, and with a mine plan available and the market secured for the product (Kusile Power Station), it was important that the alternative mining plans were assessed to determine which the most sustainable option is. To this end, discussions around all seven of the various mine plans were had, and some detailed investigations were undertaken. Options 6 and 7 were considered reasonable and possibly the best alternative for further assessment and investigation. This document has looked at the baseline for the total mineable area (Mine Plan 6), as well as the alternative of Mine Plan 7 (not mining around the pan in the north on Farm Honingkrantz). Mining is planned using mainly dragline operations with only small areas mined by fleets of conventional truck and shovel and dragline system and the concept of the roll over method of mining (open cast). These are the preferred methods that have been tabled, with the smaller or more confined areas being proposed using the truck and shovel option, and the more extensive cuts utilizing the dragline method. The details of the mining sequence, timing etc. for the two options/plans are presented in Figure 1b.

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The use of a dragline is considered the most feasible method of mining for the majority of the resource based on the depth to coal and the length of minable face available, while areas that are more confined in terms of length of minable face, but which are within the depth limits for open cast mining have been considered as truck and shovel operations. The consideration for not mining the northern pan has been tabled as a result of the biodiversity and ecological impacts that have been raised. The implications for the mine and Kusile Power Station have been detailed in the plan of study and feasibility reports. The environmental implications are that the soils and land capability will not be impacted by mining and that the re-routing of the R545 will be shortened and redirected along a more direct route just to the south of the northern pan. The land use will be retained and the present conditions and functionality of the pan will be secured. It is important to note however, that sand mining in the area is already encroaching on the soils surrounding the pan. These actions and activities will inevitably alter and impact the systems that influence the pan functionality if they have not done so already. Further investigation in this regard is needed. In the planning of any new development it is important that the impacts are understood prior to the initiation of the design and/or implementation of the project. 1.2 Methodology In better understanding the baseline conditions, the informational available and historical data was reviewed and the baseline soil information re-visited. The detail soil mapping was used to construct a map of “dominant soil groups”. The grouping of the soils was undertaken with a view to simplifying the information, but more importantly obtaining a document/map that was usable and practical to the operation of mining. The handling of the utilizable soil and its storage are paramount to the successful rehabilitation of the area. The loss of this resource will result in an unsustainable project. The soils and land capability baseline information was considered a reliable baseline for further assessment of impacts. An outcome of the original findings was that the sensitivity of the wet based soils was highlighted as an area that required more input and the “Pan” structures in particular were targeted as potential “No Go” areas or areas of High Sensitivity. These issues have been dealt with in more detail as part of this document, a reliable consideration for the best mining option being required. In simplifying the soil mapping to a dominant group level, the variables of depth, wetness (hydromorphic nature of the soil) and its structure were considered important variables that would affect the workability of the materials, and are a reflection of the sensitivity of the soils. Based on these groupings it is believed the soils can better be managed (stripped and stored), during the mining operation and during construction, and the mitigation of impacts can be better managed in terms of rehabilitation. It was incumbent on the specialist environmental team to consider the impacts of the proposed mining and its associated infrastructure on the environment as part of the overall assessment for the mining operation, and to consider the alternative of not mining the northern pan (Offset for wetland impacts overall), as well as assessing the cumulative impacts of the power station at Kusile that is already under construction.

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Consultation with the wetlands specialist and the ecological team (inclusive of hydrology and hydrogeology) has been considered in the findings. The impact assessment aims to identify and quantify the environmental and/or social aspects of the proposed activities, to assess how the activities will affect the existing state, and link the aspects to variables that have been defined in terms of the baseline study and the two alternatives (Plan 6 and Plan 7). In addition, the impact assessment will define a maximum acceptable level of impact for each of the variables, inclusive of any standards, limits and/or thresholds, and will assess the impacts in terms of the significance rating as defined. This will require that the cumulative effects are considered, and that the common sources of impact are detailed, and the differences in impact of the two options/plans are considered. These outcomes will need to be considered in terms of the overall impact assessment (EIA) before a decision can be made regarding the most sustainable mine plan. Based on the outcomes of the impact assessment, the site specific management planning and mitigation measures for the soils will be defined. This will include defining what the mitigation will do to reduce the intensity and probability of the impact, and ensure that the prescriptive mitigation proposed is clear, site specific and practical. In addition, and as part of the practical management plan, a comprehensive monitoring system has been tabled. The original baseline study (Reconnaissance Soils and Land Capability Specialist Studies - 2007) has been used as the basis for these impact assessments for the New Largo Mining Project. The original report of baseline conditions has been summarised herein for sake of convenience. However, the original document should be consulted for detailed explanations. The lead consultants (Synergistics Environmental Consultants) requested Earth Science Solutions (Pty) Ltd (ESS) to undertake additional impact assessments for the proposed mining that has been proposed in terms of the Mine Plan Option 6, and to compare these with an assessment of the alternative referred to as Option 7.

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Figure 1a - Locality Plan

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Figure 1b – Mining plan – Version 6 and Version 7A

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Figure 1a shows the general location of the proposed development that is planned for the New Largo mining area, and shows the extent of coverage, while Figure 1b reflects the two alternatives that are being considered. One of the consequences of the proposed mining is the re-alignment of the R545. The alternatives being considered will affect the proposed positioning of the road depending on the option finally decided on. The soil coverage extends beyond the proposed mining boundary, and covers the areas of re-alignment for the R545 (Refer to Figure 2 – Dominant Soil Group Map). Based on the information available (historic and current), the reconnaissance baseline studies (soils and land capability), and with the development options at hand, the areas of concern have been assessed for both of the options (6 and 7) and management measures proposed that will minimise and where possible mitigate the impacts. A comparison of impacts has been considered. The principle of “No net loss” has been used as the best practice guideline. However, the development of the open cast mining venture will require a significantly large surface area to be disturbed for a significant period of time, and the present land uses (soils) and land capabilities will definitely be changed. These activities will challenge the concept of “No Net Loss”. 1.2 Legal Considerations As part of understanding the consequences of the proposed development and the maximum acceptable levels of impact that will be considered by the authorities, a summary of the national legislation that pertains to soils is considered helpful, and will aid in setting the permissible standards and limits that can be considered, albeit that there are no prescribed quantitative limits that can be quoted for either the soils or the land capability. The most recent South African Environmental Legislation that needs to be considered for any new development with reference to management of soil includes:

The Conservation of Agricultural Resources (Act 43 of 1983) states that the degradation of the agricultural potential of soil is illegal.

The Bill of Rights (chapter 2) states that environmental rights exist primarily to ensure good health and wellbeing, and secondarily to protect the environment through reasonable legislation, ensuring the prevention of the degradation of resources.

The Environmental right is furthered in the National Environmental Management Act (No. 107 of 1998), which prescribes three principles, namely the precautionary principle, the “polluter pays” principle and the preventive principle.

It is stated in the above-mentioned Act that the individual/group responsible for the degradation/pollution of natural resources is required to rehabilitate the polluted source.

Soils and land capability are protected under the National Environmental Management Act 107 of 1998, the Minerals Act 28 of 2002 and the Conservation of Agricultural Resources Act 43 of 1983.

The National Environmental Management Act 107 of 1998 requires that pollution and degradation of the environment be avoided, or, where it cannot be avoided be minimised and remedied.

The Minerals Act 28 of 2002 requires an EMPR, in which the soils and land capability be described.

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The Conservation of Agriculture Resources Act 43 of 1983 requires the protection of land against soil erosion and the prevention of water logging and salinization of soils by means of suitable soil conservation works to be constructed and maintained. The utilisation of marshes, water sponges and water courses are also addressed.

In addition to the South African legal compliance list, the proposed development has also been assessed in terms of the International Performance Standards as detailed by the International Finance Corporation (IFC). These guidelines are needed if the proponent is to consider international funding. The IFC has developed a series of Performance Standards to assist developers and potential clients in assessing the environmental and social risks associated with a project and assisting the client in identifying and defining roles and responsibilities regarding the management of risk. Performance Standard 1 establishes the importance of:

Integrated assessment to identify the social and environmental impacts, risks, and opportunities of projects;

Effective community engagement through disclosure of project-related information and consultation with local communities on matters that directly affect them; and

The client’s management of social and environmental performance throughout the life of the project.

Performance Standards 2 through 8 establish requirements to avoid, reduce, mitigate or compensate for impacts on people and the environment, and to improve conditions where appropriate. While all relevant social and environmental risks and potential impacts should be considered as part of the assessment, Performance Standards 2 through 8 describe potential social and environmental impacts that require particular attention in emerging markets. Where social or environmental impacts are anticipated, the client is required to manage them through its Social and Environmental Management System consistent with Performance Standard 1. Of importance to this report are:

The requirements to collect adequate baseline data;

The requirements of an impact/risk assessment;

The requirements of a management program;

The requirements of a monitoring program; and most importantly;

To apply relevant standards (either host country or other). With regard to the application of relevant standards (either host country or other) there are no specific guidelines relating to soils and land use/capability, either locally or within the World Bank’s or IFC’s suite of Environmental Health and Safety Guidelines. The World Bank’s Mining and Milling, Underground guideline does state, however, that project sponsors are required to prepare and implement an erosion and sediment control plan. The plan should include measures appropriate to the situation to intercept, divert, or otherwise reduce the storm water runoff from exposed soil surfaces, tailings dams, and waste rock dumps.

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Project sponsors are encouraged to integrate vegetative and non-vegetative soil stabilisation measures in the erosion control plan. Sediment control structures (e.g., detention/retention basins) should be installed to treat surface runoff prior to discharge to surface water bodies. All erosion control and sediment containment facilities must receive proper maintenance during their design life. This will be included in the appropriate management plans when they are developed at a later stage in the project’s life cycle. 1.3 Summary of Baseline Findings This section is a summary of the 2007 baseline studies undertaken for the New Largo Project. For added detail please refer to the original data submitted (OX.NL.S.06.05.046 dated 08/05/2007). The information highlighted is regarded as the pertinent information required in order for the environmental impact assessment to be compiled, and the different options (Mine Plan 6 and Mine Plan 7) to be compared. The baseline soil and land capability specialist studies have highlighted a number of attributes and issues of concern relating to the proposed activities and actions being proposed. An understanding of the consequences and impacts of the actions are important in the development planning and the management of the mitigation measures required in obtaining a sustainable project. The findings of the baseline study (Refer to Report OX.NL.S.06.05.046 dated 08/05/2007) include the following general conclusions:

Highly variable depth characteristics occur, with relatively small areas of rocky outcrop and ferricrete exposure (< 400mm depth), and large areas of relatively deep (600mm to 800mm) to very deep (800mm to > 1500mm) in-situ derived soils that are often associated with cultivated lands and commercial livestock farming;

Generally moderate to low clay soils (10% to 25%) with low reserves of organic carbon (<0.5%) and resultant high potential erodibility on the sedimentary derived (in-situ) soils , to moderate clay (18% to 35%) contents, that are associated with better than average soil water holding characteristics (80 to 120mm/m) and moderate land capability potential on the more basic soils and colluvial/alluvial derived materials (lower slopes);

Poor nutrient stores in association with high permeability rates in the upper soil horizons and poor water holding characteristics for the sedimentary derived soils and impermeable to low permeability on the soils associated with the hydromorphic soils and transition zone materials (ferricrete layer – “C” Horizon) that underlies the relic land forms and lower slope positions in many cases;

A ferricrete layer that forms a relatively impermeable barrier to sub surface water infiltration, forming sub-surface ephemeral pans and palaeo channels (sub-surface), a zone of sensitivity (restrictive barrier) that has ecological ramifications;

Variations in the sensitivity of the soils to a change in utilization, their workability and reaction to being disturbed, and the relative ease of re-instatement when replaced on rehabilitation.

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The proposed development will impact on all of the differing soil forms, including the shallow rocky areas, deep well drained soils and wet to very wet (wetland) areas (Refer to Figure 2), with the open cast mining and associated infrastructure having a long term (30 years plus) and potentially a significantly high negative impact on the soil resource if not well managed. It is the concerns around the sensitivity of these important water contributing systems that has resulted in the alternatives analysis and the tabling of Mine Plan Option 7 as a possible sustainable option. The proposed areas of impact (Alternatives for Mine Plan 6 and Mine Plan 7 considered) recognises the possibility of wetlands associated with the non-perennial waterways, and as such has attempted to minimise the area of impact. It is however inevitable that some of the more sensitive materials may be affected. The idea of offsets has been mooted as a possible mitigation measure for the loss of biodiversity. As an alternative “Mine Plan Option 7” has been tabled as a sustainable option. This option incorporates as an “offset” the Northern Pan System (Refer to Figure 1b for an indication of the different mine plan options). The large pan in the north of the area (Northern Pan) is of significance by its extent as well as the depth and structure of the soils that surround the feature. The Northern Pan System is considered a Highly Sensitive area that requires consideration in terms of the unique biodiversity, while the deep to very deep sandy soils (moderate to high permeability) are of importance to the sustainability of the Pan System. The functionality of this system will require additional investigation for a full understanding of just how the soil water moves and is stored within the system. It is evident that the soils are an important feeder system to the pan and that the pan (inclusive of the deep soil buffer) is important in terms of biodiversity, and the maintenance of a unique ecology. The planned mining will affect some of the more ecologically and biophysically sensitive soils, albeit that in almost all cases the soils have already been impacted by other development (Intensive cultivation for the most part). These areas were highlighted in the scoping phase as “Sensitive” to “Highly Sensitive” areas that require better than average management if they are to be disturbed. The soil utilization plan (EMP) describes the management methods that should be employed in order to minimise and mitigate the effects on the soil resource. The variation in soil structure, texture and clay content of the soils combined with the presence of a ferricrete or hard setting saprolitic base (“C” Horizon) that is evident for many of the soils mapped makes for a complex of natural conditions that are going to be difficult to replicate in the rehabilitation stage and at closure. Management of the stripping of the materials (depth and soil type) and the responsible storage and maintenance of the stockpiles will aid in sustaining the soil resource for use at rehabilitation. The low levels of organic carbon and relatively low nutrient stores of some important nutrients within the top soils will require that a sound management plan is adopted. The concept of “utilizable soil” storage has been introduced as a basic management tool, and a function of good environment practise. The practicality of stripping the top soil and sub soil separately using large machinery has been noted as a problem, and the management plan recognises that topsoil and subsoil will easily be mixed and the important elements of the soil lost if the practicality is not addressed.

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The classification of the soils recognises the difference between soil depth (depth of soil to bedrock or a saprolitic/plinthic layer or “C” horizon) and “Effective Rooting Depth (ERD) (the depth of soil that the plants roots can utilize) as important in defining “Utilizable Soil”. Based on the understanding of the soil that a plant will/can use, and with the reconnaissance soil study available, a more practical stripping plan can be recommended. This involves the removal of all of the “utilizable” soil in one cut and will result in a relatively much deeper cut being stripped and stored as a separate unit from the deeper portion of the sub soil, ferricrete and soft (decomposed) overburden. The soils mapped range from shallow sub-outcrop and outcrop to moderately deep and very deep rooting profiles, with significant areas of wet based soils. As with any natural system, the transition from one system to another is often complex with multiple facets and variations that can grade over large distances. These transition zones are important in understanding the functionality of the pan systems and soil water relationship with the baseflow to the streams and rivers. It is important to better understand these functions if a working plan is to be formulated for rehabilitation purposes, and further studies will be needed. However, the act of stripping the soils, and if this resource is to be stored correctly (no mixing), then a much more simple plan of the materials present is needed. To this end, a plan showing the major soil groupings is tabled. This should be used as the working plan. Each of the major soil groups is considered in terms of the soil physical and chemical similarities, both of which are important factors when considering a soils workability and how it will react to being stored and replaced. In simplifying the trends mapped the following major soil groupings have been considered:

A group of generally very deep (> 800mm) sandy to sandy clay soils fine to medium grained sandy to silty clay loams that are associated with the development of in-situ materials, show no evidence of wetness within the profile, have better than average permeability rates (well drained) and average water holding capabilities. This group of soils are utilized for arable cultivation and are considered as good agricultural lands albeit that the nutrient pool requires additives if good returns are to be achieved. Working with and on this soil group is moderately easy at a range of moisture contents and the storage and management of these materials requires that they are protected from erosion and that the nutrient status and seed pool is protected. Some of these soils are also being mined for their sand content, an important consideration when considering the existing and cumulative impacts on the soil resource of the study area.

A group of moderately deep to deep (600mm to 800mm) sandy and sandy clay soils. These are considered along with the deep sandy soils to be of the better materials for agricultural and are extensively used for cultivation as well as livestock grazing. The well drained nature of these soils and their ability to sustain an annual crop that returns the national average (refer to land capability rating system) renders these soils of good agricultural value. Again as with the very deep soils, good management of these soils is necessary, but they are of the easier materials to work with if they are to be stripped and disturbed.

A group of moderately deep to deep (500mm to 800mm) wet based soils that are associated almost exclusively with the sub outcrop of a ferricrete layer at depth.

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This the zone of transition that is sometimes referred to as the buffer zone in terms of wetland delineation. This is an important zone as it is considered to be an integral part of the functionality of soil water and its association with the base flow to the surface water systems. These areas form a relatively small percentage of the overall area of study, but have a relatively large and very important function in the sustainability of the ecology of an area. Included in this broad grouping of soils are those associated with areas were the soil water is perched or retained close to surface, and results in the development of the “moist grassland” environments.

In contrast, but closely related spatially to the deep wet based soils are the group of more sensitive and very important (legally and environmentally) of shallow wet based soils. These soils are classified as having signs of wetness within 500mm of the surface and have been grouped separately as they constitute wetland soils. This group are generally higher in clay, have a restrictive layer as the “B” or “C” horizon and are poorly drained. The pan structures and the majority of the colluvial and/or transported soils associated with the streams and riverine environs return soils with these characteristics. As already stated, these are of the more sensitive and important soil forms that will need to be considered if they are to be impacted.

In addition, a group of very shallow and rocky soils are distinguished. These soils have as a distinct characteristic in that they are founded on hard rock. These soils are less than 400mm deep and show no signs of wetness.

All of the soils mapped are sensitive to erosion and compaction to varying degrees and, although tempered by the relative flatness of the terrain, will need a well formulated management plan were the soils are to be exposed (vegetation removed and top soils disturbed) and disturbed. In addition, the variable depth profiles of the materials that occur across the area of concern and the resultant depths of utilizable soil that can be stripped and stored will make for challenging management of the soil stripping during construction (stripping of the soils), the operational phase (storage of the soils) and at closure (rehabilitation and emplacement of stored soils). It is this challenge that needs to be addressed as part of the Soil Utilization Plan (Refer to section 3 of this document). The impact of development on the soils and the resultant change in the land capability is varied due to the unique differences associated with the colluvial derived materials (lower slopes and bottom lands), versus the in-situ derived soils. These factors will be important in the environmental assessment and final management plan tabled, with “separation” of materials forming the basis for a sustainable rehabilitation plan at closure. The moderately complex nature of the geology (physical and chemical), the geomorphology of the area, and the climate, all play a significant role in the soil forming processes, and have a bearing on the sensitivity and/or vulnerability of the materials when being worked on or disturbed. These factors are important not only in planning the construction and operational activities, but will determine the success of the rehabilitation planning for the future.

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Soil is fundamental to the ecological life cycle and the sustainability of the biosphere. The loss of the soil resource is directly connected to the sustainability of life as we know it in this environment and will have a profound effect on the End Land Use if it is not well managed and available for rehabilitation. 1.4 Study Team and Qualifications The team of specialists employed included a qualified soil scientist (pedologist) with a B.Sc. degree in the Earth Sciences and a technical assistant with a diploma in soil science (a total of 56 years of expertise between them), while the project was signed off by a professional earth scientist (Pr. Sci. Nat 400040/08). All laboratory analysis was undertaken by an accredited laboratory. The mapping and compilation of the findings of the site evaluation was compiled by a qualified GIS specialist. 1.5 Assumptions, Exclusions and Limitations The basis for these studies was the 2007 baseline information, with limitations to the accuracy of the field mapping based on the reconnaissance nature of the scale of mapping undertaken. Limitations in terms of the changes that might have occurred since 2007 are regarded as slight, with the exception of the sand mining that has occurred in the northern portions of the site. These activities will have had an impact on the cumulative impacts, but will have had little effect on the baseline soil forms present or the inherent capability of the land. These changes were not mapped or investigated in any detail. The alternatives assessment findings tabled by the client (Mining Plan Options 6 and 7) were used as the basis for the impact assessment. The wetland delineation as presented by the wetlands specialist was used as the basis for the identification of the highly sensitive and potential No Go areas, albeit that the soils mapping was used in the wetland delineation exercise. The limitations are associated with the scale of mapping used and the base map imagery available at the time.

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2. IMPACT ASSESSMENT

2.1 Impact Philosophy In line with the Terms of Reference supplied and the discussions had regarding the alternative options being considered for the mining of the coal at New Largo, the impact statements for the various mining alternatives is an important mechanism and aid in helping to decide on the most sustainable option. To this end, the well understood and accepted system of impact assessment developed as part of the South African Integrated Environmental Management Information Series (DEAT 2002) criteria and methodology developed by Theo Hacking (Hacking 1998). The following sections summarise the potential impacts associated with the proposed construction, operation and closure of the mining and its related infrastructure. and as a guideline in Impact Assessment philosophy, was used to assess two of the seven options that have been considered. Options 6 and 7 are considered to be the most feasible options in terms of the economic and engineering variables. The basic difference between the two mining plans is that Option 6 would mine the entire resource as delineated in the resource statement (Economics of the geology), while Option 7 would leave the area surrounding the northern pan out of the mining plan (Refer to Document entitled VOSSD Options and Impact – dated September 2011, and the Issues and Response document). The major activities have been assessed for these two options and the significance rating determined for the major impacts/effects envisaged using the system detailed in Table 2.1. This environmental impact assessment has been undertaken based on the Mine Plan Option 6 and compared to the outcomes for Mine Plan Option 7 (Refer to Figure 1b). The dominant soil polygon map has been used as the basis for the assessment (Please refer to Figures 2.1a and 2.1b). For ease of commentary and comparison the impact assessment for Option 7 has been dealt with as a separate chapter. However the comparison has been dealt with as part of the management and mitigation aspects of the actions and activities that are proposed. The Impact Assessment (Hacking) Methodology used is as follows: The “Significance Rating” of an impact is the product of the consequence and the probability while the consequence is a function of the severity of the impact its extent and the expected duration (Refer to Table 4 for Criteria for Assessing Impacts). i.e. Significance = consequence x probability,

Where: Consequence = severity + spatial extent + duration,

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Table 2.1 – Significance Rating System

H

M

L

L+

M+

H+

L

M

H

L

M

H

DURATION H Medium Medium Medium

M Low Low Medium

L Low Low Medium

DURATION H Medium High High

M Medium Medium High

L Low Medium Medium

DURATION H High High High


L Medium Medium High

L M H

Localised Fairly widespread Widespread

Within site

boundary

Beyond site

boundary

Far beyond site

boundary

Site Local Regional/ national

PROBABILITY H Medium Medium High

(of exposure to

impacts)


L Low Low Medium

L M H

*H = high, M= medium and L= low and + denotes a positive impact.

PART A: DEFINITION AND CRITERIA*

Definition of SIGNIFICANCE Significance = consequence x probability

Definition of CONSEQUENCE Consequence is a function of severity, spatial extent and duration

Criteria for ranking of the SEVERITY of

environmental impacts

Substantial deterioration (death, illness or injury). Recommended level will often be violated.

Vigorous community action. Irreplaceable loss of resources.

Moderate/ measurable deterioration (discomfort). Recommended level will occasionally be

violated. Widespread complaints. Noticeable loss of resources.

Minor deterioration (nuisance or minor deterioration). Change not measurable/ will remain in

the current range. Recommended level will never be violated. Sporadic complaints. Limited loss

of resources.Minor improvement. Change not measurable/ will remain in the current range. Recommended

level will never be violated. Sporadic complaints.

Moderate improvement. Will be within or better than the recommended level. No observed

reaction.Substantial improvement. Will be within or better than the recommended level. Favourable

publicity.

Criteria for ranking the DURATION of

impacts

Quickly reversible. Less than the project life. Short term

Reversible over time. Life of the project. Medium term

Permanent. Beyond closure. Long term.

Criteria for ranking the SPATIAL SCALE

of impacts

Localised - Within the site boundary.

Fairly widespread – Beyond the site boundary. Local

Widespread – Far beyond site boundary. Regional/ national

PART B: DETERMINING CONSEQUENCE

SEVERITY = L

Long term

Medium term

Short term

SEVERITY = M

Long term

Medium term

Short term

SEVERITY = H

Long term

Medium term

Short term

SPATIAL SCALE

PART C: DETERMINING SIGNIFICANCE

Definite/ Continuous

Possible/ frequent

Unlikely/ seldom

CONSEQUENCE

Medium It should have an influence on the decision unless it is mitigated.

Low It will not have an influence on the decision.

PART D: INTERPRETATION OF SIGNIFICANCE

Significance Decision guideline

High It would influence the decision regardless of any possible mitigation.

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Figure 2.1a – Plan of Mining (Mine Plan Version 6)

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Figure 2.1b – Alternative Plan of Mining (Mine Plan Version 7)

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2.2 Impact Assessment Variables

Of consequence to the soils and land capability resources that will be affected, are the relatively deep open cast dragline operations and the smaller open cast roll over truck and shovel sections. These activities and the related support aspects (haulage roads, access ways etc.) will have a moderate to high negative impact on the physical and socio economic state of the environment. The activities planned are invasive on the soil resource as they will cover a significantly large area, traversing a vast variety of different soil forms and geomorphological terrain that exhibit differing characteristics and will be affected for a significant period of time. The methods proposed will however re-instate the soils as the mining operation progresses, thus reducing the area of impact. To this end the process is considered reversible in terms of material replacement, the ultimate test being the management of the soil utilization plan that is to be used in replacing the materials. It is the objective of this impact assessment that the effects of the various activities is well understood, and that a practical plan of soil removal, storage and re-instatement is developed that will aid in the attainment of the goal of “no net loss”. In consideration of the affects that the mining venture could have on the environment, the following issues and activities are regarded as relevant: These issues are relevant to both mining options, albeit that Option 7 will offset the impacts on the sensitive wet base soils and wetlands by leaving the Northern Pan system out of the mining area.

The extremes of area that will be disturbed by the open cast mining;

The sensitive ecological and biodiversity aspects that are to be impacted;

The depth of impact due to open cast nature of the mining and the need for foundations for the larger infrastructure and support activities and the disturbance of the complete soil profile;

The length of time that the soils will need to be stored and managed (30 years plus);

The sequence of mining and extent of open void that exists at any moment in time (Roll over method proposed);

Any mine layout is primarily defined by the presence and position of the mineralised or minable reserves, its position in the geological sequence, and the surface footprint available (land tenure). The options for minimising or mitigation of the impacts of the resource development are restricted to the method of mining that is chosen (open cast versus underground mining, and the limiting or sterilization of resource by limiting the amount of mined area. There are limited opportunities for alternative placement of the majority of the waste (overburden and or rock) that will need to be stripped and stored as this needs to be placed in close proximity to the mining if it is to be replaced successfully in the correct position. However, the associated infrastructure can more easily be positioned, albeit within a reasonable distance of the resource. Where practical, the baseline (dominant soils plan) soils have been used to define alternative placement positions for overburden were it was identified there was the potential that overburden could be placed onto highly sensitive and/or wetland soils. This was necessary as the potential loss of these soils would affect ecosystem functionality.

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Variation in the soil characteristics (physical and chemical) have a bearing on the ease with which the materials can be worked and the degree of difficulty of storage. This is sometimes measured in terms of the “sensitivity” of a soil and has been used as the basis for the impact assessment and ultimately the management plan that is detailed in section 4. 2.3 Impact Drivers The mining activities associated with this project are likely to change soil baseline conditions in the following ways: The construction of infrastructure and the opening up of large open voids for open cast mining will result in a loss of soil resource and the loss of land capability due to sterilisation of the materials for significant periods of time. During construction, significant areas of soil will be needed for the stockpiling and storage of overburden and interburden. The footprint area of these dumps will be lost from the landscape, along with areas required for the support infrastructure in terms of spatial extent and utilization potential. The removal and storage of the soils associated with these footprints will also need to be stripped/removed and stored. The footprint to the storage areas will need to be compacted and engineered. There is also the potential that contaminants from various infrastructures within the mine area (salts, acids and hydrocarbons) may be transported by water from the infrastructure areas to the soils on the perimeter of the infrastructure. If these salts then accumulate in the soils, resulting in the build-up of contamination, there is the potential that this resource will be lost, resulting in an irreversible change in land capability. This will occur if good housekeeping practices and storm water management measures are not implemented early in the project. Salinization of soils may also occur under temporary stockpiles and discard facilities, if the soils are not appropriately stripped ahead of deposition. This will occur if seepage through a stockpile or overburden or interburden dump, mobilises contaminants which then enter the soil profile below the facility. If the soils below the facility were not appropriately stripped ahead of deposition, the removal of the stockpile or dump could result in a contaminated soil footprint at the end of the life of the operation. The loss of this resource will result in a change in land capability (bearing in mind that the focus of the Chamber of Mines system is suitability for use as agricultural soils or food production) from arable land, grazing, wilderness (conservation) to unavailable. The construction of infrastructure (access ways and haulage routes) and the opening up of the boxcut ready for the open cast strip mining will lead to increased erosion resulting in a loss of soil resources. If adequate water management measures are not implemented, there is the potential that the soils exposed as a result of the mining activities or soils on the perimeter of the infrastructure, may be exposed to greater water velocities than would occur if covered by vegetation. This exposure (removal of vegetation and soil) will result in an increase in overland water flow velocity which could lead to erosion followed by sedimentation in the downstream areas. The current land use in most parts of the proposed mine area is cultivated annual crops and livestock grazing. Very little natural grasslands or woodlands exist. However the proposed open cast mining and construction of infrastructure will change the land use to mining and/or industrial.

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2.4 Analyses of Impacts For the purposes of this assessment, the relative impacts for each of the mine plan options have been subdivided into the different phases of the mining life cycle (construction, operations and closure) and the comparable impact drivers rated and compared. 2.4.1 Construction Phase Issue - Loss of utilisable resource (sterilization and erosion), compaction and

contamination or salinization. The construction phase will require:

The stripping of all utilisable soil (Top 500mm to 750mm depending on activity); The preparation (levelling and compaction) of lay-down areas, foundations and

pad footprint areas for stockpiling of utilisable soil removed from the footprint of the open cast mining area, the soft overburden stockpile and the construction of the storm water control facility(s) inclusive of berms and trenches to divert clean water around the mine workings;

The clearing, stripping and stockpiling from the construction of all access and haulage roads, water supply and electrical power supply servitudes (linear infrastructure);

The use of heavy machinery over unprotected soils; The creation of dust and loss of materials to wind and water erosion, and The possible contamination of the soils by chemical and hydrocarbons spills

(dust and dirty water runoff); The noted (baseline study) differences in the texture of the various soils, the soil depth variations, composition of the “C” horizon (hard rock versus ferricrete), wetness of subsoil’s and the structure of the different soil groupings is of significance to the impact assessment and the sensitivity that is assigned to the different soil groups and land capability ratings. The difference in the significance of the expected impacts based on soil form or group alone will have an influence on the management recommendations and mitigation methods employed. The assessment is confined to the project footprint and its immediate surroundings, and as such the “spatial scale is regarded as “Low” or “Localised”. The degree of impact for the individual activities is the same or similar for the two options being considered. However, differences in the two proposed mining options are significant when the percentage of “Highly Sensitive Soil” or “No Go” areas (legal restrictions based on soil wetness and wetland status) are compared for the two options. Option 7 has significantly less overall impact on the pans and wetland status soils compared with Option 6. The size/extent of the open cast voids being proposed and the support infrastructure proposed for the project includes large and deep founding excavations (water dams) which will entail the removal of the complete soil profile and soft overburden in places. The haulage and conveyencing routes will require that heavy vehicles and loads are moved along these routes, requiring strong and stabilized foundations with moderate to deep excavation and engineering of the sub base. The access roads and general service ways will require less engineering and will not be as invasive on the natural materials. These soils will all however be sterilised and lost from the system for the life of the operation.

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A number of temporary facilities might be required during the construction phase of the project and possibly into the early stages of the operation. These will be available for rehabilitation if not needed into the operational phase. Impact Significance

The loss of the utilisation of the soil resource will impact the land use practice of commercial farming (cultivated lands and livestock grazing) that is the major activity on these lands at present. These activities are perceived to be of great economic benefit to the local economy and land owners, albeit that the proposed project is to be undertaken on land that is owned by the proponent, and the crop being grown is for the most part in over supply in the country at present (Please refer to the agro economic studies – J. Tolmey for additional findings in this regard). The open cast strip mining and roll over truck and shovel operations will if un-managed and without mitigation result in:

A definite negative impact on the environment due to the loss of the land capability and land use (soil source);

The potential for contamination (hydrocarbon and reagent chemical spills, raw materials and spillage of product),

Compaction of working/laydown areas and the waste storage facility footprints and soil stockpiles

The potential to cause erosion (wind and water – dust and suspended solids) over unprotected areas;

Destruction of ecologically sensitive habitats; These impacts are likely to continue throughout the construction phase and into the operational phase, and although these actions and impacts are reversible (can be backfilled, broken down and rehabilitated), they will be in place for a significant period of time (Life of mine +55 years). All of these impacts will be confined to the site. However, with management, the loss, degree of contamination, compaction and erosion of this primary resource can be mitigated and reduced to a level that is more acceptable. The reduction in the significance of the impact can be achieved by:

Limiting the area of impact to as small a footprint as possible, inclusive of waste

management facilities, resource stockpiles and the length of servitudes, access and haulage ways wherever possible;

Construction of the mining facilities and associated infrastructure on the less sensitive soil groups

Development of Offsets to compensate for the destruction of ecologically sensitive or No Go areas;

An awareness of the length of time that the resource will need to be stored and managed (life of the mining venture and potentially beyond if the facilities are to be used for other mining ventures after the life of this project);

The development and inclusion of soil management as part of the housekeeping operations, and the independent auditing of the management;

Effective soil stripping during the less windy months when the soils are less susceptible to erosion;

Separation of the utilisable soils and inhibiting ferricrete base materials from each other and from the soft overburden;

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Effective cladding of the berms and materials stockpiles/heaps with vegetation or

large rock fragments, and the minimising of the height of storage facilities to 15m and utilizable soil storage berms to 1,5m wherever possible;

Restriction of vehicle movement over unprotected or sensitive areas. This will

reduce compaction; Soil amelioration (cultivation) to enhance the oxygenation and growing capability

(germination) of natural regeneration and/or seed within the stockpiled soils (maintain the soils viability during storage) and areas of concurrent rehabilitation.

It is evident that, failure to manage the impacts on this important resource (soil) will result in the total loss of this resource, with a resultant much higher significance rating, and this will in turn affect the contribution of water to the base flow of the rivers.

Table 2.4.1 - Construction Phase Impact Significance

Management Severity Duration

Spatial Scale

Consequence

Probability of

Occurrence

Significance

Unmanaged H M L M H M

Managed M M L L M L

Residual Impact (Post Mitigation) The above management procedures will likely reduce the significance of the impacts to moderate in the medium term. 2.4.2 Operational Phase

Issue Loss of utilisable resource (Sterilisation and erosion), compaction,

de-nutrification and contamination and/or salinisation. The operational phase of the proposed mining project will see the impact of transportation of reagents (Explosives etc.) and additives into the area, and raw materials being transported to the plant. The potential for spillage and contamination of the in-situ and surrounding/bordering soils and the stockpiled materials due to dirty water run-off and/or contaminated dust deposition/dispersion, the de-nutrification of the stockpiled soils due to excessive through flow of rain water on unconsolidated and poorly protected soils, the flushing of the soil nutrients by rain water on unprotected soils and the impact on the more sensitive materials is probable if un-managed. In addition, the potential for compaction of the in-situ materials by uncontrolled vehicle access and movement and the loss of the soil resource from the environment (down-wind and downstream) by wind and water erosion over un-protected ground will need to be considered. In summary, the mining operation and actions of the support activities will result in:

The possible sterilisation of the soil resource on which the resource is mined and the facilities are constructed (Haulage roads etc.). This will be an on-going loss for the duration of the operation;

The creation of dust and the possible loss (erosion) of utilisable soil down-wind and/or downstream and the siltation of the local streams and waterways;


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The contamination of the in-situ and stored soils by dirty water run-off and or

spillage of hydrocarbons from vehicle and machinery or from dust and emissions from the process;

The contamination and impact of sensitive materials located on or in close proximity (bordering) the mining venture and their loss from the system;


Contamination of soil resource by dust and emission fallout; Sterilisation and loss of soil nutrient pool, organic carbon stores and fertility of

stored soils; Impact on soil structure and soil water balance and the impact on the base flow to

the local catchment. Un-managed soil stockpiles and soil that is left uncovered/unprotected will be lost to wind and water erosion, will lose the all-important, albeit moderately poor nutrient content and organic carbon stores (fertility) and will be prone to compaction. The rehabilitation of the temporary infrastructure that was used during the start-up and construction phase, and the on-going rehabilitation of the mining pits (roll over methods of mining) will result in an improvement and relative positive impact due to the reduction in the area of disturbance. Impact Significance The result of the mining and related support activities on the soil resource will have a negative intensity potential that is moderate to high, will last for the life of the operation and be confined to the immediate site or immediate vicinity. In the un-managed scenario the frequency is likely to be continuous resulting in a significance rating of high. It is inevitable that some of the soils will be lost during the operational phase if they are not well managed and a mitigation plan is not made part of the general mine management schedule. The impacts on the soils during the operational phase (stockpiled, peripheral soils and downstream (wind and water) materials) may be mitigated with management procedures including:

Minimisation of operations on areas of High Sensitivity or on legally defined “No

Go” areas; Minimisation of the area that can potentially be impacted (eroded, compacted,

sterilized or de-nutrified); Timeous replacement of the soils so as to minimise/reduce the area of affect

and disturbance; Effective and timeous soil cover and adequate protection from wind (dust) and

dirty water contamination – vegetate and/or rock cladding; Regular servicing of all vehicles in well-constructed and bunded areas; Regular cleaning and maintenance of all haulage ways, access routes and

service ways, drains and storm water control facilities; Containment and management of spillage; Soil replacement and the preparation of a seed bed to facilitate and accelerate

the re-vegetation program and to limit potential erosion on all areas that become available for rehabilitation (temporary servitudes), and

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Soil amelioration (rehabilitated and stockpiled) to enhance the growth capability

of the soils and sustain the soils ability to retain oxygen and nutrients, thus sustaining vegetative material during the storage stage.

It will be necessary as part of the development plan to maintain the integrity of the stored soils, so that they are available for rehabilitation at decommissioning and closure. If the soil quantities (sufficient soil stripped and stored) and qualities (utilisable soils) are managed through the operational phase, rehabilitation costs will be reduced and natural attenuation will more easily and readily take effect and a sustainable “End Land Use” achieved. Residual Impact (Post Mitigation)

In the long term (Life of the operation) and if implemented correctly, the above mitigation measures will reduce the impact on the utilisable soil reserves (erosion, contamination, and sterilisation) to a significance rating of medium to low. However, if sufficient of the utilizable soil is not retained/stored and managed, if a workable management plan is not implemented, the residual impact remain high and will definitely incur additional costs and result in the impacting of secondary areas (Borrow Pits etc.) in order to obtain cover materials etc.

Table 2.4.2 Operational Phase – Impact Significance

Management Severity Duration Spatial Scale

Consequence Probability Significance

Unmanaged H M L M H H

Managed M M L M M L/M

2.4.3 Decommissioning & Closure Phase

Issue: Net loss of soil volumes and utilisation potential due to change in material

status (Physical and Chemical) and loss of nutrient base. The impacts on the soil resource during the decommissioning and closure phase are both positive and negative, with:


Erosion and de-oxygenation of materials while stockpiled; Compaction and dust contamination due to vehicle movement while rehabilitating

the area; Erosion due to slope stabilization and re-vegetation of disturbed areas; Contamination of replaced soils by use of dirty water for plant watering and dust

suppression on roads and haulage ways; Hydrocarbon or chemical spillage from contractor and supply vehicles on roads and

haulage ways;

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An improvement (positive impacts) due to the reduction in areas of disturbance and

return of soil utilisation potential, uncovering of areas of storage and rehabilitation of compacted materials.

Impact Significance The impact will remain the net loss of the soil resource if no intervention or mitigating strategy is implemented. The intensity potential will remain high and negative for all of the activities if there is no active management (rehabilitation and intervention) in the decommissioning phase, and closure will not be possible. This will result in an irreversible impact that is continuous. However, with interventions and well planned management, there will be medium to medium high intensity potential as the soils are replaced and fertilisation of the soils is implemented after removal of the infrastructure. Ongoing rehabilitation during the operational (temporary infrastructure used during exploration and construction phase) and decommissioning phases will bring about a net long-term improvement on the impact on the soils, albeit that the land capability will likely be reduced to wilderness status. The intensity potential of the initial activities during rehabilitation and closure will be medium and negative due to the necessity for vehicle movement while removing the demolished infrastructure and rehabilitating the operational footprint(s). Dust will potentially be generated and soil will probably be contaminated, compacted and eroded to differing extents depending on the degree of management implemented. The net improvement on the impacts of rehabilitation on the area are the reduction in the footprint of disturbance, the amelioration of the affected soils and oxygenation of the growing medium, the stabilizing of slopes and the revegetation of disturbed areas. Residual Impacts (Post Mitigation)

On closure of the mining operation and its associated activities the long-term negative impact on the soils will be reduced from a significance ranking of moderate to low if the management plan set out in the Environmental Management Programme is effectively implemented. Chemical amelioration of the soils will possibly have a low but positive impact on the nutrient status (only) of the soils in the medium term.

Table 2.4.3 Decommissioning and Closure Phase – Impact Significance

Management Severity Duration

Spatial Scale Consequence

Probability Significance

Unmanaged H H L H H H

Managed M+ M L M H M/L+

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At closure (obtaining of certificate of closure from authorities) the residual impact should, if all rehabilitation and management efforts have been complied with, result in a net improvement (positive) impact, with the area being returned to a land capability of low intensity grazing or wilderness status (similar to the original land capability prior to development), and the use of the land being returned to that of livestock management (current sustainable dry land use). 2.5 Cumulative Impacts As part of any impact assessment process it is incumbent on the specialist to consider any/all outside influences that might add to the local impacts that are to be created by the project in question. To this end, the New Largo Mining Project will be impacted by the Kusile Power generation Plant and the conveyencing and processing of the raw materials produced and transported by the operation and its associated mining operations in the vicinity. Currently, there are potential sources of similar impact from other coal mines operating or planned to the south and east of New Largo, as well as the beneficiation plant to the south of the proposed operation, and then the planned transportation of the coal from the process plant to the power station via a conveyor system to the south and west of the mining area. These impacts are likely to occur as a result of the project and not as stand-alone activities, and as such will need to be considered as part of the overall impact that will occur. If the new Largo Mining Project does not materialise, these impacts will not be an issue. Kusile Power Station is at an advanced stage of construction and adds to the cumulative impacts on the availability of land in the area. EEven if the new Largo Colliery does not materialise (coal found from another source), the Phola-Kusile Coal Conveyor will proceed, bringing coal to Kusile via the Phola Coal Processing Plant, located to the south near Kendal Power Station. The cumulative impacts on the soils and land capability are confined mainly to the overall reduction in the resource and the potential loss of utilizable materials that have the ability to produce agricultural products. The overall loss of resource due to erosion, compaction and contamination is unlikely to be an issue in terms of cumulative effects as these constraints are site specific. , The loss of land capability and a change in land use associated with other developments (Additional mining, power stations etc.) could result in an added loss of livelihood for the present/existing communities. Further pressures could arise if there is an influx of job seekers to the region.

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3. ENVIRONMENTAL MANAGEMENT PROGRAMME

In following the spirit of environmental sustainability, it is important that the studies not only assess the potential effects that the mining activities might have on the environment, but also recommends realistic actions that can be taken as part of a management plan that will minimise and mitigate the effects to a reasonable (acceptable) limit or standard. The management of the natural resources (soils and land capability) have been assessed on a phased basis (construction, operation and decommissioning/closure) in keeping with the impact assessment (EIA) philosophy, while the Environmental Management Plan (EMP) has been designed as a working plan and utilization guide for soil and land management based on the Anglo Coal Environmental Services – Soil Stripping for Anglo Coal Mines (A utilization Std) - Mr. M.E. Aken (March 2005). The results tabled are based on the site specific soil characterisation and classification in conjunction with the geomorphology (topography, altitude, attitude, climate and ground roughness) of the areas that will be impacted or affected. The baseline reconnaissance studies undertaken in 2007 have been used as the basis for the assessment and resultant recommendations made. The proposed soil utilization plan gives recommendations on the stripping and handling of the soils throughout the life of the development along with recommendations on the handling of the soils when being replaced during the rehabilitation and at closure. It has been assumed that all infrastructure will be removed and that the areas affected will be returned to as close as possible their natural ecological state/condition (topographic levels and attitude, low intensity grazing and wilderness status (Refer to the Chamber of Mines Land Classification System (Refer to Section 2 - Table 2.2.1 of the Baseline Study), and that the landscape will be free draining and of a condition of stand-alone maintenance (erosion will be self-repairing and vegetative cover can withstand the climatic extremes). The concept of stripping and storage of all “Utilizable” soil is recommended as a minimum requirement and as part of the overall “Soil Utilization” philosophy. Significant debate has been had around the idea of removing “all soil” to a depth of two (2m) metres where it is present. Although some positive outcomes are possible, it is the opinion of this study that the negative outcomes far out way the positive. The potential dilution of the nutrient pool due to the mixing of saprolitic material construed to be good quality soil and the loss of the soils growth potential is possibly the most important loss that would occur, while the cost of removing and transporting this large quantity of soil to stockpile areas is likely to be very large. The advantages are understood to be associated with the water holding capability that would benefit the soil water environment and the contribution of the soil water to the ecological processes and systems at closure. A lot more scientific information is needed before this debate can be argued with any degree of satisfaction. It will be necessary to understand the soil water system better, the soil characteristics that are holding the water within the profile and why the water is moving horizontally through the system rather than vertically into the underlying aquifers.

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These factors are all important to an understanding of the potential for these aspects to be recreated during the rehabilitation process. There will be no point in removing and storing large quantities of soil at great cost if the required conditions cannot be re-created at closure. In terms of the Anglo Coal Environmental Policy, “usable or utilizable soil” is defined as all soil above an agreed subterranean cut-off depth defined by the project soil scientist, and will vary for different forms of soil encountered in a project area and the type of project being considered. It does not differentiate between topsoil (orthic horizon) and other subsoil horizons necessarily.

The following soil utilization guidelines (all be they generic) should be adhered to wherever possible:

Over areas of deep excavation (Open Pit Mining or Deep excavations/foundations where the majority or all of the soil profile is to be impacted) strip all usable soil as defined (750mm) in terms of the soil classification and stockpile as berms or low, terraced dumps. Alluvial soils should be stockpiled separately from the colluvial (shallower) and in-situ derived materials, which in turn should be stored separately from any ferricrete material, while the soft overburden is stored as a separate unit, as a defined dump of less than 15m in height preferably. Protect from contamination and erosion by rock cladding or vegetation cover and adequate drainage of surface runoff. At rehabilitation replace the soft overburden followed by the ferricrete, compact followed by the soil to appropriate soil depths, and cover areas to achieve an appropriate topographic aspect and attitude to achieve a free draining landscape as close as possible the pre-mining/construction land capability rating.

Over areas planned for less invasive structures (Offices, Workshops etc.) and any material stockpile or storage, strip the top 500 mm of usable soil over all affected areas including terraces and strip remaining usable soil and ferricrete (if present in profile) where founding conditions require further soil removal. Store the soil in stockpiles or berms of not more than 1.5 m around infrastructure area ready for closure rehabilitation purposes. Stockpile hydromorphic (wet) soils separately from the dry materials, and the “ferricrete” separately from all other materials. Protect all stockpiles from water and wind erosion (loss of materials) and contamination by dust and runoff water. Clad stockpiles with larger rock or vegetate the stored materials. At closure/rehabilitation, remove all large boulders and gravel from the rehabilitated landscape and place at the base/bottom of the open pit or rehabilitation profile so that they do not interfere with the tillage and cultivation of the final surface. Remove foundations to a maximum depth of 1m. Replace soil to appropriate soil depths, and over disturbed areas and in appropriate topographic position to achieve pre-development land capability and land form where possible.

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Over areas of Tailings Storage facilities, Waste Rock Dumps and all Heavy Vehicle Haulage Roads and Major Access Routes, strip usable soil to a depth of 750 mm where possible and/or in areas of arable soils and between 300mm and 500mm in areas of soils with grazing land capability. Stockpile hydromorphic soils separately from the dry and friable materials. Before rehabilitation remove all gravel and other rocky material and recycle as construction material or place in open voids. Remove foundations to a maximum depth of 1m. Replace soil to appropriate soil depths and in appropriate topographic position so as to achieve pre-mining land capability. Protect the stored materials from erosion and contamination using vegetation or rock cladding.

Over areas to be utilized for General Access Roads (light delivery vehicles), Laydown Pads and any Conveyencing servitudes (Above ground pipelines and power line servitudes)strip the top 150 mm of usable soil over all affected areas and stockpile in longitudinal stockpile or berms upslope of the facilities. Protect from erosion and contamination.

3.1 Construction Phase The construction methods and final end land use are important in deciding if the utilizable soils need to be stripped and retained, and ultimately how much of the materials will be needed for the rehabilitation (stripping volumes). Failure to remove and store the utilizable materials will result in the permanent loss of the growth medium. Making provision for retention of utilizable material for the decommissioning and/or during rehabilitation will not only save significant costs at closure, but will ensure that additional impacts to the environment do not occur. Table 3.1 is a summary of the soil utilization guide proposed to aid in soil management during the construction phase. The depths of utilizable materials vary between 150mm and greater than 1,500mm. However, due to the shallow soil depths on the more rocky areas, albeit that these are a small percentage of the overall area, it is recommended that sufficient materials are removed from the areas were the soil depths are present and do exist, so that the shallow areas can be adequately resorted during rehabilitation and at closure. The majority of the area proposed for the open cast mining and its associated infrastructural development is considered as moderate to low sensitivity and the soils are sufficiently similar that they can be stored as one soil group. However, the limited but highly sensitive soils and wet based materials should not be compromised. Table 3.1 describes the proposed utilization of the soils during the construction phase.

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Table 3.1 – Construction Phase – Soil Utilization Plan


Stripping will only occur where soils are to be disturbed by activities that are

described in the design report, and where a clearly defined end rehabilitation use

for the stripped soil has been identified.

It is recommened that all vegetation is stripped and stored as part of the utilizable

soil. However, the requirements for moving and preserving fauna and flora

according to the biodiversity action plan should be consulted.

Handling

Soils will be handled in dry weather conditions so as to cause as little compaction as

possible. Utilizable soil (Topsoil and upper portion of subsoil B2/1) must be

removed and stockpiled separately from the lower "B" horizon, with the ferricrete

layer being seperated from the soft/decomposed rock, and wet based soils

seperated from the dry soils if they are to be impacted.

Stripping

The "Utilizable" soil will be stripped to a depth of 700mm or until hard

rock/ferricrete is encountered. These soils will be stockpiled together with any

vegetation cover present (only large vegetation to be removed prior to stripping).

The total stripped depth should be 700mm, wherever possible.

Location

Stockpiling areas will be identified in close proximity to the source of the soil to

limit handling and to promote reuse of soils in the correct areas. All stockpiles will

be founded on stabilized and well engineered "pads"

Designation of AreasSoils stockpiles will be demarcated, and clearly marked to identify both the soil

type and the intended area of rehabilitation.

Delineation of areas to be stripped

Reference to biodiversity action plan

Stripping and

Handling of soils

Delineation of

Stockpiling areas

Co

nst

ruct

ion

This “Soil Utilization Plan” is intimately linked to the “development plan”, and it should be understood that if the plan of construction changes, these recommendations will probably have to change as well. 3.2 Operational Phase The operational phase will see very little change in the development requirements, with the footprint of disturbance remaining constant, albeit that the temporary infrastructure might become redundant and rehabilitation of these features might be possible. The open cast mining will progress in a sequence and follow the roll over method of mining with each subsequent cut being open and the previous cut closed behind it. In this way a minimum footprint of disturbance will be maintained. Maintenance and care of the soil and land resources will be the main management activity and objective required during the operational phase. Management of material loss, compaction and contamination are the main issues of consideration. Table 3.2 details recommendations for the care and maintenance of the resource during the operational phase. The semi-arid climate and unique character of the soils in these areas require that the site specific and unique natural phenomena should be used to the advantage of the project. Working with or on the differing soil materials (all of which occur within the areas that are to be disturbed) will require better than average management and careful planning if rehabilitation is to be successful, and it is important that the sensitive and highly sensitive materials are avoided wherever possible from the outset.

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Care in removal and stockpiling or storage of the “Utilizable” soils, and protection of materials which are derived from the “hardpan ferricrete” layer is imperative to the success of sustainable rehabilitation in these areas, with the soil water (near surface water) held within the profile by the ferricrete layer believed to be integral to the success of the biodiversity and ecological systems.

Table 3.2– Operational Phase – Soil Conservation Plan


Vegetation

establishment and

erosion control

Enhanced growth of vegetation on the Soil Stockpiles and berms will be promoted

(e.g. by means of watering and/or fertilisation), or a system of rock cladding will be

employed. The purpose of this exercise will be to protect the soils and combat

erosion by water and wind.

Storm Water ControlStockpiles will be established/engineered with storm water diversion berms in

place to prevent run off erosion.

Stockpile Height and

Slope Stability

Soil stockpile and berm heights will be restricted where possible to <1.5m so as to

avoid compaction and damage to the soil seed pool. Where stockpiles higher than

1.5m cannot be avoided, these will be benched to a maximum height of 15m. Each

bench should ideally be 1.5m high and 2m wide. For storage periods greater than 3

years, vegetative (vetiver hedges and native grass species - refer to Appendix 1) or

rock cover will be essential, and should be encouraged using fertilization and

induced seeding with water and/or the placement of waste rock. The stockpile side

slopes should be stabilized at a slope of 1 in 6. This will promote vegetation growth

and reduce run-off related erosion.

Waste

Only inert waste rock material will be placed on the soil stockpiles if the vegetative

growth is impractical or not viable (due to lack of water for irrigation etc.). This will

aid in protecting the stockpiles from wind and water erosion until the natural

vegetative cover can take effect.

VehiclesEquipment, human and animal movement on the soil stockpiles will be limited to

avoid topsoil compaction and subsequent damage to the soils and seedbank.

Op

era

tio

n

Stockpile

management

3.3 Decommissioning and Closure The decommissioning and closure phase will see:

The removal of all infrastructure;

The demolishing of all concrete slabs and ripping of any hard surfaces;

The backfilling of any open voids and deep foundations and the reconstruction of the required barrier layer (compaction);

Topdressing of the disturbed and backfilled areas with the stored “utilizable” soil ready for re-vegetation;

Fertilization and stabilization of the backfilled materials and final cover materials (soil and vegetation) and

The landscaping of the replaced soils to be free draining. There will be an improvement on the soil and land capability environments as the area of disturbance is reduced, and the soils are returned to a state that can support low intensity grazing (Highveld Grasslands).

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Table 3.3 is a summary of the proposed management and mitigation actions recommended

Table 3.3 – Decommissioning and Closure Phase – Soil Conservation Plan


Placement of Soils

Stockpiled soil will be used to rehabilitate disturbed sites either ongoing as

disturbed areas become available for rehabilitation and/or at closure. The utilizable

soil (500mm to 700mm) removed during the construction phase, must be

redistributed in a manner that achieves an approximate uniform stable thickness

consistent with the approved post development end land use (Conservation land

capability and/or Low intensity grazing), and will attain a free draining surface

profile. A minimum layer of 300mm of soil will be replaced.

Fertilization

A representative sampling of the stripped and stockpiled soils will be analysed to

determine the nutrient status and chemistry of the utilizable materials. As a

minimum the following elements will be tested for: EC, CEC, pH, Ca, Mg, K, Na, P,

Zn, Clay% and Organic Carbon. These elements provide the basis for determining

the fertility of soil. based on the analysis, fertilisers will be applied if necessary.

Erosion ControlErosion control measures will be implemented to ensure that the soil is not washed

away and that erosion gulleys do not develop prior to vegetation establishment.

Pollution of Soils In-situ Remediation

If soil (whether stockpiled or in its undisturbed natural state) is polluted, the first

management priority is to treat the pollution by means of in situ bioremediation.

The acceptability of this option must be verified by an appropriate soils expert and

by the local water authority on a case by case basis, before it is implemented.

Off site disposal of

soils.

If in situ treatment is not possible or acceptable then the polluted soil must be

classified according to the Minimum Requirements for the Handling, Classification

and Disposal of Hazardous Waste (Local Dept of Water Affairs) and disposed of at an

appropriate, permitted, off-site waste facility.

Rehabilitation of

Disturbed land &

Restoration of

Soil Utilization

Dec

omm

issi

onin

g &

Clo

sure

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4 MONITORING AND MAINTENANCE

Nutrient requirements reported herein are based on the monitoring and sampling of the soils at the time of the baseline survey. These values will definitely alter during storage and will need to be re-evaluated before being used during rehabilitation. Ongoing evaluation of the nutrient status of the growth medium will be needed throughout the life of the project and into the rehabilitation phase. During the rehabilitation exercise preliminary soil quality monitoring should be carried out to accurately determine the fertilizer requirements that will be needed. Additional soil sampling should also be carried out annually until the levels of nutrients, specifically magnesium, phosphorus and potassium, are at the required levels for sustainable growth. Once the desired nutritional status has been achieved, it is recommended that the interval between sampling is increased. An annual environmental audit should be undertaken. If growth problems develop, ad hoc, sampling should be carried out to determine the problem.

Monitoring should always be carried out at the same time of the year and at least six weeks after the last application of fertilizer. Soils should be sampled and analysed for the following parameters:

pH (H2O) Phosphorus (Bray I) Electrical conductivity Calcium mg/kg Cation exchange capacity Sodium mg/kg; Magnesium mg/kg; Potassium mg/kg Zinc mg/kg; Clay Organic matter content (C %)

The following maintenance is recommended:

The area must be fenced, and all animals kept off the area until the vegetation is self-

sustaining; Newly seeded/planted areas must be protected against compaction and erosion

(Vetiver hedges etc.); Traffic should be limited were possible while the vegetation is establishing itself; Plants should be watered and weeded as required on a regular and managed basis

were possible and practical; Check for pests and diseases at least once every two weeks and treat if necessary; Replace unhealthy or dead plant material; Fertilise, hydro seeded and grassed areas soon after germination, and Repair any damage caused by erosion;

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5 CONCLUSIONS AND KEY FINDINGS

The need for an alternatives assessment is a part of the EIA legal process and as such needed to be implemented. However, in the case of the New Largo Mining Project it became clear at an early stage that it would be an essential aspect in managing the sustainability equation for a project. The possibility of significantly large and negative effects on the biodiversity of an area that is considered to have moderate arable or grazing land status, which is understood to contribute significantly to the food production of the area, and which has proven ecologically sensitive areas that will be affected by the proposed mining project are all reasons for the detailed investigations. A total of seven different scenarios/versions have been tabled as part of the alternatives assessment, and in-depth discussions have been had around these. Issues of economics, engineering, and the environment (both socio economic as well as the physical) have been considered. These have included considerations of differing mining methods (open cast and underground), and differing aspects of the systems to be used. In terms of the environmental aspects which are the focus of these studies, consideration regarding the impacts of the project on the wetlands (wet soils) and sensitive ecological environments was given a high priority, with Option 7 of the mining plan alternatives being tabled as a realistic alternative that would offset the impacts on some of the smaller sensitive areas and wetlands on the southern and central portions of the mining area by leaving the “northern pan” system (pan and its surrounds) unaffected. This plan assumes that this area will never be impacted by any future development and that the activities that are currently in place in close proximity to the pan are not affecting the system that is proposed as the offset. The option also assumes that the system will be protected and managed as part of the mining license. In terms of the soils and the sensitivity of the land capability, the northern pan system is definitely of greater ecological sensitivity and of a larger spatial area than any of the other systems mapped, and is in the opinion of this study a reasonable offset in terms of sustaining soil water and the contribution of a wet soil system within the sensitive ecological biome. However, additional activities have been started in the area close to the Northern Pan (Sand Mining), and it is the opinion of this study (albeit that no new or detailed studies of the Northern Pan System have been carried out recently) based on a fresh knowledge (site visit) of the site and the new activities that have been started since the 2007 study was completed, that there are significant impacts already that could be affecting the functionality of the pan system. Additional studies are needed to determine the impacts of these activities (Sand Mining) before any defined statement is made in this regard. These should include but are not necessarily confined to a soils impact study, hydrogeological assessment on groundwater impacts and an assessment of the ecological and surface water status. As part of the overall assessment to the area of concern, it was important that the specialist studies inform the project decision makers of the best alternative/s for the mining and infrastructure placement.

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The concerns around the soil and land capability are varied. However, the most significant in terms of long term sustainability and affective mitigation would be the:

i) Placement of the proposed support and process infrastructure on the less sensitive and most easily rehabilitated soils;

ii) Reducing of the total area that is going to be disturbed to a minimum, iii) Planning of the resource extraction so as to optimise the sustainability

equation. This would require the balancing of the economic gains with the environmental net loss;

iv) The storage of utilizable soil (Soils >500mm in depth), v) The conservation of the soil resource (erosion by wind and water and

retention of the seed pool) and vi) The utilization of the soils at closure to re-establish the cover to the

disturbed areas that have been rehabilitated. 6 RECOMMENDATIONS

Based on the outcomes of the alternatives assessment, and using the environmental impact assessment philosophy as a means of measuring the significance of the proposed activities, a comparison of the actions contemplated for Mine Plan Option 6 versus those tabled for Mine Plan Option 7 are considered. The following observations are made with respect to the environmental aspects and the soils and land capability issues in particular.

Option 7 should be considered as a positive stand-alone option based on the highly sensitive nature of the northern pan system and the sensitive nature of the ecological findings (Refer to specialist ecological report). These issues are supported by the soils and land capability baseline study’s findings (deep sandy loam soils and relatively un-affected wet based soils associated with the pan system). This statement needs to be tempered with the knowledge that outside influences (sand mining) are probably impacting on the system (northern pan);

The effect of open cast mining of the northern pan system (Mine Plan Option 6) will have a high negative impact on the land capability (wetland status) and land use (soil water contribution to the stream baseflow) that is irreversible (recreation of pan structure). i.e. the impact will be permanent;

The conservation of the northern pan system could potentially offset the loss of wet based soil or wetland biodiversity of the less critical areas that have already been impacted by dryland cultivation on the southern and central portions of the proposed mining area. The quantitative assessment for this statement is yet to be calculated. However, the overall spatial extent and relatively unaffected nature of the northern pan system compared to the relatively small and fragmented nature of the sensitive zones delineated in the south and central portions of the mining area are considered comparable in terms of the land capability potential.

The verification of these observations is considered important in the ongoing decision making process. However, the facts based on the baseline of information are considered verifiable and of consequence to the sustainability of this project. Again, the assumptions around the undisturbed nature of the northern pan system needs to be assessed in more detail, as any impact on this system will potentially negate the positive gains that this option might have over Option 6.

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On the balance of probability, and with all of the environmental baseline information at hand (unknown impact of sand mining and no considerations of economics or engineering variables), Mine Plan Option 7 is considered the more sustainable option. Again it is emphasised that additional detailed studies of the recent impacts (Sand Mining) on the northern pan should be considered as part of the finalisation of impact assessment.

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LIST OF REFERENCES

Taxonomic Soil Classification System (Mac Vicar et al, 2nd edition 1991) The Soil Erodibility Nomograph (Wischmeier et al, 1971) Vetiver Grass for Soil and Water Conservation, Land Rehabilitation, and Embankment Stabilization – A collection of papers and newsletters compiled by the Vetiver Network – Richard G. Grimshaw (OBE) and Larisa Helfer - The World Bank – Washington DC – 1995 The South Africa Vetiver Network – Institute of Natural Resources – Scottsville – Mr. D. Hay and J. McCosh1987 to present. Chamber of Mines of South Africa, 1981. Guidelines for the rehabilitation of land disturbed by surface coal mining in South Africa. Johannesburg. Department of Environmental Affairs and Tourism, 1998. Environmental impact management. Implementation of sections 21, 22 and 26 of the Environmental Conservation Act, 1989, Pretoria: Government Printer (1998). Department of Mineral and Energy Affairs, 1992. Aide-Memoire for the preparation of Environmental Management Programme Reports for prospecting and Mining. Pretoria. Department of Water Affairs and Forestry, 2003. A practical field procedure for the identification and delineation of wetlands and riparian areas, DWAF, Pretoria. Non-Affiliated Soil Analysis Working Committee, 1991. Methods of soil analysis. SSSSA, Pretoria. Soil Classification Working Group, 1991. Soil classification. A taxonomic system for South Africa. Institute for Soil, Climate and Water, Pretoria. Van der Watt, H.v.H and Van Rooyen T. H, 1990. A glossary of soil science, Pretoria: Soil Science Society of South Africa (1990).

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APPENDIX 1

VETIVER GRASS

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APPENDIX 2

STUDY MAPS AND PLANS

re: new largo colliery (mine plan alternatives 6 and 7 ...zitholele.co.za/projects/12639 -...

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