Application for an Environmental - SAHRIS

Application for an Environmental Authorisation for the proposed construction of the new Rietkuil Private Railway Siding, Haul Road, Pollution Control Dam, and Associated Infrastructure, Exxaro Coal Mpumalanga (Pty) Ltd, Mpumalanga Province

DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT

Report Prepared for

Exxaro Coal Mpumalanga (Pty) Ltd

Report Number 467209

MDARDLEA Reference Number: 17/2/3N-340

Report Prepared by

October 2014

SRK Consulting: Project No: 467209_Exxaro Rietkuil Private Railway Siding Draft EIAr Page i

VDMW/HINM 467209_20141007_DRAFT EIAr Rietkuil railway siding_Final for client submission.docx October 2014

Application for an Environmental Authorisation for the proposed construction of the new Rietkuil Private Railway Siding, Haul Road, Pollution Control Dam, and Associated Infrastructure, Exxaro Coal (Pty) Ltd, Mpumalanga Province

DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT

Exxaro Coal Mpumalanga (Pty) Ltd

SRK Consulting (South Africa) (Pty) Ltd. Block A, Menlyn Woods Office Park

291 Sprite Avenue

Faerie Glen

Pretoria 0081

South Africa e-mail: [email protected] website: www.srk.co.za

Tel: +27 (0) 12 361 9821 Fax:+27 (0) 12 361 9912

SRK Project Number: 467209

October 2014

Compiled by: Peer Reviewed by:

Toinette vd Merwe, Manda Hinsch Environmental Scientists

Darryl Kilian Partner

Email: [email protected]

Authors:

Toinette vd Merwe; Manda Hinsch; Darryl Kilian

http://www.srk.co.za/

SRK Consulting: Project No: 467209_Exxaro Rietkuil Private Railway Siding Draft EIAr Page ii


Executive Summary Exxaro Coal Mpumalanga (Pty) (Ltd) a subsidiary of Exxaro Coal (Pty) Ltd and owned by Exxaro

Resources Limited undertook a number of studies to determine the viability and nature of the

transport system and infrastructure required for the railage of coal mined at their proposed Belfast

Coal Mine. Exxaro intends exporting a percentage of the coal mined at the proposed Belfast Coal

Mine and requires a suitable siding accessible to the existing coal line to Richards Bay Coal

Terminal. Exxaro is proposing to construct a private railway siding with associated infrastructure

south-west of the proposed Belfast Coal Mine. The proposed private railway siding will be located

parallel and north-west of the existing Transnet Freight Rail Rietkuil Station within the existing

Exxaro Arnot Coal Mine’s Mining Right area. This private railway siding with associated

infrastructure will cover a footprint of approximately 45 hectares.

The proposed development triggers activities under the National Environmental Management Act

(Act No. 107 of 1998) as listed in terms of GN R544 and GN R545 of 18 June 2010 and written

Environmental Authorisation in terms of GN R543 of 18 June 2010 must be obtained prior to Exxaro

being able to commence with any construction activities. The formerly Mpumalanga Department of

Economic Development, Environment and Tourism, now the Mpumalanga Department of

Agriculture, Rural Development, Land and Environmental Affairs is the competent authority who

would be considering the application for Environmental Authorisation in terms of the National

Environmental Management Act (Act No. 107 of 1998). An application in terms of the National

Water Act (Act No. 36 of 1998) for water uses identified in terms of Section 21 of the Act will also be

submitted to the Department of Water and Sanitation for consideration.

Ms Manda Hinsch of SRK Consulting (SA) (Pty) Ltd has been appointed as the independent

Environmental Assessment Practitioner by Exxaro Coal Mpumalanga (Pty) (Ltd) to undertake the

Environmental Authorisation application process in terms Section 24 of the National Environmental

Management Act (Act 107 of 1998) and the Integrated Water Use License Application in terms of

Section 21 of the National Water Act (Act No. 36 of 1998).

The Draft Scoping Report including the Plan of Study for Environmental Impact Assessment, dated

March 2014, was made available for public comment between 14 March 2014 and 22 April 2014.

The Final Scoping Report including the Plan of Study for Environmental Impact Assessment, dated

May 2014, was made available for public comment between 16 May 2014 and 05 June 2014, and

was accepted by the Mpumalanga Department of Economic Development and Tourism on 23 July

2014. This report, the Draft Environmental Impact Assessment Report, documents the findings of

the Environmental Impact Assessment Phase and has been compiled in accordance with Regulation

31 of GN R543 of 18 June 2010.

The Draft EIAr will be made available to Interested and Affected Parties (I&APs) for a period of 40

days, from 21 October 2014 until 01 December 2014. During this time I&APs may submit written

comments to the EAP in order for their comments and concerns to be addressed in the Final EIAr.

The Final EIAr will then be submitted to the Mpumalanga Department of Agriculture, Rural

Development, Land and Environmental Affairs, for decision making purposes.

The proposed construction of the proposed Rietkuil Private Railway Siding and associated

infrastructure will enable Exxaro to increase their coal exports via the Richards Bay Coal Terminal. It

could potentially generate export earnings for South Africa and contribute towards reducing South

Africa’s negative trade balance and current account deficit, whislt being a source of foreign revenue.

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The findings of the studies undertaken within this Environmental Impact Assessment to assess both

the benefits and potential negative impacts anticipated from the proposed project conclude that:

That there are no environmental fatal flaws that should prevent the construction and operation of

the proposed new Rietkuil Private Railway Siding and associated infrastructure from proceeding;

That the proposed new Rietkuil Private Railway Siding and associated infrastructure will remain

within existing disturbed areas/footprints within a disturbed and transformed area characterised

by mining and agricultural activities;

That the findings contained in the specialist studies concluded that the proposed construction of

the proposed new Rietkuil Private Railway Siding and associated infrastructure it is evident that

no significant negative environmental are anticipated to take place and it is that the impacts

which were identified can be adequately mitigated;

That the mitigation measures contained in the specialist studies are included in the

Environmental Management Programme to ensure that the mitigation measures are

implemented and auditable;

The cumulative significance of all the negative potential impacts on the environment is

considered low due to the limited nature and scale of the proposed development.

Based on the nature and extent of the proposed project, the local level of disturbance predicted as a

result of the construction and operation of the private railway siding and associated infrastructure,

the findings of the Environmental Impact Assessment, and the understanding of potential

environmental impacts. It is evident that the application for Environmental Authorisation for the

proposed construction of the private railway siding and associated infrastructure can be mitigated to

an acceptable level. The preferred railway siding alternative is considered to be the only reasonable

and feasible alternative from an environmental perspective. It is recommended that authorisation be

granted for the construction of a linear railway siding comprising a loading and run around railway

line parallel to the existing rail network. Notwithstanding the fact that the proposed activity occurs in

a disturbed and transformed area with no environmental sensitivities, mitigation measures

recommended by specialist are incorporated in the Environmental Management Programme.

The anticipated impacts associated with the construction, operation and decommissioning of the

Rietkuil private railway siding and associated infrastructure includes the following:

Construction related Impacts

Specialist Study Impacts Identified

Significance

Rating Before

Mitigation

Significance

Rating After

Mitigation

Biodiversity

Impacts on Habitat for Floral Species Medium-High Low

Impacts on Flora Diversity Low-Medium Low

Impacts on Flora Species of Conservation Concern Low Low

Impacts on Faunal Habitat Medium-High Low-Medium

Impacts on Faunal Diversity Medium-Hig Low-Medium

Impact on RDL and Protected Fauna Species Low Low

Wetlands

Impacts on Loss of Wetland Habitat and Ecological Structure

Medium-High Low-Medium

Changes to Wetland Ecological and Sociocultural Service Provision


Impacts on Wetland Hydrological Function Medium-High Low

Soil, Land Use and

Soil Compaction Related Impacts High Medium-High

Soil Erosion Related Impacts High Low-Medium

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Significance

Rating Before

Mitigation

Significance

Rating After

Mitigation

Land Capability Impacts Associated With the Sterilization of Topsoil Layer High High

Impacts Associated With Chemical Soil Pollution High Low

Impacts on the Loss of Current Land Capability High Low-Medium

Surface and Ground

water

Impact on groundwater quality Medium-High Low-Medium

Impact on Bosmanspruit Medium-High Low-Medium

Change in catchment runoff Low-Medium Low

Erosion Low Very-Low

Heritage

Road Construction - Damage to farmhouse Low Very-Low

Road Construction - Damage to the buildings Low Very-Low

Road Construction - Damage to kraals Low Very-Low

Road Construction - Damage to graves Low Very-Low

Road Construction - Damage to Houses Low Very-Low

Traffic

Gravel access roads of approximately 9km; D1110 & D1770

Very High Low-Medium

D1110 / D1770 Intersection Very High Low-Medium

N4 Road / D1110 Road Intersection (safety) Very High Low-Medium

New access road between Rietkuil Station and D1550 Road

Low-Medium Low-Medium

Noise

Removal and hauling of top soil from the site Low Very-Low

Earthmoving equipment at the foot print area Low Very-Low

Hauling of material to and from the specific area Low Very-Low

Construction of the pollution control dam and/or structures Low Very-Low

Upgrade of the existing gravel roads between the railway siding and the Belfast

Low Very-Low

Diesel emergency generators Low Very-Low

Socio-economic Creation of Temporary Employment Opportunities Low Medium-High

Creation of permanent Employment Opportunities Low Medium-High

Operation Phase Impacts


Significance

Rating Before

Mitigation

Significance

Rating After

Mitigation

Surface and Ground

water

Impact on groundwater quality (Leachate seeping from coal loading bay to underlying aquifers)

Low-Medium Low

Impact on groundwater quality (Leachate seeping from pollution control dam to underlying aquifers)

Low-Medium Low

Impact on groundwater quality (Leakage of hydrocarbon fuels into underlying aquifers)


Impact on Bosmanspruit (Seepage of contaminated groundwater into the river)

Medium-High Low

Impact on Bosmanspruit (Contaminated runoff flowing into the river)


Change in catchment runoff Low-Medium Low

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Significance

Rating Before

Mitigation

Significance

Rating After

Mitigation

Erosion Low Very-Low

Traffic


Very-High Low-Medium

D1110 / D1770 Intersection Very-High Low-Medium

N4 Road / D1110 Road Intersection (safety) Very-High Low-Medium


Low-Medium Low-Medium

Noise

Removal and hauling of top soil from the site Low-Medium Very-Low

Earthmoving equipment at the foot print area Low-Medium Very-Low

Hauling of material to and from the specific area Low-Medium Very-Low

Construction of the pollution control dam and/or structures Low-Medium Very-Low

Construction of the pollution control dam and/or structures Low-Medium Very-Low

Diesel emergency generators Low-Medium Very-Low

Stockpile management Low-Medium Very-Low

Air Quality

Impacts Associated with PM10 Low-Medium Low

Impacts Associated with Dust Fallout Low-Medium Low

Impacts Associated with PM2.5 Low-Medium Low

Decommissioning


Significance

Rating Before

Mitigation

Significance

Rating After

Mitigation

Soils, Land Use and Land Capability

Impacts associated with Soil Compaction High Medium-High

Surface and Ground Water


Low-Medium Low

Impact on groundwater quality Low-Medium Low


Low Low


Low Very-Low

Noise

Rehabilitation of railway siding Low-Medium Low

Demolition of plant and infra-structure Low-Medium Low

Diesel emergency generators Low-Medium Low

The Draft Environmental Impact Assessment Report will be made available to registered Interested

and Affected Parties for a 40 day commenting period, from 21 October 2014 until 01 December

2014. During this time I&APs may submit written comments to the Environmental Assessment

Practitioner in order for the comments and concerns to be addressed in the Final Environmental

Impact Assessment Report. Once these comments/responses/amendments are made it will be

released to the registered Interested and Affected Parties for perusal. The Final Environmental

Impact Assessment Report will also be submitted to the Mpumalanga Department of Agriculture,

Rural Development, Land and Environmental Affairs, as competent authority, for decision making

purposes.

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Table of Contents

Executive Summary ..................................................................................................................................... ii

Disclaimer ................................................................................................................................................... xiii

List of Abbreviations .................................................................................................................................. xiv

1 Introduction .................................................................................................................. 1

1.1 Details of the Applicant ....................................................................................................................... 2

1.2 Details of the EAP ............................................................................................................................... 2

1.2.1 Statement of independence .................................................................................................... 4

1.3 Specialists ........................................................................................................................................... 4

1.4 Authorities ........................................................................................................................................... 4

1.5 Applicable Legislation ......................................................................................................................... 5

1.5.1 The Constitution of the Republic of South Africa (Act No. 108 of 1996) ................................. 5

1.5.2 National Environmental Management Act (Act No. 107 of 1998) ........................................... 5

1.5.3 EIA Regulations GN R 543 of 18 June 2010........................................................................... 6

1.5.4 NEMA Listing Notices 1 and 2 of 18 June 2010 ..................................................................... 6

1.5.5 National Environmental Management: Biodiversity Act (Act No. 10 of 2004) ......................... 9

1.5.6 National Environmental Management: Air Quality Act (Act No. 39 of 2004) ........................... 9

1.5.7 National Water Act (Act No. 36 of 1998) ............................................................................... 10

1.5.8 National Heritage Resources Act (Act No. 25 of 1998) ......................................................... 11

1.5.9 Conservation of Agricultural Resources Act (Act No. 43 1983) ............................................ 11

1.5.10 Mpumalanga Conservation Act (Act No. 10 of 1998) ............................................................ 12

1.5.11 Guidelines ............................................................................................................................. 12

1.6 Legislative requirements ................................................................................................................... 13

2 Background ................................................................................................................ 14

2.1 Background of the project ................................................................................................................. 14

2.1.1 Existing infrastructure ............................................................................................................ 14

2.1.2 Existing approvals/authorisations .......................................................................................... 15

2.1.3 Project Area Description........................................................................................................ 15

3 Project Description ..................................................................................................... 20

3.1 Need and Desirability ........................................................................................................................ 20

3.2 Detailed Project Description .............................................................................................................. 20

3.2.1 Coal Stockpile and Siding ..................................................................................................... 21

3.2.2 Pollution Control Dam ........................................................................................................... 21

3.2.3 Storm Water Management Infrastructure .............................................................................. 21

3.2.4 Access Road and Road Upgrades ........................................................................................ 21

3.2.5 Wetland Crossings ................................................................................................................ 22

3.2.6 Operational phase ................................................................................................................. 22

3.2.7 Decommissioning and closure phase ................................................................................... 22

3.3 Alternatives ....................................................................................................................................... 22

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3.3.1 Location Alternatives ............................................................................................................. 22

3.3.2 Technology Alternatives ........................................................................................................ 23

3.3.3 ‘No-Go’ Alternative ................................................................................................................ 23

4 Description of Baseline Environment ....................................................................... 24

4.1 Climate .............................................................................................................................................. 24

4.1.1 Regional climate .................................................................................................................... 24

4.1.2 Rainfall and Evaporation ....................................................................................................... 24

4.2 Topography ....................................................................................................................................... 26

4.3 Geology ............................................................................................................................................. 26

4.4 Geochemical ..................................................................................................................................... 28

4.5 Soils and Land use............................................................................................................................ 28

4.5.1 Soils ....................................................................................................................................... 28

4.5.2 Land Capability of the area ................................................................................................... 29

4.5.3 Land Use ............................................................................................................................... 36

4.6 Biodiversity ........................................................................................................................................ 36

4.6.1 Vegetation ............................................................................................................................. 36

4.6.2 Faunal habitat ........................................................................................................................ 38

4.6.3 Avifaunal ................................................................................................................................ 38

4.6.4 Reptiles.................................................................................................................................. 38

4.6.5 Amphibians ............................................................................................................................ 39

4.6.6 Invertebrates ......................................................................................................................... 39

Spiders and scorpions ...................................................................................................................... 39

4.7 Surface Water ................................................................................................................................... 40

4.7.1 Catchment 1 .......................................................................................................................... 40

4.7.2 Catchment 2 .......................................................................................................................... 40

4.7.3 Catchment 3 .......................................................................................................................... 40

4.7.4 Catchment 4 .......................................................................................................................... 40

4.7.5 Catchment 5 .......................................................................................................................... 40

4.7.6 Catchment 6 .......................................................................................................................... 41

4.7.7 Catchment 7 .......................................................................................................................... 41

4.7.8 Catchment 8 .......................................................................................................................... 41

4.7.9 Catchment 9 .......................................................................................................................... 41

4.7.10 Catchment 10 ........................................................................................................................ 41

4.7.11 Catchment 11 ........................................................................................................................ 41

4.7.12 Catchment 12 ........................................................................................................................ 42

4.7.13 Catchment 13 ........................................................................................................................ 42

4.7.14 Catchment 14 ........................................................................................................................ 42

4.7.15 Catchment 15 ........................................................................................................................ 42

4.7.16 Catchment 16 ........................................................................................................................ 42

4.7.17 Surface Water Hydrology ...................................................................................................... 44

4.7.18 Mean Annual Runoff .............................................................................................................. 44

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4.7.19 Floodlines .............................................................................................................................. 46

4.7.20 Wetlands................................................................................................................................ 48

4.8 Groundwater ..................................................................................................................................... 52

4.9 Air quality .......................................................................................................................................... 54

4.9.1 Mining activities in the region ................................................................................................ 54

4.9.2 Road network ........................................................................................................................ 54

4.9.3 Windblown dust ..................................................................................................................... 55

4.9.4 Vehicle tailpipe emissions ..................................................................................................... 55

4.10 Noise 55

4.10.1 Existing Road Network .......................................................................................................... 61

4.10.2 Existing Rail Network ............................................................................................................ 62

4.10.3 Area of Influence ................................................................................................................. 62

4.10.4 Status quo traffic volumes ..................................................................................................... 63

4.11 Socio-economic ................................................................................................................................. 63

4.11.1 Demographic and key economic indicators of Steve Tshwete Local Municipality ................ 64

4.11.2 Demographic and key economic indicators of Emakhazeni Local Municipality .................... 65

4.12 Heritage ............................................................................................................................................. 66

5 Environmental Impact Assessment .......................................................................... 74

5.1 Specialist investigations .................................................................................................................... 74

5.2 Methodology of the Impact Assessment ........................................................................................... 82

5.3 Impact significance............................................................................................................................ 84

5.3.1 Pre-construction phase ......................................................................................................... 85

5.3.2 Construction phase ............................................................................................................... 85

5.3.3 Operational phase ............................................................................................................... 101

5.3.4 Decommissioning / Rehabilitation phase ............................................................................ 109

5.4 Uncertainties, assumptions and gaps in knowledge ....................................................................... 111

5.4.1 Uncertainties ....................................................................................................................... 111

5.4.2 Assumptions ........................................................................................................................ 111

5.4.3 Gaps in knowledge .............................................................................................................. 113

5.4.4 Risks .................................................................................................................................... 113

6 Environmental Management Programme ............................................................... 113

6.1 Background ..................................................................................................................................... 113

6.2 Objectives of the EMPr ................................................................................................................... 113

6.3 Approach to the EMPr ..................................................................................................................... 114

6.4 Implementation of the EMPr ........................................................................................................... 114

6.5 Rehabilitation and Closure .............................................................................................................. 114

7 Public Participation .................................................................................................. 115

7.1 Methodology .................................................................................................................................... 116

7.1.1 Identification of I&APs ......................................................................................................... 116

7.1.2 Announcement Phase ......................................................................................................... 117

7.1.3 Scoping Phase .................................................................................................................... 118

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7.1.4 Impact Assessment Phase .................................................................................................. 119

7.1.5 Comments and Responses ................................................................................................. 120

7.2 Actions taken during the Public Participation Process .................................................................... 121

8 Conclusions and Recommendations ...................................................................... 126

8.1 Summary of Key Findings ............................................................................................................... 126

8.2 Environmental Impact Statement .................................................................................................... 126

10 Bibliography ............................................................................................................. 129

Appendices .................................................................................................................... 131

Appendix A: Site Plans ............................................................................................... 132

Appendix B: Site Photographs ................................................................................... 133

Appendix C: Specialist Studies and declarations of independence ....................... 134

Appendix D: Public Participation ............................................................................... 135

Appendix E: EMPr ....................................................................................................... 136

Appendix F: Project Team CV’s ................................................................................. 137

Appendix G: Project Experience ................................................................................ 138

Appendix H: Application Form with EAP Declaration of Independence ................. 139

Appendix I: Authority Correspondence .................................................................... 140

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List of Tables Table 1-1: Applicant Contact Details ............................................................................................................. 2

Table 1-2: Details of the Environmental Impact Assessment Project Team ................................................. 3

Table 1-3: Specialist Team ............................................................................................................................ 4

Table 1-4: Competent Authority Details ........................................................................................................ 4

Table 1-5: Local and District Municipality Details .......................................................................................... 5

Table 1-6: Listed NEMA Activities ................................................................................................................. 7

Table 1-7: Anticipated Water Uses to be applied for................................................................................... 10

Table 1-8: Regulatory Requirements .......................................................................................................... 13

Table 2-1: Nearest Towns to the Proposed Development .......................................................................... 15

Table 2-2: List of Affected Farms and Farm Portions Illustrating the Relevant Activities ........................... 15

Table 4-1: Rainfall Station Details ............................................................................................................... 24

Table 4-2: Average Rainfall in mm from the Combined Record ................................................................. 25

Table 4-3: Average Monthly Evaporation at Symons Pan .......................................................................... 25

Table 4-4: Pre-Mining Land Capability Requirements ................................................................................ 29

Table 4-5: Summary of Catchment Hydrology for the Project Area ............................................................ 45

Table 4-6: Summary of Peak Flows (m3/s) for the Project Area ................................................................. 45

Table 4-7: Tweefontein boreholes sampled ................................................................................................ 52

Table 4-8: Groundwater chemistry laboratory results ................................................................................. 53

Table 4-9: SANS 10103 of 2008 Sound Pressure Levels for Specific Districts .......................................... 56

Table 4-10: Distance in meters between proposed Siding, Haul Road and the Noise Sensitive Areas ....... 58

Table 4-11: Overview of the Existing Road Network and Jurisdiction .......................................................... 61

Table 4-12: Nearest Towns to the Proposed Development .......................................................................... 63

Table 4-13: Level of Education of Household Heads .................................................................................... 64

Table 4-14: Employment Status of Household Heads (HH) ......................................................................... 65

Table 5-1: Specialist Terms of Reference ................................................................................................... 75

Table 5-2: Criteria for Assessing Significance of Impacts ........................................................................... 83

Table 5-3: Significance Rating Matrix.......................................................................................................... 84

Table 5-4: Positive/Negative Mitigation Ratings .......................................................................................... 84

Table 5-5: Impacts on Habitat for Floral Species during the Construction Phase of the Project ................ 85

Table 5-6: Impacts on Flora Diversity.......................................................................................................... 86

Table 5-7: Impacts on Flora Species of Conservation concern during the Construction Phase of the Project ........................................................................................................................................ 87

Table 5-8: Impacts on Faunal Habitat during the Construction Phase of the Project ................................. 87

Table 5-9: Impacts on Faunal Diversity During the Construction Phase of the Project .............................. 88

Table 5-10: Impact on RDL and Protected Fauna Species During the Construction Phase of the Project .. 88

Table 5-11: Impacts on Loss of Wetland Habitat and Ecological Structure during the Construction Phase of the Project .................................................................................................................................. 89

Table 5-12: Changes to Wetland Ecological and Sociocultural Service provision ........................................ 90

Table 5-13: Impacts on Wetland Hydrological Function during the Construction Phase of the Project ....... 91

Table 5-14: Impacts Relating to Soil Compaction during the Construction Phase of the Project ................. 92

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Table 5-15: Impacts Relating to Soil Erosion During the Construction Phase of the Project ....................... 92

Table 5-16: Impacts Associated With the Sterilization of Topsoil Layer During the Construction Phase of the Project .................................................................................................................................. 93

Table 5-17: Impacts associated with Chemical Soil Pollution ....................................................................... 93

Table 5-18: Impacts on the loss of current Land Capability during the Construction Phase of the Project .. 94

Table 5-19: Surface and Groundwater Impacts during the Construction Phase of the Project .................... 94

Table 5-20: Heritage related Impacts during the Construction Phase of the Project .................................... 96

Table 5-21: Traffic Related Impacts during the Construction Phase of the Project ...................................... 97

Table 5-22: Noise Related Impacts during the Construction Phase of the Project ....................................... 99

Table 5-23: Creation of Temporary Employment Opportunities during the Construction Phase of the Project ...................................................................................................................................... 100

Table 5-24: Creation of permanent Employment Opportunities During the Construction Phase of the Project ...................................................................................................................................... 101

Table 5-25: Surface and Groundwater during the Operational Phase of the Project ................................. 101

Table 5-26: Traffic Impacts during the Operational Phase Of The Project ................................................. 103

Table 5-27: Noise related Impacts during the Operational Phase of the Project ........................................ 104

Table 5-28: Impacts associated with PM10 during the Operational Phase of the Project ........................... 107

Table 5-29: Impacts Associated with Dust Fallout during the Operational Phase of the Project ................ 107

Table 5-30: Impacts Associated with PM2.5 during the Operational Phase of the Project .......................... 107

Table 5-31: Impacts associated with Soil Compaction during the Decommission Phase of the Project .... 109

Table 5-32: Surface and Groundwater Related Impacts during the Decommission Phase of the Project . 109

Table 5-33: Noise Impacts during the Decommission Phase of the Project ............................................... 110

Table 6-1: Approach to Impact Management ............................................................................................ 114

Table 7-1: List and Location of the Site Notices placed for the proposed Project .................................... 117

Table 7-2: Actions Taken during Public Participation Process ................................................................. 121

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List of Figures Figure 2-1: Overall Layout Map of the proposed Transport Route ............................................................... 17

Figure 2-2: Layout Map of the proposed Road Upgrades ............................................................................ 18

Figure 2-3: Layout Map of the proposed Private Railway Siding And Associated Infrastructure. ................ 19

Figure 4-1: Percentiles of Monthly Rainfall and Annual Rainfall (Inset) for the Klippan-Nooitgedacht Dam-Leeuwpan Combined Record .................................................................................................... 25

Figure 4-2: Average Monthly Rainfall for the Klippan-Nooitgedacht Dam-Leeupan Combined Record (1904 – 2012) and Symons Pan Evaporation from WR2005 ............................................................... 26

Figure 4-3: Geological Map .......................................................................................................................... 27

Figure 4-4: Land Capability of the Proposed New Access Road to the proposed new Rietkuil Private Railway Siding ............................................................................................................................ 31

Figure 4-5: Land Capability of the proposed new Rietkuil Private Railway Siding Road Upgrade (Map 1) . 32



Figure 4-8: Land capability map of the proposed new Rietkuil Private Railway Siding Pollution Control Dam and Coal Loading Facility development footprint area ...................................................... 35

Figure 4-9: Surrounding land use map of the proposed new Rietkuil Private Railway Siding ..................... 36

Figure 4-10: Catchment map of the proposed new Rietkuil Private Railway Siding and associated infrastructure study area ............................................................................................................ 43

Figure 4-11: Seepage from Shallow Groundwater ........................................................................................ 44

Figure 4-12: Floodline extent for the proposed new Rietkuil Private Railway Siding and associated infrastructure .............................................................................................................................. 47

Figure 4-13: Illustration of the wetlands in and around the proposed new Rietkuil Private Railway Siding and associated infrastructure project area ................................................................................. 49

Figure 4-14: Wetland types associated with the proposed new Rietkuil Private Railway Siding and associated infrastructure ............................................................................................................ 50

Figure 4-15: Wetland Types Associated with the upgrading of the D1770 ................................................... 51

Figure 4-15: Noise sources in the vicinity of the proposed new Rietkuil Private Railway Siding and associated infrastructure site ..................................................................................................... 57

Figure 4-16: Noise sensitive areas in the vicinity of the proposed new Rietkuil Private Railway Siding and associated infrastructure. ........................................................................................................... 60

Figure 4-17: Site layout plan depicting locations of heritage sites ................................................................. 67

Figure 4-18: Location of the Recorded Sites at the Rietkuil Private Railway Site .......................................... 68

Figure 4-19: Location of the Recorded Sites Along the Provincial Roads ..................................................... 68

Figure 4-19: Photographic Reference for Site 1 ............................................................................................. 69



Figure 4-22: Physical Location of Site 5 ......................................................................................................... 71





Figure 7-1: Environmental Authorisation and Associated Stakeholder Engagement Process. ................. 116

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Disclaimer The opinions expressed in this Report have been based on the information supplied to SRK

Consulting South Africa (Pty) Ltd (SRK) by Exxaro Coal Mpumalanga (Pty) (Ltd) (Exxaro). The

opinions in this Report are provided in response to a specific request from Exxaro to do so. SRK

has exercised all due care in reviewing the supplied information. Whilst SRK has compared key

supplied data with expected values, the accuracy of the results and conclusions from the review are

entirely reliant on the accuracy and completeness of the supplied data. SRK does not accept

responsibility for any errors or omissions in the supplied information and does not accept any

consequential liability arising from commercial decisions or actions resulting from them. Opinions

presented in this report apply to the site conditions and features as they existed at the time of SRK’s

investigations, and those reasonably foreseeable. These opinions do not necessarily apply to

conditions and features that may arise after the date of this Report, about which SRK had no prior

knowledge nor had the opportunity to evaluate.

SRK Consulting: Project No: 467209_Exxaro Rietkuil Private Railway Siding Draft EIAr Page xiv


List of Abbreviations

ADT Average daily traffic

ADTT Average daily truck traffic

BID Background Information Document

CARA Conservation of Agricultural Resources Act (Act No. 43 of 1983)

CRR Comments and Response Report

DEA Department of Environmental Affairs

DEAT Department of Environmental Affairs and Tourism

DWS Department of Water and Sanitation

DWAF Department of Water Affairs and Forestry

EA Environmental Authorisation

EAP Environmental Assessment Practitioner

EIA Environmental Impact Assessment

EIAr Environmental Impact Assessment Report

EIS Ecological Importance and Sensitivity

EMPr Environmental Management Programme

Exxaro Exxaro Coal Mpumalanga (Pty) (Ltd)

GCL Geo synthetic clay liner

HDPE High Density Polyethylene

HIA Heritage Impact Assessment

I&APs Interested and Affected Parties

IUCMA Inkomati Usuthu Catchment Management Agency

ICP Coupled Plasma

IDP Integrated Development Plan

IWULA Integrated Water Use License Application

JSE Limited Johannesburg Stock Exchange Limited

MAP Mean Annual Precipitation

MDARDLEA Mpumalanga Department of Agriculture, Rural Development, Land and Environmental Affairs

MDEDET Mpumalanga Department of Economic Development, Environment and Tourism

MDRT Mpumalanga Department of Roads and Transport

MHSA Mines Health and Safety Act (Act No. 50 of 1991)

NBC North Block Complex

NEM: AQA National Environmental Management: Air Quality Act (Act No. 39 of 2004)

NEM: BA Biodiversity Act (Act No. 10 of 2004)

NEM: WA National Environmental Management: Waste Act (Act No. 59 of 2008)

NEMA National Environmental Management Act (Act No. 107 of 1998)

NFEPA National Freshwater Ecosystem Priority Areas

NHRA National Heritage Resources Act (Act No. 25 of 1999)

NPAES National Protected Area Expansion Strategy

NWA National Water Act (Act No. 36 of 1998)

SRK Consulting: Project No: 467209_Exxaro Rietkuil Private Railway Siding Draft EIAr Page xv


PCD Pollution Control Dam

PES Present State of a Wetland

PPP Public Participation Process

RBCT Richards Bay Coal Terminal

RDL Red Data List

REC Recommended Ecological Class

SAHRA South African Heritage Resources Agency

SANBI South African National Biodiversity Institute

SANS South African National Standards

SAR Sodium Absorption Ratio

SAS Scientific Aquatic Services

SAWS South African Weather Services

SDF Spatial Development Framework

SRK SRK Consulting (SA) (Pty) Ltd

Sub-WMAs sub-Water Management Area

TFR Transnet Freight Rail

SRK Consulting: Project No: 467209_Exxaro Rietkuil Private Railway Siding Draft EIAr Page 1


1 Introduction Exxaro Coal Mpumalanga (Pty) (Ltd) (Exxaro) is a subsidiary of Exxaro Coal (Pty) Ltd and owned

by Exxaro Resources Limited. Exxaro undertook a number of studies to determine the viability

and nature of the transport system and infrastructure required for transporting of coal mined at

their proposed Belfast Coal Mine via rail. Exxaro intends exporting a percentage of the coal

mined at the proposed Belfast Coal Mine and requires a suitable siding accessible to the existing

coal line to Richards Bay Coal Terminal (RBCT).

Exxaro therefore proposes to construct a new private railway siding with associated infrastructure

(referred to as the “proposed new Rietkuil Private Railway Siding and associated infrastructure”)

south-west of the proposed Belfast Coal Mine. The proposed Rietkuil Private Railway Siding and

associated infrastructure will be located parallel and north-west of the existing Transnet Freight

Rail (TFR) Rietkuil Station within the existing Exxaro Arnot Coal Mine’s Mining Right area. This

proposed new Rietkuil Private Railway Siding and associated infrastructure will cover a footprint

of approximately 45 hectares. The construction activities will include the following:

The construction of a private railway siding of approximately 3.5 km in length, this includes

the loading and run around lines;

The establishment of a coal stockpile of approximately 54 000 tons, with associated

operational facilities;

The construction of a storm water management system for the management of clean and

dirty water around the coal stockpile. The coal loading platform slopes away from the railway

track work with a slope of 2% (1:50). Surface run-off from the loading facility and adjacent

access road is collected in a concrete lined drain on the northern edge of the coal loading

platform. The contaminated run-off flows under gravity and passes through a silt trap into the

PCD on the South Western boundary of the site. Clean surface run-off water is diverted from

the dirty water catchment area by means of cut-off channels and berms;

Construction of a pollution control dam (PCD) with a capacity of approximately 51 230 cubic

metres;

The upgrade and widening of existing provincial roads (D 1770 and D 1110);

The upgrade of a new private access road. This new access will intersect with the existing D

1555 provincial road;

The construction of culverts associated with the provincial road D 1770 and the new private

access road;

The construction of other associated infrastructure including, but not limited to, construction

camps, weighbridge, and offices.

However, authorisation must be obtained in terms of the following legislation prior to Exxaro

being able to commence with any construction activities:

National Environmental Management Act (Act No. 107 of 1998) (NEMA) Environmental

Impact Assessment (EIA) Regulations contained in GN R543 of 18 June 2010, with

reference to the Listing Notices contained in GN R544 and GN R545 of 18 June 2010;

National Water Act (Act No. 36 of 1998) (NWA) for water uses identified in terms of Section

21 of the NWA.

The proposed development triggers activities listed in terms of GN R544 and GN R545 of 18

June 2010. Therefore, the application for Environmental Authorisation (EA) entails undertaking a

Scoping and EIA Phase, which is regulated by the EIA Regulations GN R543 of 18 June 2010

and promulgated under the NEMA.

Ms Manda Hinsch of SRK Consulting (SA) (Pty) Ltd (SRK) has been appointed as the

independent Environmental Assessment Practitioner (EAP) by Exxaro to undertake the EA



application process in terms Section 24 of the NEMA and the Integrated Water Use License

Application (IWULA) in terms of Section 21 of the NWA.

The application for EA was lodged with the competent authority the Mpumalanga Department of

Agriculture, Rural Development, Land and Environmental Affairs (MDARDLEA), formerly

Mpumalanga Department of Economic Development, Environment and Tourism (MDEDET).

The Draft Scoping Report including the Plan of Study for Environmental Impact Assessment

(EIA), dated March 2014, was made available for public comment between 14 March 2014 and

22 April 2014. The Final Scoping Report including the Plan of Study for EIA, dated May 2014,

was made available for public comment between 16 May 2014 and 05 June 2014, and was

accepted by the Mpumalanga Department of Economic Development and Tourism on 23 July

2014. This report, the Draft Environmental Impact Assessment Report (EIAr), documents the

findings of the Environmental Impact Assessment Phase and has been compiled in accordance

with Regulation 31 of GN R543 of 18 June 2010.

The Draft EIAr will be made available to Interested and Affected Parties (I&APs) for a period of

40 days, from 21 October 2014 until 01 December 2014. During this time I&APs may submit

written comments to the EAP in order for their comments and concerns to be addressed in the

Final EIAr. The Final EIAr will then be submitted to the MDARDLEA, as competent authority, for

decision making purposes.

1.1 Details of the Applicant

Exxaro operates a coal mining complex in the Mpumalanga Province which is situated between

the towns of Glisa and Strathrae Coal Mines as well as the proposed Eerstelingsfontein and

proposed Belfast Coal Mines. Exxaro is a South African based mining group, listed on the

Johannesburg Stock Exchange Limited (JSE) Limited, a constituent of the JSE’s top 40 index

and one of the best-performing constituents of the JSE Socially Responsible Investment index.

Exxaro has a diverse and world-class commodity portfolio in coal, mineral sands, base metals

and ferroalloys, and growing exposure to iron ore. The details of the applicant can be found in

Table 1-1.

Table 1-1: Applicant Contact Details

Name Simon Mkhonza (on behalf of Exxaro Resources Pty Ltd)

Designation Business Unit Manager: North Block Complex

Telephone (013) 253 7300

Fax (013) 253 7360

E Mail [email protected]

Postal Address 1 P.O Box 321

Town Belfast

Postal Code 1100

Postal Address 2 P.O Box 9229

Town Pretoria

Postal Code 0001

1.2 Details of the EAP

Ms Manda Hinsch from SRK was appointed as the independent EAP to facilitate the EA

application process for the construction of the proposed new Rietkuil Private Railway Siding and

mailto:[email protected]



associates infrastructure. SRK has 40 years’ experience in environmental consulting and has

appointed a lead EAP and associated project team to undertake the necessary EA.

SRK commenced its practises in 1974 as has since been involved in a large variety of

environmental studies. SRK is a South African founded international organisation of

professionals providing a comprehensive range of consulting services to natural resource

industries and organisations. SRK’s Johannesburg and Pretoria offices are staffed with over 300

professional consultants operating in a range of disciplines, mainly related to the environment,

water, social and mining sectors. Back-up and peripheral expertise is available within these

offices for all environmental projects. SRK has a demonstrated track record of undertaking

independent assessments of resources and reserves, project evaluations and audits, listing

reports and independent feasibility studies to bankable standards on behalf of exploration

companies, mining companies and financial institutions worldwide. The SRK project team

consists of the following members as listed in Table 1-2.

Table 1-2: Details of the Environmental Impact Assessment Project Team

SRK Project Team

Designation

Project Partner and Reviewer

Project Manager

Report preparation

Report preparation

Public participation Coordinator

Team Member

Darryll Kilian

Manda Hinsch Toinette van der Merwe

Andrew Caddick

Annerine Prinsloo

Donne du Toit

The project reviewer is Mr Darryll Kilian who is a Partner at SRK with over 21 years’ experience

in environmental management. Mr Darryll Kilian is appropriately qualified and registered as a

Certified Environmental Assessment Practitioner.

The project manager, Ms Manda Hinsch is an Associate Partner at SRK, with 32 years’

experience in the environmental field. Mrs Manda Hinsch is appropriately qualified and

registered with the relevant professional bodies as a Professional Natural Scientists (Pr.Sci.Nat.

400164/09) with the South African Council of Natural Scientific Professions and has extensive

experience in compilation, implementation, amendment and assessing environmental

compliance of a diverse set of EIA’s and Environmental Management Programmes (EMPr’s) in

terms of the NEMA.

Ms Toinette van der Merwe holds a BSc (Honours) in Environmental Science. She is a senior

environmental scientist at SRK with 11 years’ experience in the environmental field. Her

experience lies in the field of environmental management and has extensive regulatory,

compliance and enforcement experience at Local, Provincial and National Government level.

She has experience in compilation, amendment and assessing environmental compliance for a

diverse set of EIAs and EMPr’s in terms of the NEMA.

Mr Andrew Caddick holds a BSc (Honours) in Geography and Environmental Science. He is an

environmental scientist at SRK with 5 years’ experience in the environmental field. His

experience lies in the management of EIA and EMPr processes, coordination, and execution of

Public Participation Process (PPP), and management of multi-disciplinary project teams, mainly

for mining related projects. He is also involved in conducting EMPr audits and site assessments.

The CV’s of the key SRK staff members for this project can be found in Appendix F and the

project experience is provided in Appendix G.



1.2.1 Statement of independence

The EAP, Ms Manda Hinsch hereby declares her independence of Exxaro and any affiliates of

the Exxaro as per the requirements of Regulation 17(a) of GN R543 of 18 June 2010. She

further declares that the SRK project team has the expertise to conduct EIAs, including

knowledge of the relevant Acts, Regulations and any guidelines that have relevance to the

proposed activity as required by Regulation 17(b) of GN R543 of 18 June 2010.

Neither SRK nor any of the authors of this report, its specialist / sub consultants and / or

associates have any material present or contingent interest in the outcome of this report, nor do

they have any pecuniary or other interest that could be reasonably regarded as being capable of

affecting their independence or that of SRK.

SRK, nor any sub- consultants and specialists, have any correlation or interest in the proposed

project or future/present developments influenced by this project in any way.

1.3 Specialists

The following specialist team conducted the specialist studies identified in Section 5.1 of this

Draft EIAr which is in accordance with the Plan of Study for EIA approved as part of the Final

Scoping Report by the MDARDLEA:

Table 1-3: Specialist Team

Specialist Field Company Contact Person

Air Quality SRK Consulting V Reddy

Biodiversity Scientific Aquatic Services (SAS) S van Staden

Geochemistry SRK Consulting J Lake

Groundwater SRK Consulting P Shepherd

Heritage Department of Anthropology and Archaeology, UNISA

F Coetzee

Noise DB Acoustics B van der Merwe

Soils, land use and land capability

Terra-Africa M Pienaar

Surface SRK Consulting P Shepherd

Traffic ITS J Stolp

Wetlands SAS S van Staden

Rehabilitation and Closure SRK Consulting J Lake

1.4 Authorities

The MDARDLEA is the competent authority in terms of the EA application and the Department of

Water and Sanitation (DWS) is the competent authority for the IWULA. Details of the competent

authorities are given in Table 1-4.

Table 1-4: Competent Authority Details

Department Contact Person Contact Details

MDARDLEA O Fakude Tel: 013 693 5806


DWS F Guma Tel: 013 759 7331


IUCMA M Golden Tel: 083 929 1354



Department Contact Person Contact Details


The proposed development is located within the jurisdiction of the Steve Tshwete and

Emakhazeni Local Municipalities of the Nkangala District Municipality, Mpumalanga Province.

Details of the relevant Local and District Municipalities’ are given in

Table 1-5.

Table 1-5: Local and District Municipality Details

Municipality Contact Person Contact Details

Steve Tshwete Local Municipality

Mr WD Fouché Tel: 013 249 7000

Emakhazeni Local Municipality

Mrs T Shoba Tel: 013 253 7600

Nkangala District Municipality

Mr A Zimbwa (Acting) Tel: 013 249 2000

1.5 Applicable Legislation

1.5.1 The Constitution of the Republic of South Africa (Act No. 108 of 1996)

In terms of Section 24 of the Constitution of the Republic of South Africa (Act No.108 of 1996),

everyone has the right to an environment that is not harmful to their health or well-being and to

have the environment protected, for the benefit of present and future generations, through

reasonable legislation and other measures that prevent pollution and ecological degradation,

promote conservation and secure ecologically sustainable development and use of natural

resources while prompting justifiable economic and social development. The needs of the

environment, as well as affected parties, should thus be integrated into overall project

management in order to fulfil the requirements of Section 24 of the Constitution.

1.5.2 National Environmental Management Act (Act No. 107 of 1998)

The NEMA, as amended, contains a set of principles in Chapter 2 that govern environmental

management. These principles must be adhered to and taken into consideration during the EA

Application as well as all the life cycle phases of the proposed project.

The term ‘environment’ is defined in terms of NEMA as:

“Environment“ means the surroundings within which humans exist and that are made up

of –

(i) the land, water and atmosphere of the earth;

(ii) micro-organisms, plant and animal life;

(iii) any part or combination of (i) or (ii) and the interrelationship among and between

them;

(iv) The physical, chemical, aesthetic and cultural, properties and conditions of the

foregoing that influence human health and wellbeing.

Section 24(1) of the NEMA states:

“In order to give effect to the general objectives of integrated environmental management

laid down in this Chapter [Chapter 5], the potential consequences for or impacts on the

environment of listed activities or specified activities must be considered, investigated,

assessed and reported on to the competent authority or the Minister of Minerals and



Energy, as the case may be, except in respect of those activities that may commence

without having to obtain an environmental authorisation in terms of this Act.”

Based on the aforesaid, the proposed new Rietkuil Private Railway Siding and associated

infrastructure constitute activities listed contained in GN R544 and GN R545 of 18 June 2010

which requires that EA, from the Competent Authority (MDARDLEA), in terms of GN R543 of 18

June 2010 must be obtained prior to the commencement of construction activities.

Further, Section 28 of the NEMA places a Duty of Care on all persons to prevent, limit or

remediate any pollution or degradation of the environment. This duty of care should be adhered

to at all times during construction, operation and decommissioning of the proposed project.

Section 28 applies to all activities taking place, and not solely focused on the listed activities

being applied for.

1.5.3 EIA Regulations GN R543 of 18 June 2010

The EIA Regulations (GN R543 of 18 June 2010) were promulgated in terms of Section 24 of the

NEMA, to manage the process, methodologies and requirements for the undertaking of an

application for an EA as stipulated in Section 24 of NEMA. GN R543 of 18 June 2010 stipulates

that the applicant must appoint an independent EAP to manage the application process for EA

where a development constitutes activity/ies listed in terms of GN R544, GN R545 and/or GN

R546 of 18 June 2010.

GN R543 of 18 June 2010 defines two categories for undertaking an application for EA, namely

the basic assessment process and the ‘full’ EIA process.

The basic assessment process is generally intended for smaller scale projects, or activities

whose impacts are well understood and can be easily managed or where permission is granted

to undertake the basic assessment process instead of the ‘full’ EIA process. The basic

assessment process requirements are contained in Regulations 21 to 25 of GN R543 of 18 June

2010.

The full EIA process must be followed where the development constitutes activity/is listed in

terms of GN R545 of 18 June 2010 or where permission is granted to undertake the full EIA

process instead of the basic assessment process.

The proposed construction of the proposed new Rietkuil Private Railway Siding and associated

infrastructure constitute listed activities listed in GN R544 and GN R545 of 18 June 2010 and

based on the regulatory requirements, requires that a ‘full’ EIA process be undertaken in order to

meet the requirements of both processes as contained in GN R543 (22)(2)(c) of 18 June 2010.

1.5.4 NEMA Listing Notices 1 and 2 of 18 June 2010

The listed activities triggered under GN R544 and GN R545 of 18 June 2010, are listed in Table

1-6 as well as the project activities that trigger the listed activities.



Table 1-6: Listed NEMA Activities

Number and date of relevant notice

Activity No(s)

(in terms of the relevant notice)

Description of each listed activity as per the government notice and the detailed project description

Description of the proposed activities in relation to the listed activities being applied for

GN R544 9 The construction of facilities or infrastructure exceeding 1000 metres in length for the bulk transportation of storm water with a peak throughput of 120 litres per second or more.

The construction of storm water management systems for the management of clean and dirty water around the coal stockpile. These systems will be sized to accommodate the 1:50 year flood and may thus exceed the 120 l/s peak flow.

11 The construction of channels and bridges where such construction occurs within a watercourse or within 32 metres of a watercourse, measured from the edge of a watercourse.

The construction of culverts, channels at river/stream crossings associated with the upgrade of the D 1770 and the new access road.

12 The construction of facilities or infrastructure for the off-stream storage of water, including dams and reservoirs, with a combined capacity of 50000 cubic metres or more, unless such storage falls within the ambit of activity 19 of Notice 545 of 2010;

Construction of a PCD with a capacity of approximately 51 230 cubic metres with a vertical wall height not exceeding 3 metres.

18 The infilling or depositing of any material of more than 5 cubic metres into, or the dredging, excavation, removal or moving of soil, sand, shells, shell grit, pebbles or rock of more than 5 cubic metres from a watercourse.

The construction of culverts, channels at river/stream crossings associated with the upgrade of the D 1770 and the new access road. This will result in the dredging or moving of 5 cubic meters of soil or more from two unnamed tributaries

22 The construction of a road, outside urban areas, with a reserve wider than 13,5 meters.

The construction of an access road with servitude ranging between 23 m and 150 m. The access road will be approximately 6.5 km long and intersecting with the existing D 1555 Road. The access road will accommodate both bi-directional and single directional traffic flow. The width of the access road will vary between an approximate 4 m and 8 m respectively. Further to the above the access road will be designed with a 1 m gravel shoulder on either side of the road.

47 The widening of a road by more than 6 metres, or the lengthening of a road by more than 1 kilometre where the existing reserve is wider than 13,5 meters.

The widening and upgrade the existing D 1770 Road by more than 6 metres to accommodate increased traffic load.

GN R545 5 The construction of facilities or infrastructure for any process or activity which requires a permit or license in terms of national or provincial legislation governing the generation or release of emissions,

The construction of a PCD requiring a water use license in terms of Section 21 of the NWA.



Number and date of relevant notice

Activity No(s)

(in terms of the relevant notice)

Description of each listed activity as per the government notice and the detailed project description

Description of the proposed activities in relation to the listed activities being applied for

pollution or effluent and which is not identified in Notice No. 544 of 2010 or included in the list of waste management activities published in terms of Section 19 of the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008) (NEM: WA) in which case that Act will apply.

11 The construction of a railway lines, stations or shunting yards. The construction of a private railway siding of approximately 3.5 km in length. This distance includes the loading and run around lines.

19 Physical alteration of undeveloped, vacant or derelict land for residential, retail, commercial, recreational, industrial or institutional use where the total area to be transformed is 20 hectares or more.

The construction of:

A new Rietkuil Private Railway Siding of approximately 3.5 km in length;

A coal stockpile of approximately 54 000 tons;

A PCD with a capacity of approximately 51 230 cubic metres;

Other associated infrastructure including construction camps; and

The cumulative area is anticipated to exceed 20 hectares.



1.5.5 National Environmental Management: Biodiversity Act (Act No. 10 of 2004)

In line with the Convention on Biological Diversity, the National Environmental Management:

Biodiversity Act (Act No. 10 of 2004) (NEM: BA) aims to legally provide for biodiversity

conservation, sustainable use and equitable access and benefit sharing. NEM: BA creates a

basic legal framework for the formation of a national biodiversity strategy and action plan and the

identification of biodiversity hotspots and bio-regions which will then be given legal recognition. It

imposes obligations on landowners (state or private) governing alien invasive species as well as

regulates the introduction of genetically modified organisms.

The NEM: BA ensures that provision is made by the site developer to remove any aliens which

have been introduced to the site or are present on the site.

The NEM: BA also provides for listing of threatened or protected ecosystems, in one of four

categories: critically endangered, endangered, vulnerable or protected. Threatened ecosystems

are listed in order to reduce the rate of ecosystem and species extinction by preventing further

degradation and loss of structure, function and composition of threatened ecosystems. The

purpose of listing protected ecosystems is primarily to conserve sites of exceptionally high

conservation value.

According to the National List of Threatened Terrestrial Ecosystems (2011) the proposed

portion of the remaining extent of the Eastern Highveld Grassland Ecosystem, listed as a

‘Vulnerable’ ecosystem is present in most sections of the study area.

1.5.6 National Environmental Management: Air Quality Act (Act No. 39 of 2004)

The National Environmental Management: Air Quality Act (Act No. 39 of 2004) (NEM: AQA) was

implemented on 24 February 2005 and reforms the law regulating air quality in order to protect

the environment by providing reasonable measures for the prevention of pollution and ecological

degradation and for securing ecologically sustainable development while promoting justifiable

economic and social development; to provide for national norms and standards regulating air

quality monitoring, management and control by all spheres of government; for specific air quality

measures; and for matters incidental thereto.

On 22 November 2013 the list of activities which result in atmospheric emissions which have or

may have a significant detrimental effect on the environment, including health, social conditions,

economic conditions, ecological conditions or cultural heritage was published under GN 893 of 22

November 2013. Part 3, Category 5, subcategory 5.1 of GN 893 of 22 November 2013 which

stipulates that storage and handling of ore or coal not situated on the premises of a mine or

works as defined in the Mines Health and Safety Act (Act No. 50 of 1991) (MHSA) at locations

designed to hold more than 100 000 tons requires an Air Emission Licence is applicable to the

proposed project. The proposed coal stockpile area will have an approximate capacity of 54

000 tons and will thus not trigger the minimum emissions standards as stipulated under

subcategory 5.1 of GN 893 of 22 November 2013.

On 1 November 2013 the National Dust Control Regulations were published under GN R827.

The dust fall rate for non-residential areas should less than 1200 mg/m2/day measured over 30

days.

For the purpose of the proposed development a continuous dust fall monitoring

programme will be implemented to ensure compliance with the Dust Control Regulations.



1.5.7 National Water Act (Act No. 36 of 1998)

The National Water Act (Act No. 36 of 1998) (NWA) is the primary regulatory legislation,

controlling and managing the use of water resources as well as the pollution thereof. The NWA

provides for fundamental reformation of legislation relating to water resource use. The preamble

to the NWA recognises that the ultimate aim of water resource management is to achieve

sustainable use of water for the benefit of all users and that the protection of the quality of water

resources is necessary to ensure sustainability of the nation’s water resources in the interests of

all water users. The purpose of the NWA is stated in Section 2 and enforced by the DWS.

Section 2 of the NWA relates to the following:

Promoting the efficient, sustainable and beneficial use of water in the public interest;

Facilitating social and economic development;

Protecting aquatic and associated ecosystems and their biological diversity;

Reducing and preventing pollution and degradation of water resources;

Meeting international obligations.

The NWA presents strategies to facilitate sound management of water resources, provides for

the protection of water resources, and regulates use of water by means of Catchment

Management Agencies, Water User Associations, Advisory Committees and International Water

Management. As the NWA is founded on the principle the government has overall responsibility

for and authority over water resource management, including the equitable allocation and

beneficial use of water in the public interest, an industry (including mines) can only be entitled to

use water if the use is permissible under the NWA. The anticipated water uses in terms of

Section 21 of the NWA for the proposed project are included in Table 1-7.

Table 1-7: Anticipated Water Uses to be applied for

Section 21

of the

NWA

Description of each listed activity as per the government notice and the detailed

project description

21 (a) Taking water from a water resource

Abstraction of water from a borehole located at the proposed new Rietkuil Private

Railway Siding for day to day activities at the siding. This activity will take place on Portion

24 of the Farm Driefontein, Farm No 297 JS. Approximately 2.5 cubic metres will be

abstracted daily.

21 (c) Impeding or diverting the flow of water in a watercourse

Upgrading approximately 3 km of the provincial road D 1770, on Portions 9 and 10 of the

Farm Blyvooruitzicht, Farm No 383 JT, which will include the construction of a new culvert.

Constructing a new private access road of approximately 6.5 km, with culverts approximately

every 200m through the wetland area on the Portion 4 of the Farm Tweefontein, Farm No

458 JS, Portions 6 and 16 of the Farm Grootlaagte, Farm No 449 JS. This new access will

intersect with the existing D 1555 Road.

These construction activities will take place within 500m of a wetland or watercourse will be

licensed under Section 21 (c).

21 (g) Disposing of waste in a manner which may detrimentally impact on a water resource

Storage of waste water originating from the proposed new Rietkuil Private Railway



Section 21

of the

NWA

Description of each listed activity as per the government notice and the detailed

project description

Siding and surface water runoff from the coal stockpile in the pollution control dam; and

using the waste water from the pollution control dam as dust suppression measure. These

activities will take place on the Portion 4 of the Farm Tweefontein, Farm No 458 JS.

21 (i) Altering the bed, banks, course or characteristics of a watercourse

Upgrading approximately 3 km of the provincial road D 1770, on Portions 9 and 10 of the

Farm Blyvooruitzicht, Farm No 383 JT, which will include the construction of a new culvert.

Constructing a new private access road of approximately 6.5 km, with culverts approximately

every 200m through the wetland area on the Portion 4 of the Farm Tweefontein, Farm No

458 JS, Portions 6 and 16 of the Farm Grootlaagte, Farm No 449 JS. This new access will

intersect with the existing D 1555 Road.

All activities taking place within 500m of a wetland or watercourse will be licensed under

Section 21 (j).

1.5.8 National Heritage Resources Act (Act No. 25 of 1998)

The protection and management of South Africa’s heritage resources are controlled by the

National Heritage Resources Act (Act No. 25 of 1999) (NHRA). The enforcing authority for this

act is the South African Heritage Resources Agency (SAHRA). In terms of the NHRA, historically

important features such as graves, trees, archaeology and fossil beds are protected. Similarly,

culturally significant symbols, spaces and landscapes are also afforded protection. In terms of

Section 38 of the NHRA, SAHRA can call for a Heritage Impact Assessment (HIA) where certain

categories of development are proposed. The Act also makes provision for the assessment of

heritage impacts as part of an EIA process and indicates that if such an assessment is deemed

adequate, a separate HIA is not required. Should a permit be required for the damage or

removal of specific heritage resources, Exxaro will submit a separate application for these

activities to the SAHRA for approval, should these resources be potentially damaged or removed.

The activities identified in the NHRA requiring notification to SAHRA include:

Section 38 states:

“(1) (a): The construction of a road, wall, power line, pipeline, canal or other similar form of linear development or barrier exceeding 300 m in length;

(c): Any development or other activity which will change the character of a site

i. exceeding 5 000 m² in extent ; or ii. involving three or more existing erven or subdivisions thereof ; or iii. involving three or more erven or divisions thereof which have been

consolidated within the past 5 years; or iv. the costs of which will exceed a sum in terms of regulations by

SAHRA or a provincial heritage resource authority.”

A HIA will be conducted as part of this project. The terms of reference for the HIA can be

found in Section 4.12.

1.5.9 Conservation of Agricultural Resources Act (Act No. 43 1983)

The Conservation of Agricultural Resources Act (Act No. 43 of 1983) (CARA) aims to provide for

control over the utilisation of natural agricultural resources in order to promote the conservation of



soil, water resources and vegetation and to combat weeds and invader plants. The CARA makes

provision for control measures to be applied in order to achieve the objectives of the CARA, these

measures relate to inter alia:

Cultivation of virgin soil;

Utilisation / protection of wetlands, marshes, water sponges, water courses / sources;

The regulating of the flow pattern of run-off water;

The utilisation and protection of vegetation;

The grazing capacity of veld and the number and type of animals;

The control of weeds and invader Plants;

The restoration or reclamation of eroded land or land which is disturbed or denuded.

The surface area of the proposed project is mainly utilised for mining, grazing and crop

production. Exxaro should pay cognisance to the requirements of this Act where

applicable.

1.5.10 Mpumalanga Conservation Act (Act No. 10 of 1998)

The Mpumalanga Conservation Act (Act No. 10 of 1998) aims to consolidate and amend the laws

relating to nature conservation within the Province and to provide for matters connected thereof.

Chapter 2 (hunting of wild animals), Chapter 6 (picking of indigenous plants) and Chapter 7

(removal of endangered of rare species from the Province) of this act could be applicable if these

activities take place by employees, contractors or sub-contractors employed by Exxaro during the

construction, operational and decommissioning phase of the proposed new Rietkuil Private

Railway Siding and associated infrastructure.

1.5.11 Guidelines

In addition to the above mentioned Acts and their associated Regulations, the following

Guidelines and reports will be taken cognisance of during the EIA/EMPr phase of the proposed

project:

Mpumalanga Biodiversity Conservation Plan, 2007;

Nkangala Integrated Development Plan (IDP);

Nkangala Spatial Development Framework (SDF);

Steve Tshwete SDF;

Emakhazeni SDF;

Mpumalanga Environmental Implementation Plan, 2001;

Mpumalanga State of the Environment Report. 2003;

Department of Environmental Affairs and Tourism (DEAT). 2002. Integrated Environmental

Management, Information series 2: Scoping. Department of Environmental Affairs and

Tourism (DEAT. 2002);

Department of Environmental Affairs (DEA). 2012. Companion to the EIA Regulations 2010,

Integrated Environmental Management Guideline Series 5, Companion to the NEMA EIA

Regulations of 2010, Department of Environmental Affairs;

DEA 2012. Companion to the EIA Regulations 2010, Integrated Environmental Management

Guideline Series 7, Public Participation, Department of Environmental Affairs; and

DEAT. 2002. Integrated Environmental Management, Information Series 12: Environmental

Management Programmes. Department of Environmental Affairs and Tourism (DEAT. 2002);

DEA. 2012. Draft guideline on need and desirability in terms of the environmental impact

assessment (EIA) regulations, 2010.



1.6 Legislative requirements

The content of this Draft EIAr complies with the requirements of Regulation 31 of GN R543 of 18

June 2010. The regulatory requirements can be found in the sections of the report indicated in

Table 1-8.

Table 1-8: Regulatory Requirements

Regulation Content Section of Report

GN R543

31(2)(a) Details of—

(i) the EAP who prepared the report; and

(ii) the expertise of the EAP to carry out scoping procedures.

Section 1.2

31(2)(b) A description of the proposed activity. Section 3

31(2)(c) A description of the property on which the activity is to be undertaken and the location of the activity on the property, or if it is—

(i) a linear activity, a description of the route of the activity; or

(ii) an ocean-based activity, the coordinates where the activity is to be undertaken;

Section 2.1.3

31(2)(d) Description of the environment that may be affected by the activity and the manner in which the physical, biological, social, economic and cultural aspects of the environment may be affected by the proposed activity

Section 4

31(2)(e) Details of the public participation process conducted in terms of sub-regulation (1), including—

Section 0

31(2)(e)(i) Steps undertaken in accordance with the plan of study Section 7.2

31(2)(e)(ii) A list of persons, organizations and organs of state that were

Registered as interested and affected parties;

Appendix D

31(2)(e)(iii) A summary of comments received from, and a summary of

Issues raised by registered interested and affected parties, the date of receipt of these comments and the response of the EAP to those comments; and

Appendix D

31(2)(e)(iv) Copies of any representations and comments received from registered interested and affected parties;

Appendix D

31(2)(f) A description of the need and desirability of the proposed activity

Section 3.1

31(2)(g) A description of identified potential alternatives to the proposed activity, including advantages and disadvantages that the proposed activity or alternatives may have on the environment and the community that may be affected by the activity;

Section 3.3

31(2)(h) An indication of the methodology used in determining the significance of potential environmental impacts

Section 5.2

31(2)(i) A description and comparative assessment of all alternatives identified during the environmental impact assessment process

Section 3.3

31(2)(j) A summary of the findings and recommendations of any specialist report or report on a specialized process

Section 5.3

31(2)(k) A description of all environmental issues that were identified during the environmental impact assessment process, an assessment of the significance of each issue and an indication of the extent to which the issue could be addressed by the adoption of mitigation measures;

Section 4

31(2)(l) An assessment of each identified potentially significant Section 5.3



Regulation Content Section of Report

impact, including—

(i) cumulative impacts;

(ii) the nature of the impact;

(iii) the extent and duration of the impact;

(iv) the probability of the impact occurring;

(v) the degree to which the impact can be reversed;

(vi) the degree to which the impact may cause irreplaceable loss of resources; and

(vii) the degree to which the impact can be mitigated

31(2)(m) A description of any assumptions, uncertainties and gaps in knowledge

Section 5.1

31(2)(n) A reasoned opinion as to whether the activity should or should not be authorized, and if the opinion is that it should be authorized, any conditions that should be made in respect of that authorisation

Section 8

31(2)(o) An environmental impact statement which contains—

(i) a summary of the key findings of the environmental impact assessment; and

(ii) a comparative assessment of the positive and negative implications of the proposed activity and identified alternatives;

Section 8.2

31(2)(p) A draft environmental management programme containing the aspects contemplated in regulation 33;

Appendix E

31(2)(q) Copies of any specialist reports and reports on specialized processes complying with regulation 32

Appendix C

31(2)(r) Any specific information that may be required by the competent authority; and

N/A

31(2)(s) Any other matters required in terms of sections 24(4)(a) and (b) of the act.

N/A

2 Background Exxaro intends exporting a percentage of the coal mined at the proposed Belfast Coal Mine and

requires a suitable siding accessible to the existing coal line to RBCT. Therefore, Exxaro

undertook a number of studies to determine the viability and nature of the transport system and

infrastructure required for the railage of coal mined at their proposed Belfast Coal Mine.

Subsequently to these viability and feasibility studies Exxaro identified the need for them to

construct the proposed development south-west of the proposed Belfast Coal Mine.

The proposed development will be located parallel and north-west of the existing TFR Rietkuil

Station and situated within the existing Exxaro Arnot Coal Mine’s, Mining Right area. This

proposed development with associated infrastructure will cover a footprint of at approximately 45

hectares. It is proposed to construct a proposed development, a coal stockpile area, a storm

water management system, a PCD, the construction, upgrade and widening of access roads, the

construction, expansion and rectification of the culverts, and the construction of other associated

infrastructure.

2.1 Background of the project

2.1.1 Existing infrastructure

The only existing infrastructure associated with the activities proposed to take place is the

existing road network and railway infrastructure. No other infrastructure exists on the site where



the proposed private railway siding, the coal stockpile area, the storm water management system

and the PCD are proposed to be constructed. Further, existing road infrastructure will be

upgraded from unpaved to paved roads. The sections where the road upgrades are proposed

will be widened and culverts will be installed.

2.1.2 Existing approvals/authorisations

There are no active EAs associates with the site where the activities are proposed to take place.

2.1.3 Project Area Description

In terms of the administrative boundaries, the proposed project is located within the Mpumalanga

Province. The project is located within the Steve Tshwete and Emakhazeni Local Municipalities

of the Nkangala District Municipality. The proposed new Rietkuil Private Railway Siding and

associated infrastructure will be located within Ward 7 of the Steve Tshwete Local Municipality

with the upgrade of the D 1110 and the upgrade and widening of the D 1770 road located within

Wards 1 and 8 of the Emakhazeni Local Municipality. The towns, cities, and residential areas

close to the proposed project area are given in Table 2-1 with line-of-sight distances.

Table 2-1: Nearest Towns to the Proposed Development

Town Distance (km) Direction

Rietkuil 3.8 km South of the coal stockpile and private railway siding

Belfast 17 km North-east of the D 1770 and D 1110 road upgrades

Pullenshope 20 km West of the coal stockpile and private railway siding

Carolina 29 km South-east of the D 1770 and D 1110 road upgrades

Bankfontein 30 km North-west of the coal stockpile and private railway siding

Machadodorp 34 km North-east of the D 1770 and D 1110 road upgrades

Middleburg 34 km North-west of the coal stockpile and private railway siding

Emalahleni 52 km West of the coal stockpile and private railway siding

The proposed new Rietkuil Private Railway Siding and associated infrastructure will be located on

the farm portions listed in Table 2-2 and the table also provides a description of the activities

proposed to take place on each farm portion.

Table 2-2: List of Affected Farms and Farm Portions Illustrating the Relevant Activities

Farm Portions Proposed Activities

Arnot East 984 JS Farm is not subdivided

PCD and Access Road

Blesbokspruit 455 JS Portion 3 and 4 Upgrade of the D 1110 provincial road

Blyvooruitzicht 383 JT Portion 9 and 10 Upgrade of the D 1770 provincial road

Grootlaagte 449 JS Portions 6, and 16 Siding Access Road (and construction of culverts)

Kaalplaats 453 JS Portion 1, 4 and 5 Upgrade and widening of the D 1770 (and construction of culverts) provincial road and upgrade of the D 1110 provincial road

Leeuwbank 427 JS Portion 3 and 16 Upgrade of the D 1110 provincial road

Tweefontein 458 JS Portion 4 and the Remainder

Coal stockpile area, PCD, private railway siding and new access road (and construction of culverts)

Wonderfontein 428 JS Portion 19 Upgrade of the D 1110 provincial road

The proposed new Rietkuil Private Railway Siding and associated infrastructure is located

approximately 38 km southwest of the town of Belfast, approximately 38 km southeast of the



town of Middelburg, and approximately 180 km east of Johannesburg. Figure 2-1 contains the

locality map and provides an overview of the proposed transport route from the proposed Belfast

Coal Mine to the proposed new Rietkuil Private Railway Siding and associated infrastructure.

Figure 2-2 provides a close up view of the proposed road upgrades. Figure 2-3 provides a close

up view of the proposed new Rietkuil Private Railway Siding and access road.



RIETKUIL PRIVATERAILWAY SIDING AND ASSOCIATED INFRASTRUCTURE Project No.

467209

Figure 2-1: Overall Layout Map of the proposed Transport Route from the Belfast Coal Mine to the Rietkuil private railway siding



RIETKUIL PRIVATERAILWAY SIDING AND ASSOCIATED INFRASTRUCTURE

Project No. 467209

Figure 2-2: Layout Map of the proposed Road Upgrades




Project No. 467209

Figure 2-3: Layout Map of the proposed Private Railway Siding and Associated Infrastructure.



3 Project Description

3.1 Need and Desirability

In addition to the local sales of thermal coal to Eskom the proposed Belfast project aims to support

the strategic vision of Exxaro by increasing Exxaro Coal’s steam coal exports and thereby its share

of the South African coal market as well as extend the life of mine of the Exxaro North Block

Complex (NBC).

A percentage of coal mined by the proposed Belfast Coal Mine will be exported via the RBCT.

South Africa has substantial coal reserves and there is scope for expanding its coal exports, which

may in turn generate much needed export earnings which may reduce South Africa’s negative trade

balance and current account deficit (Eberhard, 2011). Coal exports remain a source of foreign

revenue for South Africa.

The upgrade of the D 1110 and the upgrade and widening of the D 1770 provincial road will be

required in order to allow a safe hauling route from the proposed Belfast Coal Mine to the proposed

private siding. The upgrade of these roads will further be required to minimise safety risks and

generation of noise and dust during construction and operational activities of the proposed

development.

3.2 Detailed Project Description

The proposed new Rietkuil Private Railway Siding and associated infrastructureis planned to be

located parallel and northwest of the existing TFR Rietkuil station within the existing Exxaro Arnot

Coal Mine’s Mining Right area. The proposed development will cover a footprint of approximately 45

hectares, on the farm portions listed in Section 2.1.3. A site layout plan is contained in Appendix A.

The proposed construction activities will include the following:

The construction of a private railway siding of approximately 3.5 km in length, this includes the loading and run around lines;

The establishment of a coal stockpile of approximately 54 000 tons, with associated operational facilities;

Construction of a PCD with a capacity of approximately 51 230 cubic metres (described in Section 3.2.2);

The construction of a storm water management system for the management of clean and dirty water around the coal stockpile. The coal loading platform slopes away from the railway track work with a slope of 2% (1:50). Surface run-off from the loading facility and adjacent access road is collected in a concrete lined drain on the northern edge of the coal loading platform. The contaminated run-off flows under gravity and passes through a silt trap into the PCD on the South Western boundary of the site. Clean surface run-off water is diverted from the dirty water catchment area by means of cut-off channels and berms (described in Section 3.2.3);

Upgrading of the provincial D 1110 and D 1770 roads and the construction of a new private access road (described in Section 3.2.4);

The construction, expansion and rectification of the culverts associated with the new private access road and the provincial road D 1770 at wetland/river/stream crossings (described in Section 3.2.5);

The construction of other associated infrastructure (below the legal thresholds/triggers) including, but not limited to, construction camps, a weighbridge, offices, an approximately 26 500 litre capacity self-bonded diesel storage tank, complete with a hydrocarbon separator, and an 11kV 3 phase power route with a 200 kVA 3 phase transformer to provide electricity to the site.



3.2.1 Coal Stockpile and Siding

The proposed private siding will be equipped with a single signalled connection to the existing

Geluksplaas – Wonderfontein TFR mainline. The proposed new Rietkuil Private Railway Siding and

associated infrastructure will comprise of a rail way line adjacent to the coal loading platform. The

accumulative length of railway line will be approximately 3.5 km and include both loading and run

around lines. The stockpile area should be able to accommodate approximately 54 000 tons of

product with a height of 2.5 – 3 m. To prevent any contamination of ground water and pollution of

the soils, liners will be installed across the complete stockpile area.

3.2.2 Pollution Control Dam

The PCD has side slopes of 1:3 and is lined with a 2 mm thick high-density polyethylene (HDPE)

liner underlain by a geosynthetic clay liner (GCL). It is sized not to spill more than once in 50 years

and have an allowance for operational storage volume. The PCD has a freeboard of 800 mm, and is

equipped with reinforced concrete inlets and outlets. The PCD is provided with a 2 m wide concrete

hard standing to allow for access with a small Bobcat type loader for cleaning purposes. In the sizing

of the PCD allowance is made for water usage for dust suppression on the coal loading platform

(1.5l/m2/day average for the year but application rate will be about 2l/m

2/day). The proposed

capacity of the PCD is 51,230 m3 with a minimum surface area of 15,630 m

2.

3.2.3 Storm Water Management Infrastructure

A stormwater management plan was designed in order to prevent polluted water from entering a

water resource and separate the clean water system from any dirty area. The coal loading platform

slopes away from the railway track work with a slope of 2% (1:50). Surface run-off from the loading

facility and adjacent access road is collected in a concrete lined drain on the northern edge of the

coal loading platform. The contaminated run-off flows under gravity and passes through a silt trap

into the PCD on the South Western boundary of the site. Clean surface run-off water is diverted

from the dirty water catchment area by means of cut-off channels and berms.

3.2.4 Access Road and Road Upgrades

It is proposed to upgrade the D 1110 and D 1770 provincial roads and to construct a new private

access road. The upgrade of the D 1110, D 1770 and the construction of the new private access

road will include the construction of new culverts (where applicable) and will include amongst other:

Upgrade/expansion/surfacing of the existing provincial roads (provincial roads D 1110 and D

1770):

Approximately 9 km of the D 1110 will be upgraded to a paved road;

Approximately 3 km of the D 1770 will be widened by more than 6 metres;

The remaining portion of the D 1770 to the intersection with the D 1110 road will be upgraded to

a paved road.

Construction of a new private access road:

A new private access road of approximately 6.5 km long and servitude of between 23 m and 150

m will be constructed. This new access will intersect with the existing D 1555 provincial road.

The new private access road will accommodate bi-directional traffic and will have a paved area

of approximately 8 m in width and gravel shoulders of 1 m width. However, the area adjacent to

the siding and stockpile will comprise of a single lane traffic direction with an approximate paved

area (4 m wide) and shoulders (1 m wide) on either side of the road. The private access road to



the proposed siding is to enable haulage trucks to enter the siding and off-load product at the

planned coal stockpile area, north of the existing TFR railway line.

3.2.5 Wetland Crossings

Drainage channels and culverts associated with the wetland crossings will be constructed for the D

1770 provincial road and the new private access road. These 900 mm diameter pre-cast concrete

pipe culverts Class100D with ogee-type interlocking joints will be installed along sections of the

access roads to ensure that will allow surface water runoff to drain from the road surface into the

receiving environment.

3.2.6 Operational phase

During the operational phase Exxaro will be hauling coal from the proposed Belfast Coal Mine

operation via the abovementioned access roads to the coal stockpile area adjacent to the proposed

new Rietkuil Private Railway Siding and associated infrastructure. The coal will then be loaded onto

the locomotives and transported via rail to the RBCT for export purposes. All the stormwater runoff

from the coal stockpile area will be diverted to the PCD. The water accumulated in the PCD will be

used for dust suppression at the coal stockpile and the proposed new Rietkuil Private Railway

Siding.

3.2.7 Decommissioning and closure phase

All the infrastructure, i.e. the private railway siding, the PCD, the coal stockpile area and other

associated infrastructure will be decommissioned and removed and the site will be rehabilitated to

allow an approved land use to take place.

3.3 Alternatives

In terms of Regulation 31(g) of GN R543 18 June 2010, reasonable land use or development

alternatives to the proposed operation, alternative means of carrying out the proposed operation and

the consequence of not proceeding with the proposed operation must be identified and described.

The Draft EIAr provides a description of these alternatives to the proposed activity, including the

advantages and disadvantages that the activity or alternative may have on the environment as well

as how the community may be affected by the activity.

3.3.1 Location Alternatives

During the operational phase Exxaro will be hauling coal from the proposed Belfast Coal Mine

operation via the abovementioned access roads to the coal stockpile area adjacent to the proposed

new Rietkuil Private Railway Siding and associated infrastructure. The coal will then be loaded onto

the locomotives and transported via rail to the RBCT for export purposes. All the stormwater runoff

from the coal stockpile area will be diverted to the PCD. The water accumulated in the PCD will be

used for dust suppression at the coal stockpile and the proposed new Rietkuil Private Railway Siding

Screening of the Location Alternatives:

A number of alternatives were assessed as part of the feasibility study conducted for the proposed

new Rietkuil Private Railway Siding. Three alternative locations for the new Rietkuil Private Railway

Siding have been assessed with the Rietkuil location being the preferred site location for the

proposed activities. A feasibility study was undertaken and the following sites were investigated and

considered:

Proposed new Rietkuil Private Railway Siding and associated infrastructure (Preferred

Location Alternative):



Following the feasibility studies conducted for the proposed project, the location of the new Rietkuil Private Railway Siding at Rietkuil was deemed most preferable as the facilities will be in close proximity to the existing RBCT line and adjacent to an existing private railway siding.

Exxaro Glisa Siding at Belfast;

The Glisa site was eliminated at basic feasibility stage due to site congestion and the operational complexity of serving the site (shunting and train movements).

Transfer Freight Rail at Wonderfontein;

The TFR Wonderfontein site was eliminated on the basis of environmental and access constraints surfaced during previous attempts to activate this facility.

No location alternatives for the coal stockpile was assessed as the coal stockpile must be located in

close proximity to the private railway siding.

No alternatives for the road upgrades of the D 1110 and D 1770 to accommodate the hauling to and

from the proposed Belfast Coal Mine have been assessed. The existing gravel roads will be

upgraded to paved roads which will reduce the generation of dust and increase the safety of road

users.

No alternatives were considered for the construction of the new private access road from the

proposed new Rietkuil Private Railway Siding to the intersection of the D 1550 as all environmental

sensitivities were considered during the feasibility study and specialist studies conducted for this

project.

3.3.2 Technology Alternatives

Linear Railway Siding and Coal Stockpile Area (Preferred Technology Alternative)

The linear railway siding will consist of a loading and run around railway line parallel to the existing

rail network in a disturbed and transformed area with no environmental sensitivities. The

construction of a linear railway siding will result in a reduced footprint thereby minimising the

anticipated biophysical, social and cultural impacts in the immediate vicinity. Loading of coal onto

empty waggons will be done through the use of front end loaders. Loading by means of front end

loaders will prolong the loading time compared to the use of a balloon siding where conveyors are

utilised for the loading of coal onto the empty waggons. However, the use of front end loaders will

increase the employment opportunities during the operation phase of proposed facility.

Balloon Railway Siding (Technology Alternative 1)

The balloon railway siding will result in a railway loop being constructed to the north of the coal

stockpile area. The balloon siding will utilise conveyors for the loading of coal onto the empty

waggons from storage silos. A balloon type siding will reduce the loading time of empty waggons.

However, this would entail larger disturbance footprint to accommodate the silos, the conveyors and

railway line. It was concluded by the specialist studies that the area where the proposed

balloon railway siding could be accommodated comprise of environmental sensitivities,

wetlands and the spoor of the Parahyaena brunnea (Brown Hyaena) that was found in the

area. This proposed alternative is not regarded as viable or feasible to the applicant and the

impacts will not be further assessed in this report.

3.3.3 ‘No-Go’ Alternative

It is envisaged that the proposed Belfast Coal Mine will mine approximately 2.2 million tons coal per

annum. Exxaro intends to increase its coal exports and a percentage of the coal mined by the

proposed Belfast Coal Mine will be exported via the proposed new Rietkuil Private Railway Siding to



the RBCT. Should the proposed project not commence, the status quo remains, and the proposed

Belfast Coal Mine would not be able to export coal via the RBCT as no railway siding will be

constructed.

It is evident from the specialist studies conducted as part of this application process for EA

that no significant negative/detrimental environmental impacts that cannot be mitigated,

limited and minimized exists or are associated with the construction of the preferred option

of the proposed new Rietkuil Private Railway Siding and associated infrastructure that would

prohibit the construction thereof. The proposed location and preferred technology

alternative will be constructed in a transformed area and will be situated adjacent to an

existing railway line.

4 Description of Baseline Environment In this section of the report, a summary of the baseline environment of the areas on which the

proposed project is to be located is described.

4.1 Climate

4.1.1 Regional climate

The nearest South African Weather Services (SAWS) monitoring stations are located in Belfast and

the second closes station is situated in Witbank. The regional climate has been provided in order to

understand the climatic conditions around the proposed project area. The monthly distribution of

average daily maximum temperatures shows that the average midday temperatures for Belfast

range from 14.7 °C in June to 22.5 °C in January. The region is the coldest during June when the

mercury drops to 1.3 °C on average during the night (SRK Consulting, 2014).

4.1.2 Rainfall and Evaporation

About 85% of the yearly rainfall falls in summer (October – March), in the form of showers and

thunderstorms, with the maximum precipitation falling in January and the minimum during July. The

data below includes rainfall and evaporation values. The rainfall stations with historical data have

been identified and are listed in Table 4-1. Initial enquiries to the SAWS have revealed that none of

these stations are currently operational.

The data were supplemented with records from the Nooitgedacht dam and the Leeuwpan farm

owner. A combined rainfall record was created with these stations from October 1903 to May 2013.

The final record comprised of the daily rainfall records from October 1903 to August 2000 from the

Klippan station (0516653 W), from September 2000 to September 2009 from the Nooitgedacht Dam

(0517147W), and from October 2009 to May 2013 from the Louis Breytenbach’s farm records. The

daily rainfall from this record for the period July 2012 to May 2013 were compared with the data for

the same period from the Leeuwpan farm and the data compared favourably.

Table 4-1: Rainfall Station Details

Rainfall station name

Rainfall station SAWS

number

Sta

rt o

f R

eco

rd

En

d o

f re

co

rd

Years

reco

rd

MA

P

Lo

ng

itu

de

La

titu

de

Alt

itu

de

Dis

tan

ce

fro

m s

ite

YYYY/MM YYYY/MM years mm DDMM DDMM mamsl km

Klippan 0516653 W 1903/10 2000/07 96 680 29 52 25 53 1715 5.5

Grootlaagte 0516592 W 1882/01 2000/08 103 713 29 50 25 53 1730 6.5



Rainfall station name

Rainfall station SAWS

number Sta

rt o

f R

eco

rd

En

d o

f re

co

rd

Years

reco

rd

MA

P

Lo

ng

itu

de

La

titu

de

Alt

itu

de

Dis

tan

ce

fro

m s

ite

Fairview 0516777 W 1903/10 2000/07 95 710 29 56 25 57 1701 6.9

Farmhouse 2009/10 2013/05 5 727 29 86 25 93 1734 0.35

Bosmanspruit 0516414 1882/01 2000/08 103 626 29 45 25 54 1661 2.5

The annual and monthly statistics were derived from the combined rainfall data. The annual rainfall

varies from a minimum of 389mm (1935) to a maximum of 1083mm (1987) as indicated in Figure

4-1. The annual rainfall is less than 600 mm for 25% of the time.

RIETKUIL PRIVATE RAILWAY SIDING AND

ASSOCIATED INFRASTRUCTURE

Project No.

467209

Figure 4-1: Percentiles of Monthly Rainfall and Annual Rainfall (Inset) for the Klippan-Nooitgedacht Dam-Leeuwpan Combined Record

Long-term monthly averages for rainfall (combined rainfall record) and evaporation Symons pan

derived from the quaternary records in WR2005, (Middleton & Bailey, 2011), are shown in Table 4-2

and Table 4-3.

Table 4-2: Average Rainfall in mm from the Combined Record

Rain Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Total

(mm) 123 89 90 42 13 6 5 8 23 73 111 116 685

Table 4-3: Average Monthly Evaporation at Symons Pan

Evaporation Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Total

S-Pan Evap. (mm)

137.8 137.5 156.2 163.6 140.2 137.6 104.4 91.1 74.8 80.8 102.2 124.0 1450

Lake Evap Factor

0.8 0.8 0.8 0.8 0.8 0.8 0.8 0.8 0.8 0.8 0.8 0.8

Lake Evap (mm)

111.6 112.7 129.6 137.4 123.4 121.1 91.9 79.2 63.6 67.0 82.8 100.1 1220





Project No.

467209

Figure 4-2: Average Monthly Rainfall for the Klippan-Nooitgedacht Dam-Leeuwpan Combined Record (1904 – 2012) and Symons Pan Evaporation from WR2005

4.2 Topography

The general topography of the area consists of undulating plains. The terrain morphology forms part

of Division E, namely closed hills and mountains with a moderate and high relief, and sub-division

27, namely low mountains. The slopes consist of concave, convex and straight slopes with a relief

of between 450 – 900 m. Less than 20% of the area consists of areas with a slope of less than 5%

(Marsh (Pty) Ltd, 2010). Two drainage systems are present where the proposed coal stockpiling

area will be located, falling from the east to the west over the northern section of the proposed coal

stockpile area draining towards the Bosmanspruit. The Bosmanspruit is approximately 1.2 km away

from the proposed railway siding, PCD and coal stockpile area. Based on the site contours the

Bosmanspruit will not be impacted upon by the construction of the proposed new Rietkuil Private

Railway Siding and associated infrastructure. The coal stockpile area will be appropriately lined and

in terms of the storm water management system the storm water run-off from the stockpile area will

drain towards the lined PCD.

4.3 Geology

The geology of the study area is comprised of Vryheid and Dwyka sediments of the Ecca Group,

within the Karoo Supergroup. The basement is made up of pre-Karoo, gabbro, diabase and felsite

(Rooiberg Formation). The sedimentary succession of sandstones, thinly laminated siltstones,

subordinated shales and coal seams is generally horizontal. A map of the geology of the study area

is included as Figure 4-3.



RIETKUIL PRIVATE RAILWAY SIDING AND ASSOCIATED INFRASTRUCTURE Project No.

467209

Figure 4-3: Geological Map



4.4 Geochemical

Information on the geology and geochemistry of coal generated from the Witbank Coal Fields was

sourced from literature and it was important to interpret the analyses of the samples from the

analogue collieries that are located in close proximity to Belfast area, with these collieries used as

indicative of the geochemical characteristics of the material to be stockpiled at the siding.

Mineralogical analysis studies carried out by Pinetown, K. & Boer, R. (2004) as part of a regional

acid base accounting study of the Highveld/Witbank coalfields indicated that the coal contains the

acid generating sulfide mineral, pyrite. Fast acid neutralising carbonate minerals, calcite and

dolomite, are also present in the coal discard and coal fines (Vermeulen, D., Cruywagen, L. M., &

Steyl, G., 2011).

Three coal samples from Coal Seam No. 2 were collected by Exarro as analogues that Exxaro

believes to be representative of the material to be stockpiled at the siding and these were delivered

to SRK for analyses. A large diameter core was drilled from the Belfast coal deposit to obtain the

samples. Based on geological data, the deposit was divided into different areas (1, 2 & 3) on the

basis of the areas where coal was expected to have similar characteristics. The laboratory results,

data analysis and interpretation for the geochemical characterisation of the coal samples concluded

that the coal to be stockpiled at the proposed new Rietkuil Private Railway Siding are potentially non

–acid forming as it is presently neutral and is predicted to stay neutral in the future.

4.5 Soils and Land use

4.5.1 Soils

The dominant soil forms identified in the project affected area (sidings and roads) belong to the

Bloemdal, Glencoe, Hutton, Longlands and Pindene soil forms. Brief characteristics of the dominant

soils forms pertinent to rehabilitation are presented below.

Bloemdal form (Bd) (12.4 ha or 17.7 % of the baseline study area)

Soil depths of the Bloemdal profiles surveyed on site ranged between 400mm and 700mm with

restrictive layers of rock or unspecified material with signs of wetness. Bloemdal soils with no

restrictions shallower than 500mm are generally good for crop production. All Bloemdal profiles are

structure less or have very weakly developed structure. The high quality orthic A and red apedal B-

horizons make it a suitable soil form for annual crop production.

Glencoe form (Gc) (15.2 ha or 21.7 % of the baseline study area)

This soil form characteristically has a moderately high degree of weathering, depletion of bases and

no significant acidity. The texture is a sandy loam and the morphology indicates a fluctuating water

table. Available Phosphate is usually very low although bases and micronutrients are in moderate

supply. The acidification risk is high with large Nitrogen fertiliser applications because of the sandy

structure. The soil can be used for dry land crop production but is more suitable for grazing.

Hutton form (Hu) (14.08 ha or 20.09% of the total study area)

Soil depths of the Hutton profiles surveyed on site ranged between 400mm and 700mm with

restrictive layers of rock or unspecified material without signs of wetness. Hutton soils with no

restrictions shallower than 500mm are generally good for crop production. All Hutton profiles are

structure less or have very weakly developed structure. The high quality orthic A and red apedal B-

horizons make it a suitable soil form for annual crop production (good rooting medium) and use as



‘topsoil’, having favourable structure (weak 1blocky to 2apedal) and consistence (slightly firm to

friable). However, its suitability for crop production is limited by the climate where it is found but

rainfall in the study area is sufficient for successful dryland crop production.

Longlands form (Lo) (10.3 ha or 20% of the baseline study area)

The Longlands soil form has a moderately high degree of weathering, depletion of bases and

moderate acidity and a sandy loam texture. The soil needs lime and broad-spectrum fertilising for

crop production but low buffer capacity will lead to rapid acidification if nitrogen is applied to

generously. Groundwater vulnerability would be high in the case of pollution. Lateral discharge

through the E and B horizons would result in the toe slope reception area being affected by a plume

of polluted water.

Pinedene form (Pn) (21.4 ha or 30.5 % of the baseline study area)

The Pinedene soil form consists of an orthic A horizon overlying a yellow-brown apedal B horizon

that is underlain by unspecified material with signs of wetness. The Pinedene soil form has a

moderately high degree of weathering, depletion of bases and moderate acidity and a sandy loam

texture. Dolomitic lime would be needed to achieve good crop yields. The soil is suited to dryland

crop production, subject to appropriate chemical amelioration.

4.5.2 Land Capability of the area

Land capability classes were determined using the guidelines outlined in Section 7 of The Chamber

of Mines Handbook of Guidelines for Environmental Protection (Volume 3, 1981). The Chamber of

Mines pre-mining land capability system was utilised, given that this is the dominant capability class

classification system utilized in the mining and industrial fields.

Table 1 indicates the set of criteria as stipulated by the Chamber of Mines (1981) to group soil forms

into different land capability classes.

Table 4-4: Pre-Mining Land Capability Requirements

Criteria Description

Criteria for Wetland Land with organic soils; or

A horizon that is gleyed throughout more than 50 % of its volume and is significantly thick, occurring within 750mm of the surface.

Criteria for Arable

Land

Land, which does not qualify as a wetland;

The soil is readily permeable to the roots of common cultivated plants to a depth of 750mm;

The soil has a pH value of between 4,0 and 8.4’

The soil has a low salinity and SAR;

The soil has a permeability of at least 1,5-mm per hour in the upper 500-mm of soil;

The soil has less than 10 % (by volume) rocks or pedocrete fragments larger than 100-mm in diameter in the upper 750-mm;

Has a slope (in %) and erodibility factor (K) such that their product is <2.0;

Occurs under a climatic regime, which facilitates crop yields that are at

1 BLOCKY STRUCTURE: A cube shaped ped

2 APEDAL: These soils are either single grained (incoherent) or massive (coherent). Peds are not apparent when the soil is moderately

moist.



least equal to the current national average for these crops, or is currently being irrigated successfully.

Criteria for Grazing

Land

Land, which does not qualify as wetland or arable land;

Has soil, or soil-like material, permeable to roots of native plants, that is more than 250-mm thick and contains less than 50 % by volume of rocks or pedocrete fragments larger than 100-mm;

Supports, or is capable of supporting, a stand of native or introduced grass species, or other forage plants, utilizable by domesticated livestock or game animals on a commercial basis.

Criteria for

Wilderness Land

Land, which does not qualify as wetland, arable land or grazing land.

Based on this system, the soil and land types identified in the study area could all be classified into

three different land capability classes. Deeper soils of the Hutton, Pinedene, and Bloemdal forms

have arable land capabilities which are suitable for dryland crop production. The Glencoe soil form

has grazing land capability. The Katspruit, Kroondal, Longlands and Willowbrook soil forms (6.72 ha

or 9.59% of the study site) have wetland land capability. Figure 4-4, Figure 4-5, Figure 4-6, Figure

4-7 and Figure 4-8 depicts the land use capability of the area.



RIETKUIL PRIVATE RAILWAY SIDING AND ASSOCIATED

INFRASTRUCTURE Project No.

467209

Figure 4-4: Land Capability of the Proposed New Access Road to the proposed new Rietkuil Private Railway Siding




INFRASTRUCTURE

Project No. 467209

Figure 4-5: Land Capability of the proposed new Rietkuil Private Railway Siding Road Upgrade (Map 1)





467209






467209






467209

Figure 4-8: Land capability map of the proposed new Rietkuil Private Railway Siding Pollution Control Dam and Coal Loading Facility development footprint area



4.5.3 Land Use

The entire siding and its immediate surrounds can be broadly defined as agricultural land with crop

and grazing fields on commercial farms. Crops like maize, potatoes, soya beans and sunflowers are

produced and grazing fields are mainly used for cattle farming. Other surrounding land uses include

coal mines with their associated infrastructure and an Eskom power station and substation also with

associated infrastructure. There are also commercial activities like a fuel station. Figure 4-9 depicts

the surrounding land uses.


ASSOCIATED INFRASTRUCTURE Project No.

467209

Figure 4-9: Surrounding land use map of the proposed new Rietkuil Private Railway Siding

4.6 Biodiversity

4.6.1 Vegetation

The study area falls within the Eastern Highveld Grassland vegetation type which occurs in the

plains between Belfast in the east and the eastern side of Johannesburg in the west and extends

southwards to Bethal, Ermelo and west of Piet Retief (Mucina & Rutherford, 2006).

The Eastern Highveld Grassland is considered endangered (Mucina & Rutherford, 2006) with only a

very small fraction conserved in statutory reserves (Nooitgedacht Dam and Jericho Dam Nature

Reserves) and in private reserves (Holkranse, Kransbank, Morgenstond). Approximately 44% is

transformed primarily by cultivation, plantations, mines, and urbanisation and by building of dams.

Cultivation may have had a more extensive impact, indicated by land-cover data. No serious alien



invasions are reported, but Acacia mearnsii can become dominant in disturbed areas. Erosion is

very low (Mucina & Rutherford, 2006).

However, in terms of the National List of Threatened Terrestrial Ecosystems (2011) published in

terms of NEM: BA the proposed portion of the remaining extent of the Eastern Highveld Grassland

Ecosystem, listed as a ‘Vulnerable’ ecosystem, presents most sections of the study area.

Further, in terms of National Protected Area Expansion Strategy (NPAES) the study area is not

affected by areas earmarked as part of the NPAES, nor is it situated close to any formally or

informally protected areas.

Three habitats are present in the study area and it comprises of:

Transformed Habitat Unit:

Commercial crop cultivation is the dominant land-use associated with the region where the study

area is situated, with Zea mays (maize) being the dominant crop. Furthermore, several stands

of alien tree bushclumps (mainly Acacia mearnsii) are present in the study area. All areas

associated with past or present crop cultivation, existing roads and all other disturbed areas fall

within the transformed habitat unit. All of these land-use activities have led to the alteration of

the floral community structure and habitat integrity of the transformed habitat unit to an

irreversible degree in most instances. Therefore, the transformed habitat unit is considered to

be of low conservation importance.

Secondary grasslands:

Sections associated with the study area which are not characterised as wetlands or transformed

areas are classified as secondary grassland. The majority of the grassland areas have been

transformed by grazing related impacts and edge effects associated with existing infrastructure

and commercial agriculture which has resulted in alteration of the floral community structure,

resulting in woody encroachment of species such as Seriphium plumosum, erosion and

trampling. As a result, ecological function was found to be moderate to low in most areas,

especially nearer to crop fields and existing railway infrastructure. The dominant grasses at the

time of the assessment were Eragrostis curvula and E. chloromelas; grass species associated

with transformation, which proliferates in disturbed places such as old cultivated lands and along

roadsides. Invasion of alien and invasive species such as Verbena bonariensis, Verbena

tenuisecta and Seriphium plumosum was also encountered within the more disturbed grassland

areas. The project is not deemed a threat to grassland habitat conservation in the area.

Wetland areas:

Several wetland features (see more detail in wetland section) were identified in the study area.

All of these wetlands have been affected to varying degrees by road construction, agriculture,

trampling by livestock and general anthropogenic activities, which have negatively affected the

habitat integrity of these systems. The wetlands are considered to be in a moderately modified

state and a moderate change in ecosystem processes and loss of natural habitats has taken

place but the natural habitat remains predominantly intact. Therefore, although some wetland

areas are more transformed than others, the wetland habitat unit as a whole is considered to be

of increased conservational importance from a floral perspective in relation to the surrounding

terrestrial areas.



4.6.2 Faunal habitat

Various faunal habitat units were identified within the proposed new Rietkuil Private Railway Siding

study area. The major habitat units included transformed grassland habitat which comprised the

majority of the study area, transformed habitat (roads, railways and crop fields) as well as wetland

habitat.

No mammals were directly observed during the field assessment of the study area. Scattered

burrows, most likely those of the Ichneumia albicauda (white-tailed mongoose), provided proof of

mammal presence on the site. Further, the following species Canis mesomelas (Black backed

Jackal), Hystrix africaeaustralis (South African Porcupine), Raphicerus campestris (Steenbok),

Cephalophus natalensis (Red duiker), Leptailurus serval (serval) and Parahyaena brunnea (Brown

Hyaena) were identified by scat and spoor found within the proposed Rietkuil Private Railway Siding

study area. All of the aforementioned species, except for the Parahyaena brunnea (Brown Hyaena),

are considered to be of Least Concern. The Brown Hyaena is considered to be Near Threatened in

terms of the (IUCN, 2013).

Livestock such as goats and cattle were also noted within the proposed new Rietkuil Private Railway

Siding and associated infrastructure study area. Several other mammal species may also reside or

forage within the study area or utilise it as a migratory or movement corridor.

The Brown Hyaena is known to be highly adaptable and often inhabits areas with high levels of

anthropogenic activity. The likelihood of any other threatened mammal species crossing the

proposed new Rietkuil Private Railway Siding and associated infrastructure study area is considered

to be low due to the high levels of anthropogenic activity such as agricultural activity, historic and

current mining activities in the study area.

4.6.3 Avifaunal

Avifauna surveys were conducted across the entire Proposed Rietkuil Private Railway Siding and

associated infrastructure study area and all avifauna species seen or heard during the time of the

field assessment were recorded.

Common species known to utilise the grassland and wetland habitat in the region for either foraging

or breeding and may therefore be either permanently or occasionally present within the study area.

No threatened Red Data List (RDL) avifauna species were identified within the study area during the

site survey. However, the likelihood that some of these RDL avifauna species utilising the study

area for foraging purposes or as a migratory corridor, with specific reference to raptor species, is

considered high. Threatened species with a greater than 60% probability of occurrence of utilising

the proposed Rietkuil Private Railway Siding study area, predominantly for foraging purposes, are

Tyto capensis (African Grass Owl) and Falco peregrinus (Peregrine Falcon). Furthermore,

according to the National Freshwater Ecosystem Priority Areas (NFEPA) database, a depression

(pan) in close proximity to the D 1110 provincial road, is located within a sub-quaternary catchment

that has sightings or breeding areas for threatened Bugeranus carunculatus (Wattled Crane),

Balearica regulorum (Grey Crowned Crane) or Anthropoides paradiseus (Blue Crane).

4.6.4 Reptiles

No reptiles were observed during the Proposed Rietkuil Private Railway Siding and associated

infrastructure field assessment. No RDL reptile species were identified during the field assessment

and due to the high levels of historical and current anthropogenic activities within the study area and

surrounding region, the probability of such species occurring will be very low.



4.6.5 Amphibians

No amphibian species were encountered during the field assessment, partially due to the largely

nocturnal habits of amphibians and due to high levels of habitat transformation within and around the

Proposed Rietkuil Private Railway Siding and associated infrastructure study area. The only

amphibian species listed as being of conservational concern is the Pyxicephalus adspersus (Giant

Bullfrog) in terms of the Mpumalanga State of the Environment Report (2003).

However, no Giant Bullfrogs were identified within or in the vicinity of the study area, although the

study area falls within the distribution range of this species. The Pyxicephalus adspersus is known

to occur within and nearby riparian and wetland zones.

They breed in shallow waters and can occupy temporary floodplains and rapidly drying pool areas.

Giant bullfrogs are also known to travel vast distances and may utilise wetlands as migratory

corridors in favourable conditions. The lack of extensive areas with shallow seasonal pans within the

proposed Rietkuil Private Railway Siding surface area will limit the ability for this species to

successfully breed in the study area, however it is likely to utilise the wetlands in and around the

proposed Rietkuil Private Railway Siding project footprint area as migratory corridors and in search

of food. However, with the implementation of the mitigation measures as set out in this report, it is

considered highly likely that any impact on the migratory corridors or areas with adequate food

availability can be reduced. In terms of conservation important species, there is a low possibility of

encountering RDL and / or threatened amphibian species within the study area.

4.6.6 Invertebrates

The invertebrate assessment conducted was a general assessment with the purpose of identifying

common species and taxa in the study area. The proposed new Rietkuil Private Railway Siding and

associated infrastructure footprint falls within the distribution range noted for Metisella meninx,

however, no populations of this species were identified during the site assessment. M. meninx,

commonly known as the Marsh Sylph, is an invertebrate noted as Vulnerable by the Mpumalanga

State of the Environment Report (Mpumalanga Department of Agriculture, 2003) although it is not

yet listed on the (IUCN, 2013). Its preferred habitat comprises of wetlands where Leersia hexandra

(Marsh grass) is dominant. Despite the fact that L. hexandra was identified within proposed

development footprint of the private railway siding, during the survey, no M. meninx were recorded.

The likelihood of M. meninx occurring is also considered to be low as the wetland areas have been

significantly transformed.

Spiders and scorpions

No threatened spider or scorpion species are listed in the Mpumalanga State of the Environment

Report (2003). Therefore, a record of threatened spiders and scorpions was acquired from the most

recent RDL spider and scorpion data available for South Africa using the South African National

Biodiversity Institute (SANBI) threatened species database (http://www.speciesstatus.sanbi.org).

Various arachnid species, which includes amongst other Trapdoor and Baboon spiders, are

protected or listed as threatened throughout South Africa in terms of the NEM: BA. I

However, no evidence was encountered of endangered or threatened Mygalomorphae arachnids

(Baboon and Trapdoor spiders) and RDL scorpions within the study area. It should, however, be

noted that these species are notoriously difficult to detect and is considered highly unlikely that these

species will occur within the study area due to habitat transformation. No spider or scorpion species

were encountered during the field assessment, and it is unlikely that a diverse arachnid and scorpion

community is present within the proposed development footprint area and surroundings due to the

lack of suitable habitat such as rocky areas. Thus, due to the already highly transformed habitat

http://www.speciesstatus.sanbi.org/



within the study area, the proposed development is unlikely to pose a threat to arachnid and

scorpion conservation in the region, provided that the mitigation measures as set out in this report

are adhered to.

4.7 Surface Water

This site bisects the four quaternary catchments X11C, X11D, B12B and B12C. These quaternary

catchments fall within the Olifants and Inkomati Water Management Areas. Each WMA is divided

into several sub-Water Management Areas (subWMAs). The subWMAs for the study area is the

Upper Olifants subWMA and the Komati West subWMA. The total catchment area of the study area

is 86.87 km2. The area is divided into a number of southward running streams. There are also a

number of pans and dams within the catchment. The quaternary catchments are divided into sub

catchments and described below.

4.7.1 Catchment 1

This catchment forms part of quaternary catchment X11C. The catchment was delineated and the

size of the catchment is 29.04 km2. The catchment consists of a few tributaries that drain into the

Blesbokspruit which is a tributary of the Witkloofspruit. There are a number of small dams within the

catchment. The natural vegetation within the catchment is covered by grasslands and cultivated

land and the land use within the catchment is mainly farming. The catchment is characterised with a

maximum catchment elevation in the north flowing and the lowest elevation in the catchment in the

south.

4.7.2 Catchment 2


size of the catchment is 3.08 km2. There is only one tributary within the catchment that drains to the

Blesbokspruit. Any runoff within the catchment will drain towards the Blebokspruit. There is one pan

(Pan 1) within the catchment. The pan has a surface area of 5000 m2 and a gross storage capacity

of 2500 m3. The natural vegetation within the catchment is covered by grasslands and cultivated

land and the land use within the catchment is mainly farming.

4.7.3 Catchment 3


size of the catchment is 3.89 km2. There is one river within the catchment namely the tributary of the

Blesbokspruit. There is one dam within the catchment with a surface are of 60 000 m2. The natural

vegetation within the catchment is covered by grasslands and cultivated land and the land use within

the catchment is mainly farming.

4.7.4 Catchment 4


size of the catchment is 2.80 km2. The catchment consist of 1 pan (Pan 1) with a surface area of 5

500 m2 and a gross storage capacity of 3000 m

3. There are no major rivers within the catchment.

The catchment seems to be fairly flat. The natural vegetation within the catchment is covered by

grasslands and cultivated land and the land use within the catchment is mainly farming. The

catchment is characterised with a maximum height being experienced in the north.

4.7.5 Catchment 5


size of the catchment is 3.63 km2. There are no major rivers within the catchment. The natural



vegetation within the catchment is covered by grasslands and cultivated land and the land use within

the catchment is mainly farming.

4.7.6 Catchment 6


size of the catchment is 3.56 km2. There are no pan and major rivers in this catchment. All pans

have being mined through. The land use in the catchment is mainly for mining. The catchment is

characterised with a maximum height being experienced in the North West flowing towards the south

east.

4.7.7 Catchment 7


size of the catchment is 2.78 km2. There is one minor tributary within the catchment which flows into

catchment 13 and then into the Klippan. There is only one dam (Dam 5) within the catchment with a

vertical wall height of 13 m; crest length of 100 m and a gross storage capacity of 100 000 m3. The

natural vegetation within the catchment is covered by grasslands and cultivated land and the land

use within the catchment is mainly farming.

4.7.8 Catchment 8

This catchment forms part of quaternary catchment B12C. The catchment was delineated and the

size of the catchment is 1.30 km2. There is one river that’s contributing to the catchment namely the

tributary of the Klippan. There is one dam (Dam 6) within the catchment with a vertical wall height of

2.5 m; crest length of 350 m and a gross storage capacity of 20 000 m3. The natural vegetation

within the catchment is covered by grasslands and cultivated land and the land use within the

catchment is mainly farming.

4.7.9 Catchment 9


size of the catchment is 1.33 km2. There is an unknown tributary that’s contributing to the

catchment. There are no dams and pans within the catchment. The natural vegetation within the

catchment is covered by grasslands and cultivated land and the land use within the catchment is

mainly farming.

4.7.10 Catchment 10

This catchment forms part of quaternary catchments B12B and B12C. This catchment forms part of

quaternary catchment B12C. The catchment was delineated and the size of the catchment is

1.13 km2. There are no major rivers and also no dams and pans within the catchment. The slope of

the catchment seems to be fairly flat. The natural vegetation within the catchment is covered by

grasslands and cultivated land and the land use within the catchment is mainly farming.

4.7.11 Catchment 11

This catchment forms part of quaternary catchments B12B and B12C. The catchment was

delineated and the size of the catchment is 9.56 km2. Runoff within the catchment flows to the

Bosmanspruit, which is a tributary of the Klein Olifants River. There are no dams and pans within

the catchment. The natural vegetation within the catchment is covered by grasslands at some

places and the land use within the catchment is farming and mining. Run-off within the catchment

flows away from the rail siding towards the Bosmanspruit located to the north west of the catchment.



4.7.12 Catchment 12


size of the catchment is 0.99 km2. There are no major rivers within the catchment. There is one

dam (Dam 7) within the catchment with a vertical wall height of 4.5 m and a gross storage capacity

of 65 000 m3. The land use within the catchment is mainly mining. The topography of the catchment

is fairly flat. Most of the run-off in the catchment flows towards the pan.

4.7.13 Catchment 13


size of the catchment is 20.50 km2. There is one river that’s contributing to the catchment namely

the tributary of the Klippan. There is one pan on the upstream of catchment with a surface area of

100 000 m2. The natural vegetation within the catchment is covered by grasslands and cultivated

land and the land use within the catchment is mainly farming. Elevations vary between 1,760

mamsl, in the north of the catchments and 1,720 mamsl in the south of the catchments. Most of the

run-off in the catchment flows towards the Klippan.

4.7.14 Catchment 14

This catchment forms part of quaternary catchment B12B. The catchment was delineated and the

size of the catchment is 2.84 km2. There are no major rivers and pans within the catchment. The

catchment is characterised with a maximum level experienced in the north east and drains towards

catchment 12. The natural vegetation within the catchment is covered by grasslands at some places

and the land use within the catchment is mainly mining.

4.7.15 Catchment 15

This catchment forms part of quaternary catchments X11C and B41A. The catchment was

delineated and the size of the catchment is 0.44 km2. There are no major rivers and pans within the

catchment. The catchment is characterised with a maximum level experienced in the north and

drains towards the south. The natural vegetation within the catchment is covered by grasslands and

cultivated land and the land use within the catchment is mainly farming.

4.7.16 Catchment 16

This catchment forms part of quaternary catchments B12C. The catchment was delineated and the

size of the catchment is 8.49 km2. Runoff within the catchment flows to a Tributary of the

Bosmanspruit, which is a tributary of the Klein Olifantsriver. There are no dams or pans within the

catchment which contains a portion of the railway loop. The natural vegetation within the catchment

is covered by grasslands at some places and the land use within the catchment is farming and

mining. Run-off within the catchment flows away from the rail siding towards the Bosmanspruit

located to the north west of the catchment.





467209

Figure 4-10: Catchment map of the proposed new Rietkuil Private Railway Siding and associated infrastructure study area



4.7.17 Surface Water Hydrology

The groundwater flow has been described as mimicking the topography and flowing towards

surface drainage features, with a hydraulic gradient of approximately 0.02 (a 20m fall for every

1000m) (Golder Associates, 2012). The regional flow patterns are likely to have been disturbed by

mine pits surrounding the study area. A site reconnaissance visit to the study area shows

groundwater seepages from the margins of the rolling hills (Figure 4-11). The seepage decants to

shallow natural surface depressions or “pans” that are underlain by clays.



Project No.

467209

Figure 4-11: Seepage from Shallow Groundwater

4.7.18 Mean Annual Runoff

Catchments areas were delineated for various points of interest and peak flows at their respective

outlets were calculated. The catchments 1 to 10 and 13 to 15 were used as part of the description

of the haul road where streams cross the road. Catchment 11 describes the catchment where the

railway siding will be situated. Catchment 12 describes the catchment where the PCD will be

situated. From the catchment layout shown in Figure 4-10, the catchments were delineated to

calculate the peak flows. The tables below, Table 4-5 and Table 4-6, provide a summary of the

catchment hydrology and peak flows for the catchments of the project area.



Table 4-5: Summary of Catchment Hydrology for the Project Area

Catchment Name Net area (km

2)

Hydraulic Length (m) Elevation (m) Slope

(m/m) 10 per cent 85 per cent

Catchment 1 29.04 11989.65 1742.75 1820.00 0.006

Catchment 2 3.08 4788.38 1710.00 1776.71 0.014

Catchment 3 3.89 5013.16 1755.92 1802.30 0.009

Catchment 4 2.80 3243.24 1745.00 1795.29 0.016

Catchment 5 3.63 2982.54 1754.98 1774.10 0.006

Catchment 6 3.56 4040.55 1759.50 1765.36 0.001

Catchment 7 2.78 2399.99 1705.42 1755.00 0.021

Catchment 8 1.30 2379.86 1715.00 1733.08 0.008

Catchment 9 1.33 2295.68 1705.89 1720.00 0.006

Catchment 10 1.13 2134.51 1710.00 1720.43 0.005

Catchment 11 9.56 5381.01 1637.64 1699.37 0.011

Catchment 12 0.99 1361.70 1680.00 1687.83 0.006

Catchment 13 20.50 2747.16 1683.88 1728.16 0.016

Catchment 14 2.84 3727.27 1681.42 1710.00 0.008

Catchment 15 0.44 961.98 1793.84 1795.00 0.001

Catchment 16 8.49 4003.66 1682.26 1700.27 0.004

Table 4-6: Summary of Peak Flows (m3/s) for the Project Area

Catchment Name Area (km2)

Peak discharge (m3/s) for different recurrence intervals

2 5 10 20 50 100 200

Catchment 1 29.04 7.64 11.09 14.30 18.42 26.88 36.35 48.39

Catchment 2 3.08 1.83 2.66 3.43 4.42 6.46 8.73 11.62

Catchment 3 3.89 1.98 2.88 3.71 4.78 6.98 9.44 12.57

Catchment 4 2.8 2.04 2.96 3.82 4.92 7.18 9.71 12.92

Catchment 5 2.24 3.26 4.20 5.41 7.89 10.67 14.21 40.79

Catchment 6 3.56 1.23 1.78 2.30 2.96 4.32 5.84 7.77

Catchment 7 2.78 2.52 3.66 4.72 6.08 8.87 12.00 15.98

Catchment 8 1.3 0.94 1.37 1.77 2.28 3.32 4.50 5.98

Catchment 9 1.33 0.94 1.36 1.75 2.26 3.29 4.45 5.93

Catchment 10 1.13 0.78 1.14 1.46 1.89 2.75 3.72 4.95

Catchment 11 9.56 4.82 6.99 9.02 11.62 16.95 22.93 30.52

Catchment 12 0.99 0.89 1.29 1.66 2.14 3.12 4.22 5.62

Catchment 13 20.5 14.73 21.39 27.57 35.53 51.84 70.11 93.33

Catchment 14 2.84 1.65 2.39 3.08 3.97 5.80 7.84 10.43

Catchment 15 0.44 0.32 0.46 0.60 0.77 1.12 1.52 2.02

Catchment 16 8.49 3.90 5.67 7.31 9.42 13.74 18.58 24.74



4.7.19 Floodlines

A floodline assessment was undertaken after delineating the catchment in which the proposed new

Rietkuil Private Railway Siding and associated infrastructure will be situated. The proposed railway

siding will be situated in Catchment 11. As indicated in Section 4.7 the catchment was delineated

and the size of the catchment is 9.56 km2 with run-off flowing towards the Bosmanspruit which is

situated approximately 1.2 km north-west of the proposed railway siding and PCD.

The catchment delineation was done by following 5 m contours in order to determine what impact

the 1:50 and 1:100 year floodlines would have on the proposed new Rietkuil Private Railway

Siding, the coal loading/stockpile area and PCD. The maximum height of Catchment 11 is

experienced along the southern section of the delineated catchment. The railway siding is situated

along the sourthern section of the delineated catchment. From The simulation shows that the

proposed private railway siding will be located outside of the 1:50 and 1:100 year floodlines.

The closest point to the floodlines is approximately 1.2 km away from the proposed new

Rietkuil Private Railway Siding and associated infrastructure. Therefore it is evident that

the 1:50 and 1:100 year flood will have no impact on the proposed private railway siding.



RIETKUIL PRIVATE RAILWAY SIDING AND ASSOCIATED INFRASTRUCTURE

Project No. 467209

Figure 4-12: Floodline extent for the proposed new Rietkuil Private Railway Siding and associated infrastructure



4.7.20 Wetlands

The Mpumalanga Biobase (which is also contained forming part of SANBI’s BGIS database) layer

was consulted to ascertain the location of wetlands and pans mapped by the Mpumalanga Parks

Board. It was established that a number of wetlands have been identified in and around the

proposed development and Figure 4-13 provides an illustration of possible wetlands in and around

the proposed development footprint. Figure 4-14 and Figure 4-15 provides an illustration of the

possible wetlands located in and around the proposed private railway siding and D1770. According

to the Classification System compiled by (Ollis, 2013), the wetland systems associated with the

study area comprise four wetland types, namely hillslope seep, channelled valley bottom,

unchannelled valley bottom and depression. The wetland functions and service provision of the

wetland features was assessed utilising the WET-Ecoservices (Kotze, et al., 2008) method and

concluded that the wetlands provide moderate level of eco-services and functionality.

In terms of the Present State of a Wetland (PES) scores it was determined that all the wetlands can

be considered Category C wetlands (moderately modified; a moderate change in ecosystem

processes and loss of natural habitats has taken place but the natural habitat remains predominantly

intact). The PES categories/scores for wetlands features are obtained by using the formula3 as

provided by the Wet-Health methodology.

The method used for the Ecological Importance and Sensitivity (EIS) determination was adapted

from the method as provided by DWAF (1999) for floodplains. The method takes into consideration

PES scores obtained for WET-Health as well as function and service provision to enable the

assessor to determine the most representative EIS category for the wetland feature or group being

assessed. The EIS method was applied to all four wetlands in order to ascertain their sensitivity to

flow and habitat modifications. After consideration of the wetland function and WET-Health

assessments, as well as the outcome of the EIS assessment, the Recommended Ecological Class

(REC) for the wetlands is considered to be a Category B for wetlands A, B, D, E and F and Category

C for the remainder of the wetlands.

3 ((Hydrology score) x 3 + (geomorphology score) x2 + (vegetation score) x 2))/ 7 = PES



RIETKUIL PRIVATE RAILWAY SIDING AND ASSOCIATED INFRASTRUCTURE Project No. 467209

Figure 4-13: Illustration of the wetlands in and around the proposed new Rietkuil Private Railway Siding and associated infrastructure project area




Figure 4-14: Wetland types associated with the proposed new Rietkuil Private Railway Siding and associated infrastructure




Figure 4-15: Wetland Types Associated with the upgrading of the D1770



4.8 Groundwater

Previous studies identified four water bearing units that may or may not be connected: upper

shallow, fractured, aquifers associated with coal seams and aquifers associated with dolerite

intrusions. The weathered Karoo aquifer is described as consisting of in situ weathered or

transported material, extending down to depths of 5m to 15m below surface. The fractured

aquifers, coal seam aquifers and those associated with dolerite intrusions consist of deeper

Karoo strata, with water strikes associated with bedding plane fractures, faults and contact

zones with dolerite dykes and sills (Golder Associates, 2012).

The measured groundwater levels vary between 4m and 8m below ground level (Wates,

1996) and (Ferret Mining and Environmental Services, 2004). Twelve boreholes drilled by

Golder in 2012 showed groundwater levels ranging from 3.81mbgl to 46.6mbgl. No major

water strikes were encountered.

Groundwater is mainly abstracted by means of boreholes and springs for domestic supplies

and livestock watering. The yields of the local aquifers are incapable of supporting intensive

irrigation. According to the Department of Water Affairs classification system (1998) the

aquifers around the proposed new Rietkuil Private Railway Siding project area can be

classified as Minor Aquifer systems.

Groundwater recharge is estimated at 1% - 3% of the Mean Annual Precipitation (MAP =

685mm/yr), translating to 7mm - 21mm per year. Groundwater contribution to surface water

flows is reduced by evapotranspiration and abstraction from the shallow weathered aquifers.

Only two functioning boreholes were identified during a limited hydrocensus around the

project area. The two boreholes, Twee BH1 and Twee BH2 are used for domestic purposes

and for limited livestock waterin and situated north of the site.

Table 4-7: Tweefontein boreholes sampled

Hole ID Locality pH EC (mS/m)

Twee BH1 Tweefontein 7.2 46.8

Twee BH2 Tweefontein 7.4 66.0

The results returned show groundwater electrical conductivities of 57.2 and 77.9mS/m for

BH1 and BH2, respectively. The groundwater is alkaline with pH measured at 8.1 and 8.4,

respectively. The laboratory results were compared against South African Drinking Water

Quality Standards for Chronic health (South African National Standards (SANS) 241:2011).

Major cation, anion and metal concentrations in the groundwater fall within acceptable

drinking water quality standards.

The laboratory results were compared against South African Drinking Water Quality

Standards for Chronic health (SANS 241:2011). Major cation, anion and metal

concentrations in the groundwater fall within acceptable drinking water quality standards

Table 4-8.

.



Table 4-8: Groundwater chemistry laboratory results

Sample ID pH EC

(mS/m) TDS

(mg/l) Ca

(mg/l) Mg

(mg/l) Na

(mg/l) K

(mg/l)

Total Alkalinity as CaCO3

Ammonia as N

(mg/l)

Cl (mg/l)

SO4 (mg/l)

NO3-N (mg/l)

F (mg/l)

Co (mg/l)

Cr (mg/l)

Cu (mg/l)

Fe (mg/l)

Mn (mg/l)

Ni (mg/l)

V (mg/l)

Zn (mg/l)

As (mg/l)

Pb (mg/l)

Twee BH1 8.1 57.2 360 6.1 3.7 100 20 245 <0.10 25 19.5 0.1 0.8 0.001 0.005 0.02 0.16 0.01 0.003 0.01 0.01 0.005 <0.001

Twee BH2 8.4 77.9 424 19.7 10.4 125 22 299 <0.10 37 8.4 0.5 1.3 0.001 0.005 0.03 0.09 0.03 <0.003 0.02 0.008 0.004 0.01

Limits (Chronic Health)

5.0-9.7 <170 <1200 <150 <70 <200 <50

<1.5 <300 <500 <11 <1.5 <0.5 <0.05 <2 <2 <0.5 <0.07 <0.2 <5 <0.01 <0.01



Groundwater quality may be impacted by the oxidation of sulphides in the coal and may

result in acid leachate percolating through the topsoil and into the underlying aquifers.

The acid drainage resulting from the oxidation of sulphides in the coal may infiltrate

downwards into the shallow groundwater system, subsequently seeping out and flowing

into surface water courses and water bodies (tributaries and pans). The use of haulage

trucks and machinery powered by hydrocarbon fuels presents the risk of leaks of fuels

and oils finding their way into the shallow groundwater system. .

4.9 Air quality

Dust fallout results were obtained from the neighbouring Arnot Coal Mine monitoring network.

Since the railway siding will be centrally located from the Arnot Coal Mine’s activities it was

deemed necessary to understand a baseline representation (before Exxaro activities) of dust

fallout in the area. The dust fallout results were generally below the South African dust fallout

standards. Dust fallout results are higher at the centre of Arnot Coal Mine’s operations, which

is 1.6 km south-southeast from the proposed new Rietkuil Private Railway Siding and

associated infrastructure operations. The residential area standard of 600 mg/m2/day and the

non-residential standard of 1,200 mg/m2/day are exceeded at these four locations which

suggest dust generation is higher in this central area (i.e. plant area) when compared to the

other monitoring points south and north of the facility.

The project area and surrounding land can be described as being rural and mainly used for

mining operations and farming land. The town of Rietkuil is located 4.5 km to the south-

southwest of the project site. The following sources of air emissions have been identified in

the area:

Mining activities in the region;

Road network;

Windblown dust (windblown dust especially during the dry season);

Vehicle tailpipe emissions.

4.9.1 Mining activities in the region

There is one mine in close proximity to proposed new Rietkuil Private Railway Siding and

associated infrastructure, namely Arnot Coal Mine. Activities such as crushing, hauling,

activities at the plant and materials handling all contribute to pollutants in the atmosphere.

The main pollutant of concern is particulate matter in the form of inhalable and nuisance dust

as a result of dust fallout.

4.9.2 Road network

Particulate emissions from roadways depend on the type (paved or unpaved) of road and the

number of vehicles using the road. Windblown dust resulting from the erosion of bare ground

depends on the velocity of the wind, the size of the exposed area and moisture and silt

content of such areas. Areas that receive high amounts of rainfall will experience lower levels

of fugitive dust being released into the air than areas that experience low amounts of rainfall

because the rainfall acts as a natural dust suppressant due to the higher moisture content of

the road surface.

The majority of the road network in the surrounding area consists of paved roads. The

access road leading to the proposed operations is currently unpaved. Entrainment of dust by

vehicles may increase dust levels in the atmosphere. However, it is proposed to upgrade the

unpaved road to a paved road leading to the operations, which will result in a reduction of the



current dust levels in the atmosphere. It will be used as an access road to the private railway

siding and for access to the nearby farms.

Fugitive dust emissions are expected to be low as the rainy season is from October to March

and the wind speeds are generally low during the year. Fugitive dust from the unpaved road

network in the area is expected to be low over 24 hours, as the road is seldom used.

Management measures such as wet suppression will also be implemented to manage dust

levels.

4.9.3 Windblown dust

There are a few sources of windblown dust in the area, such as Arnot Coal Mine’s storage

stockpiles, farming activities and bare ground. The coal material deposited at the storage

area, will erode away the initial layer of dust on the coal that is erodible and as coal is

dumped this will prevent the erosion from the layers below. The particle sizes of the coal are

too large to be transported by wind. Stacking and reclaiming of the coal stockpiles implies

that contributions to the dust load during these activities vary with the size of the affected area

and the activities that occur during stacking and reclaiming operations. The coal at the

storage facility will also have high moisture contents in the range from 2.8-12%. These high

moisture contents will have a major role in managing fugitive dust emissions.

4.9.4 Vehicle tailpipe emissions

Vehicle tailpipe emissions depend on the number of vehicles and depending on the age and

efficiency of the vehicle, the tailpipe emissions can contribute heavily or minimally to air

pollution. Vehicle emissions can be classified into two groups, namely, primary and secondary

pollutants. Pollutants such as carbon monoxide (CO), carbon dioxide (CO2), sulphur dioxide

(SO2), oxides of nitrogen (NOx), and particulates are generally released into the atmosphere

depending on the type of fuel that is used. These pollutants are termed primary pollutants.

Secondary pollutants exist only because of the chemical reactions that take place in the

atmosphere. Pollutants formed during this process include nitrogen dioxide (NO2), sulphates

and nitrates. Vehicle tailpipe emissions are expected to be relatively low in the area over a 24

hour period; however it may be elevated during specific times of the day, i.e. during the

morning and evening peak vehicle travel periods.

4.10 Noise

The purpose of the environmental noise study was to determine the prevailing ambient levels

in the vicinity of proposed new Rietkuil Private Railway Siding and associated infrastructure

along the existing railway line and along the haul road from the proposed Belfast Coal Mine to

the proposed siding. The proposed new Rietkuil Private Railway Siding and associated

infrastructure will be situated south of the Arnot Coal Mine’s mining area and the main east

west railway line. There is an existing coal loading facility (railway loop with a silo and a coal

holding area where coal is loaded with front-end loaders) in the vicinity of the proposed new

Rietkuil Private Railway Siding and associated infrastructure. There are gravel roads from the

proposed Belfast Coal Mine to the main feeder roads which will be upgraded to transport the

coal to the holding facility. This gravel road is currently used by farmers and heavy-duty

vehicles. The loading of the train will take place when there is a train available and coal will

be transported along the existing infrastructure.

The topography of the study area is slightly undulated ground with agricultural land covered

with patches of grass and shrubs and scattered trees. The study area can be classified as

medium to hard ground conditions. Noise sources exist in the vicinity of the proposed new



Rietkuil Private Railway Siding study area which are point sources which have an influence

on the prevailing ambient noise levels. The line sources such as the conveyor, railway line

and road network add to the prevailing ambient noise level on a continuous to a finite basis.

The prevailing ambient noise level is made up out of seasonal farming activities, traffic,

distant traffic noise, plant noise, wind, birds, animals and insects.

The levels of noise emissions are a function of:

The distance the receptors are from the noise sources;

The intervening topography and structures that may shield the noise from the receiver;

Meteorological conditions such as wind speed, temperature and the season.

The difference between the actual noise and the ambient noise level and the time of the day

and the duration of the activity, will determine how people will respond to sound and what the

noise impact will be. In order to evaluate such, there must be uniform guidelines to evaluate

each scenario. The SANS 10103 of 2008 has laid down sound pressure levels for specific

districts and has provided the following continuous noise levels per district as illustrated in

Table 4-9.

Table 4-9: SANS 10103 of 2008 Sound Pressure Levels for Specific Districts

Type of district Recommended noise levels for different districts. Type

of district

Equivalent continuous rating level LReq.T for ambient noise - dBA

Outdoors Indoors, with open windows

Day-night

Daytime

Night-time

Day-night

Daytime

Night-time

a) Rural districts 45 45 35 35 35 25

b) Suburban districts with

little road traffic 50 50 40 40 40 30

c) Urban districts 55 55 45 45 45 35

d) Urban districts with some

workshops, with business

premises and with main

roads

60 60 50 50 50 40

e) Central business district 65 65 55 55 55 45

f) Industrial districts 70 70 60 60 60 50

The reference time intervals can be specified to cover typical human activities and variations

in the operation of noise sources and are for daytime between 6h00 to 22h00 and for night

time between 22h00 and 6h00. These noise sources are illustrated in Figure 4-16.



RIETKUIL PRIVATE RAILWAY SIDING AND ASSOCIATED INFRASTRUCTURE Project No.

467209

Figure 4-16: Noise sources in the vicinity of the proposed new Rietkuil Private Railway Siding and associated infrastructure site



The Noise Control Regulations (NCR) GN154 as promulgated in Government Gazette No.

13717 dated 10 January 1992 say that “No person shall make, produce or cause a disturbing

noise, allow it to be made, produced or caused by any person, animal, device or apparatus or

any combination thereof.” A disturbing noise means a noise level that exceeds the prevailing

ambient noise level measured continuously at the same measuring point by 7.0dBA or more.

The noise sensitive areas A to M contained in the table below are in the vicinity of the haul

route and there are no noise sensitive areas (NSAs) in a radius of 1 300m from the siding.

These NSAs are illustrated in Figure 4-17.

Table 4-10: Distance in meters between proposed Siding, Haul Road and the Noise Sensitive Areas

Noise sensitive area

Distance to the siding -

m

Other noise

sources in the vicinity of the NSA

Distance to the haul road - m

Other noise sources in

the vicinity of the noise sensitive

area

Distance between the NSAs and the

pollution control

dam – m


proposed train loop

- m

A 1 385 Mine, railway line, existing railway loop and loading facilities.

1 357 Railway line, existing loading activities.

1 385 4 169

B 3 790 Power station, existing road, railway line.

3 166 Railway line, existing road.

3 790 4 980

C 5 105 Railway line, existing road, power station.


5 105 3 729

D 5 900 Conveyor, mine ventilation shaft, railway line.

650 Railway line, existing road.

5 900 3 167

E 1 810 Mine, existing railway loop, railway line, conveyor.

1 841 Railway line, mine. .

1 810 2 124

F 7 350 Existing road, ventilation shaft, conveyor


7 350 4 513

G N/A 490 Railway line, existing road.

N/A N/A

H N/A 545 Railway line, existing road.

N/A N/A

I N/A 177 Railway line, existing N4 Road.

N/A N/A

J N/A 410 Existing gravel road, Genet mine.

N/A N/A



Noise sensitive area

Distance to the siding -

m

Other noise

sources in the vicinity of the NSA

Distance to the haul road - m

Other noise sources in

the vicinity of the noise sensitive

area


pollution control

dam – m


proposed train loop

- m

K N/A 56 Existing gravel road, Genet mine.

N/A N/A

L N/A 754 Existing gravel road, Genet mine.

N/A N/A

M N/A 1 400 Existing gravel road.

N/A N/A

*N/A – Distance between source and receptor too far to have a noise impact.




INFRASTRUCTURE

Project No.

467209

Figure 4-17: Noise sensitive areas in the vicinity of the proposed new Rietkuil Private Railway Siding and associated infrastructure.



The prevailing ambient noise levels in the different areas within the study area demonstrated

that there is already a disturbance from non-residential activities such as existing train

activities, ventilation shaft noise, conveyor activities, hauling activities and traffic to which the

people living in the vicinity of these point and line sources are exposed to. There is at times

an increase of the prevailing ambient noise levels due to traffic which make use of the gravel

road and along the railway line. During seasonal agricultural activities there will be an

increase in the prevailing ambient noise level in and around the noise sensitive areas near

crops. Table 4-10 illustrates the distance in meters between proposed siding, haul road and

the noise sensitive areas. The noise level along a section of the N4 road is normal for this

type of road with a constant flow of traffic during the day and night periods. The existing

feeder roads are existing gravel roads which will be upgraded and tarred whereas the other

feeder roads are already tarred surfaces. There will be an increase in the traffic volume along

these roads which will create a finite type increase after which the prevailing ambient noise

level will be maintained.

The noise at the proposed new Rietkuil Private Railway Siding and associated infrastructure

can however be controlled by means of approved acoustic screening measures, state of the

art equipment, proper noise management principles and compliance to the Local Noise

Control Regulations, and the International Finance Corporation’s Environmental Health and

Safety Guidelines.

4.10.1 Existing Road Network

The existing external road that might be directly affected by new traffic generated is listed in

Table 4-11 below.

Table 4-11: Overview of the Existing Road Network and Jurisdiction

Road Link

Jurisdiction Class

of road

Function of the Road

Road Surfacing Cross Section

(Typical Width of the road)

N4 SANRAL C1 The road is an east-west, Provincial Class 1 national road. The N4 Road connects Komatipoort border post with Lobatsi border post.

The road is paved and the surface condition is good*.

Dual carriageway (4 lanes: two lanes per direction) with median and turning lanes at intersections.

D1110 Mpumalanga Department of Roads and Transport (MDRT)

R2 The road is a north-south, Provincial Class 2 rural road with a collector-distributor function. The D1110 Road connects the N4 Road with the D1770 Road.

The road is a gravel road and the surface condition is fairly adequate**.

Single carriageway (2 lanes: one lane per direction)

D1770 MDRT R2 The road is an east-west, Provincial Class 2 rural road with a collector-distributor function. The D1770 Road connects the D1110 Road with the N4 Road.

The road is a gravel road and the surface condition is fairly adequate**.

Single carriageway (2 lanes: one lane per direction)



Road Link

Jurisdiction Class

of road

Function of the Road

Road Surfacing Cross Section

(Typical Width of the road)

D1555 MDRT R2 The road is an east-west, Provincial Class 2 rural road with a collector-distributor function. The D1555 Road connects the R104 Road with the D383 Road.

The road is a paved road and the surface condition is good*.

Single carriageway (2 lanes: one lane per direction), with gravel shoulders

D383 MDRT R2 The road is a north-south, Provincial Class 2 rural road with a collector-distributor function. The D383 Road connects the P15-1 Road with the N4 Road.



P15-1 MDRT R2

The road is a north-south, Provincial Class 2 rural road with a collector-distributor function. The P15-1 Road connects the N4 Road with the D383 Road.



“Good” = road maintenance standard, include surface of road, sight distance, road signs, road markings, driver experience, etc.

“Fairly adequate” = require road maintenance, improvement of road markings, road signs, surfacing, driver experience less than freeway, etc.

4.10.2 Existing Rail Network

Transnet has a major rail line located north of the N4 Road. This railway line is part of the

national major rail network between Komatipoort and Gauteng. The main focus of this

existing railway line is on transporting main commodities like coal, iron and passengers. The

railway line feeds large volumes of bulk traffic into and through Mpumalanga area. The

nearest railway station to the proposed Belfast Coal Mine is Wonderfontein and Rietkuil

Stations.

4.10.3 Area of Influence

As mentioned in Section 4.10.1 above, the following external link roads might be directly

affected by new traffic generated by the proposed Belfast Coal Mine development:

N4 Road;

D1110 Road;

D1770 Road;

P15-1 Road;

D383 Road;

D1555.

The area of influence area for this study was determined by the locality of the site and based

on the proposed Belfast Coal Mine transport needs (origins and destination).

The following intersections have been investigated as part of the Traffic Impact Assessment:



Intersection 1: N4 Road / D1110 Road;

Intersection 2: D1110 Road / D1770 Road;

Intersection 3: N4 Road / P15-1 Road;

Intersection 4: D383 Road / P15-1 Road;

Intersection 5: D383 Road / D1555 Road.

4.10.4 Status quo traffic volumes

As part of the traffic impact assessment a traffic survey comprising traffic counts was carried

out. The traffic counts were carried out between 06:00 in the morning and 18:00 in the

afternoon. Classified counts at the above intersections included light vehicles, heavy vehicles

(2-4 axels) and very heavy vehicles (more than 5 axels). The AM and PM peak hour was

determine based on the highest traffic volumes registered during the morning and afternoon

periods respectively.

The influence area for this study was determined by the locality of the proposed new Rietkuil

Private Railway Siding and associated infrastructure and based on the proposed Belfast Coal

Mine transport needs (origins and destination).

The AM peak hour on the D1110 Road was found to be from 07:15 to 08:15 and the PM peak

hour was recorded at 15:15 to 16:15 with a total of 32 vph both directions (light + heavy) with

28 vph both directions respectively. Approximately 48% of the counted AM and PM peak

hour traffic volumes are heavy vehicles.

Comprehensive Traffic Observations (CTO) Data from SANRAL from counting stations “1125

Wonderfontein R33 (MS18)”, “1126 Wonderfontein East (MS19)” and “1828 R33 Belfast”

were used to determine traffic volumes on the R33, (R33) Carolina Road and D383 Road.

The following data were obtained from station “1125 Wonderfontein R33 (MS18)”:

Total number of vehicles = 226 831 (112 816 to Wonderfontein, 114 015 to Carolina)

Average daily traffic (ADT) = 2 652;

Average daily truck traffic (ADTT) = 447;

Percentage trucks = 16.9% (16% night traffic).

The following data were obtained from station “1126 Wonderfontein East (MS19)”:

Total number of vehicles = 318 177 (163 8482 to Wonderfontein, 154 695 to Hendrina);

ADT = 888;

ADTT = 370;

Percentage trucks = 41.7% (17.6% night traffic).

4.11 Socio-economic

The Nkangala District Municipality is one of the three District Municipalities in Mpumalanga

Province. The headquarters of Nkangala District Municipality are in Middelburg. The District is

composed of six Local Municipalities: namely; Victor Khanye Local Municipality, Emalahleni

Local Municipality, Steve Tshwete Local Municipality, Emakhazeni Local Municipality,

Thembisile Hani Local Municipality, and Dr J S Moroka Local Municipality. The area of the

District covers a total area of approximately 16 892 km2 (Nkangala District Municipality,

2011). The two affected Local Municipalities are Steve Tshwete and Emakhazeni.

Table 4-12: Nearest Towns to the Proposed Development

Town Distance Direction



(km)

Rietkuil 3.8 km South of the coal stockpile and private railway siding

Belfast 17 km North-east of the D 1770 and D 1110 road upgrades

Pullenshope 20 km West of the coal stockpile and private railway siding

Carolina 29 km South-east of the D 1770 and D 1110 road upgrades

Bankfontein 30 km North-west of the coal stockpile and private railway siding

Machadodorp 34 km North-east of the D 1770 and D 1110 road upgrades

Middleburg 34 km North-west of the coal stockpile and private railway siding

Emalahleni 52 km West of the coal stockpile and private railway siding

4.11.1 Demographic and key economic indicators of Steve Tshwete Local Municipality

The Steve Tshwete Municipality is a category B municipality situated in the Nkangala District

of the Mpumalanga Province. It is positioned some 150 km east of Pretoria on the way to

Mbombela, and covers a geographic area of 3993 km². The N4 runs east/west through the

municipal space, whilst the N11 traverses the area in a north/south direction. Some six other

provincial roads link Middelburg to other towns in Mpumalanga (Steve Tshwete Local

Muicipality, 2012).

There are two nodal points or note: Middelburg/Mhluzi that is the main commercial and

administrative centre, and the much smaller Hendrina/Kwazamokuhle near the south/east

boundary (Steve Tshwete Local Municipality, 2008).

The IDP of Steve Tshwete Local Municipality indicates a growth of 27.8% over the last 6 year

period with an average growth of 4.63% per year. The total population size is approximately

182 507 people according to the community survey done in 2007. About 64.3% of the

population is below 35 years of age (Steve Tshwete Local Muicipality, 2012).

Education

The level of education for the population in the Steve Tshwete Local Municipality is reflected

in Table 4-13 (Steve Tshwete Local Muicipality, 2012).

Table 4-13: Level of Education of Household Heads

Level of Education Number Percentage

No Schooling 5 542 11 %

Grade 0 352 1 %

Grade 1-2 1530 3 %

Grade 3-7 11 313 23 %

Grade 8-11 15 586 31 %

Grade 12 7 607 15 %

Diploma/ Certificate without Grade 12 3 386 7 %

Diploma/ Certificate with Grade 12 2 840 6 %

Post Graduate Diploma / BTech / Bachelor's Degree And Higher 1 986 4 %

Only 10 % of the total Steve Tshwete Local Municipality population has a tertiary education,

while 11 % have attended no schooling at all.

Employment



Table 4-14 illustrates the employment status of households in the Steve Tshwete Local

Municipality in Mpumalanga (Steve Tshwete Local Muicipality, 2012).

Table 4-14: Employment Status of Household Heads (HH)

Employment Status No. HH Heads Percentage

Employed 37 777 75 %

Unemployed 5 639 11 %

Not Economically Active 7 033 14 %

A large percentage of the Steve Tshwete Local Municipality is currently employed, with 75 %

of the total household heads economically active. About 25 % of the household heads are

currently not employed or economically active.

Energy

In a study conducted on rural areas an indication is given that on average only 27% of the

households in the rural areas of the Steve Tshwete Local Municipality have access to

electricity. This leaves a massive 73% of the households having to rely on other sources of

energy such as wood, coal, gas or paraffin thereby contributing significantly to air pollution in

Mpumalanga (Steve Tshwete Local Muicipality, 2012).

4.11.2 Demographic and key economic indicators of Emakhazeni Local Municipality

The Emakhazeni Local Municipality is situated between the two major towns in Mpumalanga

Province, namely Middelburg and Nelspruit and is connected to both these centres via the N4

Freeway. The N4 and Road P81-1 provide links from Gauteng to the major tourism centres in

Mpumalanga, specifically the Kruger National Park to the east and Pilgrim’s Rest, Graskop,

Lydenburg and Hoedspruit to the northeast (Emakhazeni Local Municipality , 2012).

According to the municipal IDP the population of Emakhazeni Local Municipality from the

census count of 2001 was 43,007 persons, and it declined to 32,840 persons based on the

estimates from the 2007 community survey. This implies an annual growth rate of -4.5%

between the 6 year period (Emakhazeni Local Municipality , 2012).

The population of Emakhazeni Local Municipality was mostly Black based on the estimate

from the 2007 Community Survey. Approximately 87 % of the population is Black, 12 % White

and consists of less than 10 % of Asians and Coloureds.

Education

About 15% of males and 27% of females in 2007 has no schooling in the Emakhazeni Local

Municipality, which indicate favourable improvements in educational attainment over a period

of 6 years.

Employment

The overall unemployment rate in Emakhazeni Local Municipality is 30 % in 2007. About 65

% of males and 37 % females were employed in 2007 (Emakhazeni Local Municipality ,

2012).

Energy

During 2007, electricity use for heating and cooking was observed in 58% households.

Electricity use among households was not uniform, meaning even households with electricity

do not choose to use it for all their energy needs. Although electricity is the most dominant



source of energy, it is preferred more for cooking and less for heating. The other sources of

cooking and heating energy are paraffin and coal, the use of which was high in 2007

(Emakhazeni Local Municipality , 2012).

The proposed activities will take place in the Steve Tshwete and eMakhazeni Local

Municipalities, situated in the Nkangala District Municipality of the Mpumalanga Province.

The District covers a total area of approximately 16,892 square kilometres (Nkangala District

Municipality, 2011).

The Steve Tshwete Municipality is a category B municipality situated in the Nkangala District

of the Mpumalanga Province. It is positioned some 150km east of Pretoria on the way to

Mbombela, and covers a geographic area of 3993km². The N4 runs east/west through the

municipal space, whilst the N11 traverses the area in a north/south direction. Six provincial

roads link Middelburg to other towns in Mpumalanga (Steve Tshwete Local Muicipality, 2012).

The IDP of Steve Tshwete Local Municipality indicates a growth of 27.8% over the last 6 year

period with an average growth of 4.63% per year. The total population size is approximately

182 507 people according to the community survey done in 2007. About 64.3% of the

population is below 35 years of age (Steve Tshwete Local Muicipality, 2012).

The Emakhazeni Local Municipality is situated between the two major towns in Mpumalanga

Province, namely Middelburg and Nelspruit and is connected to both these centres via the N4

Freeway. The N4 and Road P81-1 provide links from Gauteng to the major tourism centres in

Mpumalanga, specifically the Kruger National Park to the east and Pilgrim’s Rest, Graskop,

Lydenburg and Hoedspruit to the north-east (Emakhazeni Local Municipality , 2012).

According to the municipal IDP the population of Emakhazeni Local Municipality from the

census count of 2001 was 43,007 persons, and it declined to 32,840 persons based on the

estimates from the 2007 community survey. This implies an annual growth rate of -4.5%

between the 6 year period (Emakhazeni Local Municipality , 2012).

4.12 Heritage

A heritage survey has been conducted for the proposed Belfast Coal Mine (see De Jong

2009), which covered portions of the farms Leeuwbank 427 JS, Blyvooruitzicht 383 JT and

Zoekop 426 JS.

A total of 6 historical farmhouse sites and other structures (Sites 1, 2, 4, 5, 6, & 9) as well as

two graveyards (Sites 7 & 8) were recorded. Most of the historical structures that are older

than 60 years have a low rating of significance. The two graveyards recorded (Sites 7 & 8),

each contains approximately 11 and 12 graves respectively. Most of the graves are not

inscribed with a date and as such most of the graves are, by default, regarded as older as 60

years in terms of the NHRA. No Stone Age or Iron Age settlements, structures, features, or

artefacts were recorded during the survey. The location of the recorded sites for the

proposed development can be found in Figure 4-18, Figure 4-19 and Figure 4-20.




Project No. 467209

Figure 4-18: Site layout plan depicting locations of heritage sites

Figure 4-18

Figure 4-19





467209

Figure 4-19: Location of the Recorded Sites at the Rietkuil Private Railway Site



467209

Figure 4-20: Location of the Recorded Sites Along the Provincial Roads



Site 1: Cement Reservoir

The site comprises a cement reservoir that was probably used to water cattle that were

grazing in the area. The reservoir is roughly 4 metres in diameter with an outer trough. It is

currently not being used. The reservoir is not older than 60 years and therefore not

considered for protection. Photographic reference for this site can be found in Figure 4-22.


Project No. 467209

Figure 4-21: Photographic Reference for Site 1

Site 2: Historical farmhouse

The site comprises a farm homestead which consists of a main farm house and several other

outbuildings and structures. The main house was probably been built in the late 19th century,

but it has been substantially altered and renovated recently. Several of the other outbuildings

are constructed with dressed sandstone blocks. All the buildings have corrugated iron roofs.

Additions and changes have also been done to the outbuildings.

The buildings are located on the farm Wonderfontein 428 JS which was first settled by JMS

Scheepers, with a title deed to the property, in August 1868. The farm was only surveyed in

January 1890. These buildings are probably older than 60 years and are therefore protected

by the NHRA. Although their significance value is rated lower due to the recent alterations.

Photographic reference for this site can be found in Figure 4-22.



RIETKUIL PRIVATE RAILWAY SIDING

AND ASSOCIATED INFRASTRUCTURE Project No.

467209



The site comprises a dilapidated brick farm house and shed that is currently being used to

keep cattle. No middens were recorded. The structures identified at this site are assumed to

be not older than 60 years. Photographic reference for this site can be found in Figure 4-23.

RIETKUIL PRIVATE RAILWAY SIDING

AND ASSOCIATED INFRASTRUCTURE Project No.

467209





The site comprises a homestead that is currently dilapidated. No historical remains or

middens were recorded. The site is approximately 400 metres from the road and will not be

affected. Figure 4-24 illustrates the location of Site 5 in relation to the D 1110 road which is

proposed to be upgraded from gravel to surface.



467209

Figure 4-24: Physical Location of Site 5


The site comprises two square stone foundations that measures approximately 4x4 and 5x5

metres, respectively. They were probably used as livestock enclosures and the stones have

been removed. No deposits were found in association with the structures. Photographic

reference for Site 6 can be found in Figure 4-25.


Project No. 467209




Site 7: Graves’s location

The site comprises a graveyard which contains approximately 12 graves. They are all

arranged in an east-west orientation with the headstone on the western side. Most of the

graves are demarcated with stone bases. One headstone with an inscription was recorded:

Maseko (Died: 1978/02/04)

Unmarked graves are regarded as older than 60 years and are therefore protected by the

NHRA. Figure 4-26 provides a photographic reference for graves found at Site 7.


Project No. 467209


Site 8: Graves’s location

The site comprises a graveyard which contains approximately 11 graves. They are all

arranged in an east-west orientation with the headstone on the western side. Most of the

graves are demarcated with stones, but there are also granite and cement headstones and

bases. The following inscriptions were recorded:

Maria Maredi (no dates);

Nomvula Sabina Shoba (Born: 1975/04/02; Died: 2012/11/08);

Jan Mashila (Born: 1922/07/01; Died: 2005/08/08);

Maria Malika Shoba (Born: 1932/05/13; Died: 2003/04/03);

Jan Mfana Shoba (Born: 1951/06/01; Died: 2005/08/16).

Unmarked graves are regarded as older than 60 years and are therefore protected by the

NHRA. Figure 4-27 provides a photographic reference for the graves found at Site 8.




Project No. 467209



The site comprises a historical farmhouse and two possibly older stone houses and two

modern outbuildings. The main farmhouse probably dates to the late 19th century and is built

from brick with a corrugated iron roof. The iron windows (with burglar proof decorations) are

also later additions. The two dilapidated stone houses might even predate the farmhouse.

No middens were recorded. Photographic reference for this site can be found in Figure 4-28.


Project No. 467209




5 Environmental Impact Assessment The impact assessment was undertaken for the construction, operational and

decommissioning phases. Impacts to each environmental element documented in the

baseline are described under initial assessment, additional impact, cumulative impact,

mitigation measures and residual impact. The initial assessment outlines the existing level of

impact by current activities. The additional impact assesses the potential impact of the

development on a criterion. Mitigation measures for the additional impact are then prescribed

and a residual impact is calculated. The Impact Assessment will highlight and describe the

impacts to the environment following the above mentioned methodology and will assess the

following components:

Geochemical;

Biodiversity;

Wetlands;

Surface and Groundwater;

Groundwater;

Soils, land use and land capability;

Heritage;

Traffic;

Geochemical;

Noise;

Air quality;

Socio-economic.

5.1 Specialist investigations

The following specialist studies were conducted during the EIA phase of the EA application

process:

Air Quality Impact Assessment;

Biodiversity Impact Assessment;

Geochemistry Impact Assessment;

Heritage Impact Assessment;

Surface and Groundwater Impact Assessment;

Soil, Land Use and Land Capability Impact Assessment;

Noise Impact Assessment;

Traffic Impact Assessment;

Wetland Specialist Assessment;

Rehabilitation and Closure Study.

The Terms of Reference presented to the specialists in preparation for the compilation of the

specialist studies is contained in Table 5-1 below. These studies were conducted by suitably

qualified and experienced specialists and the findings of the studies were used to inform the

compilation of the Draft EIAr.



Table 5-1: Specialist Terms of Reference

Specialist Study

Scope

Air Quality The air quality assessment will include the following scope:

Literature review with respect to air quality and climate for the study area

(a radius of 5 km from the project area);

The assessment of the air quality impacts associated with construction and

operational phases of the proposed new infrastructure;

Identification of all sources of atmospheric emissions that are associated with

the proposed new infrastructure;

Set up and run an air dispersion model for dust (PM10 and dustfall, suspended

particulate matter) for construction and operational conditions for all locations

where possible; and

Develop an emissions inventory for the construction and operational activities.

Biodiversity The scope of work includes a full ecological investigation, including a terrestrial

fauna and flora assessment. The assessment will fulfil the ecological assessment

requirements of the EIA as required in terms of the Mineral and Petroleum

Resources Development Act (Act 28 of 2002) and NEMA and the associated

regulations as well as other legal requirements applicable on both a national and

provincial level including the requirements of the NWA and associated guidelines

and regulations. The assessment will also be conducted to best meet all relevant

stakeholders’ requirements for ecological assessments.

Desktop information will be gathered to obtain background information on the

project. Field assessments will be undertaken and assessment methods will be

applied to characterise the environment and to identify ecosystems and biological

assemblages at risk. Once site specific issues have been identified the impact

assessment stage investigations will be initiated. At this stage, specific aspects

requiring further investigation will be addressed within the final project area

including studies of more sensitive areas, and specific studies of threatened faunal

and floral assemblages.

Floral assessments

The proposed methodology includes both a desktop review and a field work

component. A desktop review of distribution lists (including Red Data /

Conservation Important Species) and available literature will be conducted to guide

the field work component. Included in the desktop study will be an evaluation of the

floral lists already compiled as part of previous studies. The vegetation type of the

area will be defined according to sources such as Low & Rebelo, (1996), Acocks

(1988) and Mucina and Rutheford (2006). Extensive consideration will also be

given to determining the EIS of the subject property according to relevant spatial

information databases. The SANBI and National Herbarium Pretoria Computerised

Information System databases (PRECIS List) for the quarter degree square will

also be consulted and will serve as the reference data to which field surveys will be

compared to:

Various habitat types; and

A description of each habitat type based on conservation importance and

present ecological state.

Floral species associated with each habitat component will be assessed by

applying the following:

Focus on sensitive habitat types and impacts associated to them in order to

fulfil the requirements of the study;

Focus on establishing the presence of red data species and other sensitive

species identified as well as suitable habitats for any of these species;



Specialist Study

Scope

Specific focus will also be given to identifying areas of severe weed

encroachment which will be mapped;

Medicinal plant species will also be identified and the location of special

medicinal species will be presented on maps;

Veld condition will be quantitatively assessed according to a pre-defined veld

condition index and will also be quantitatively compared to the typical

vegetation for the vegetation type of the area according to (Mucina &

Rutherford, 2006);

Species lists for each habitat unit will be developed;

Stands of alien vegetation will be mapped;

Sensitive areas will be mapped where detail will be given of the ecological

aspect of concern in each sensitivity zone;

An assessment of cumulative impacts on floral assemblages in the region will

also be made;

The reports produced will include sensitive habitat types and impacts from

habitat disturbance, floral assemblages at risk. Based on the findings a

detailed impact assessment on all identified significant risks will take place;

Recommendations on management and mitigation measures (including

opportunities and constraints) with regards to the construction and operation of

the proposed development in order to manage and mitigate impacts on the

ecology of the area;

Rehabilitation and closure requirements will be considered.

Faunal Assessment

Faunal assemblage will be determined using the following methods:

Extensive consideration will be given to determining the EIS of the proposed

new Rietkuil Private Railway Siding surface area according to relevant

spatial information and conservation databases. The SANBI and National

Herbarium Pretoria Computerised Information System (PRECIS)

databases for the quarter degree square will also be consulted and will serve

as the reference data to which field survey data will be compared to;

Visual observations of actually occurring species;

Identification of evidence of occurrence, e.g. call spoor, droppings etc.;

Capture of fauna by various methods including netting, trapping and dragging.

In this regard special mention is made of the use of pitfall traps and sweep

netting for invertebrates as well as the use of Sherman traps to determine the

composition of the small mammal community on the site. Rope dragging

methods may also be used to flush birds from areas where red data list

avifaunal species are deemed likely to occur;

Nocturnal studies to identify nocturnal animals in the area may take place if it is

deemed necessary.

The reports produced will include sensitive habitat types and impacts from habitat

disturbance, faunal assemblages at risk and an assessment of impacts on

migratory routes. An assessment of cumulative impacts on faunal assemblages in

the region will also be made. The Red Data Sensitivity Index Score (RDSIS) index

will also be considered in order to quantify the importance of the proposed new

Rietkuil Private Railway Siding in terms of RDL faunal conservation. Based on

the findings a detailed impact assessment on all identified significant risks will take

place:

Recommendations on management and mitigation measures (including



Specialist Study

Scope

opportunities and constraints) with regards to the construction and operation of

the proposed development in order to manage and mitigate impacts on the

faunal assemblage of the area.

The following field assessment methodologies will be followed as deemed

necessary:

Invertebrates:

Sweep netting;

Pitfall trapping;

Direct visual observations.

Amphibians:

Identification through call identification and direct observation;

Habitat and potential biodiversity list;

Pitfall trapping;

Habitat evaluation for RDL species.

Reptiles:

Searching of target areas including rocky outcrops and through direct

observation;

Potential biodiversity list;

Pitfall trapping;


Birds:

Identification through call and direct observation;



Mammals:

Direct observation

Identification through call, spoor or dung;

Trapping using Sherman traps;



The effects of the development on migratory corridors and connectivity will be

addressed and a sensitivity map will be developed for the proposed development

site. Mitigation measures will be recommended on completion of the study.

Geochemistry The scope of the geochemistry analysis will include a representative sample of the

material in the stockpiles, and undertake a suite of geochemical laboratory

analyses that will provide an indication of potential impacts. It is likely that Static

Geochemical tests will provide sufficient data on which to develop management

measures. The tests that SRK will therefore facilitate will include:

Acid Base Accounting using the modified Sobek Method;

Acid regia digest followed by an Inductively Coupled Plasma (ICP) scan to

understand total metal content;

Contact water leach followed by an ICP scan to determine mobile metal and

salt concentrations;

Synthetic Precipitation Leach Potential followed by an ICP scan to understand

metal mobility in a mildly acid medium.



Specialist Study

Scope

Heritage The purpose of the heritage survey is to ascertain if any archaeological or historical

remains occur in the survey area and if they are of aesthetic, architectural,

historical, scientific, social, spiritual, linguistic or technological value. Attention will

also be given to both tangible and intangible heritage remains. A site visit will be

conducted to investigate and evaluate the survey area. Baseline information will be

sources and reviewed to compile a heritage framework for the survey area.

Recommendations will then be made to conserve, preserve and mitigate any

recorded heritage remains.

Heritage surveys usually involve the following aspects:

Archival and desktop survey of existing archaeological and heritage

information of the survey area (baseline assessment);

Liaise with SAHRA and search SAHR Information Systems for existing reports

and information of the survey area;

Compile detailed maps of the survey area indicating all cultural heritage

resources (Stone Age, Iron Age and Historical Period);

Utilise GIS systems and Google Earth (also topographic maps and aerial

photographs);

Conduct pedestrian and intuitive survey techniques during field work;

Random consultation with local people to ascertain aspects of intangible

heritage;

Recording and documenting of all sites using standard archaeological field

work techniques.

The phase 1 heritage impact report will include the following:

Detailed description of all archaeological and historical artefacts, structures

(including graves) and settlements documented in the area (including

photographs) will be included in the phase 1 heritage report;

Establish the level of sensitivity/importance of the archaeological and historical

(both tangible and intangible) remains in the area;

Cultural traditions related by the local communities will be a high priority when

establishing the significance of archaeological and historical remains as well as

graves in formal cemeteries and informal burials;

Propose practical mitigation measures for predicted impacts (management

measures);

Indicate limitations and assumptions;

Provide the relevant authorities with appropriate documents for their review

and decision-making. In particular, copies of the Heritage Report must be sent

to SAHRA and the relevant Provincial Heritage Resource Agency.

Noise The study to determine the noise impact such a development will have during the

construction and operational phases on the environment will be based on:

SANS 10328 – Methods for environmental noise impact assessments;

SANS 10103:2008 – The measurement and rating of environmental noise with

respect to annoyance and to speech communication;

Guidelines for community noise impact assessments;

Relevant Noise Control Regulations.

The noise study and subsequent assessment will be applicable on the abutting

noise sensitive areas. This noise survey from an environmental noise point of view

will have to be done during the daytime period and the night time period in order to



Specialist Study

Scope

evaluate the recommended residual noise levels laid down by SANS 10103:2008

and to get a representative residual noise level for the areas where the proposed

activities will or takes place.

The construction, operational and closure phases will be addressed in the report

and the baseline information existing and newly acquired data will be used to

determine the potential impact and management measures.

There will be two types of noise sources of which the one is a point source at the

overload facility and the line source which will be the haul routes. These two

categories of noise sources will determine how mitigation and the management

thereof will be addressed.

The proposed noise survey will comprise the following:

Preliminary survey and identification of measuring points;

All measurements will be done on the boundary of the property;

Sound pressure readings and vibration levels will also be done at the closest

residential area – if applicable;

Noise survey at the identified measuring sites – Ambient noise measurements;

Calculation of noise propagation;

Analysing of results;

Results of the survey, report and recommendations and mapping of noise

contours for the sites.

The report will be in line with SANS ISO 14001:2004 and will provide the following

information:

Executive summary;

Introduction;

Environmental, Industrial and Community noise guidelines;

Types of noise;

Method of evaluation;

Comments;

Results;

Discussion of the results;

Recommendations;

Conclusion.

Soils, Land Capability and Land Use

The soil study will include the following components:

Preliminary assessment

Outline of the study approach and identification of the assumptions and

sources of information to be used.

A desktop study of existing maps, broad soil classes, etc. to establish broad

baseline conditions and areas of environmental sensitivity.

Soil survey

A detailed soil survey (150 m x 150 m) will be conducted where the proposed

development project will be. The maps generated during the desktop study phase

will be used to determine a grid and these areas will be traversed on the pre-

determined transects and auger samples will be studied. In areas of great soil form

variety, more samples points will be evaluated as well as to establish soil form

boundaries.

Observations will be made regarding soil texture, depth of soil, soil structure,



Specialist Study

Scope

organic matter content and slope of the area. The soil characteristics of each

sample point will be noted and logged with a global positioning system. The

location of these auger points will be indicated in a Survey Points Map to be

included in the final specialist report. Soil samples for chemical analysis will be

taken at 3 sampling points and at each point both topsoil (0-300 mm) and subsoil

(300-600 mm) will be sampled.

The soils will be described using the S.A. Soil Classification Taxonomic System

(Soil Classification Working Group, 1991) published as memoirs on the Agricultural

Natural Resources of South Africa No. 15. Soils will be grouped into classes with

relatively similar soil properties and paedogenesis. A cold 10% hydrochloric acid

solution will be used on site to test for the presence of carbonates in the soil.

Chemical analyses

The 16 representative soil samples (8 topsoil and 8 subsoil samples) will be stored

in perforated soil sampling plastic bags on site and sent by courier to Geolab for

chemical soil analysis. Samples will be analysed for pH, phosphorus content, cat

ions (calcium, magnesium, potassium and sodium) and electrical conductivity.

Reporting

The results of the soil survey will be mapped and zones of similar soil forms

indicated. Once soil form groups have been outlined, soil potential and land

capability will be determined using the guidelines developed by the Agricultural

Research Council unless otherwise specified by the client.

The possible impacts of the proposed project on soil, agricultural potential and land

capability will then be evaluated using the method as prescribed by Scientific

Aquatic Services.

The results of the study will be provided in a comprehensive electronic document

and will include geo-referenced maps, photos, diagrams, as well as the following:

Details and expertise of specialist;

Declaration of independence;

Scope and purpose of the report;

Description of methodology;

Identification of gaps and assumptions;

Results of impact assessment;

Findings and conclusions.

Surface and Groundwater

The scope of work associated with the Hydrological and Hydrogeological study will

include the establishment of baseline conditions for the area to be disturbed. This

is to include:

An examination of the overall surface water management strategy in terms of

the relevant legislation and regulations. This will include the discharge of storm

water, permissible proximity of development to water bodies and the potential

reuse and recycling of water;

The provision of 1:50 and 1: 100 year floodlines for the relevant drainage

features on or adjoining the sites;

In collaboration with the ecological specialist, a description of the presence and

extent of water bodies that may be affected by the development;

Liaison with the ecological team to determine ecological impacts in terms of

any change to the surface water flow in terms of stream diversion and quantity;

A review of baseline information on rainfall and evaporation, as well as a

delineation of the affected catchment area;



Specialist Study

Scope

An identification of potential surface water contamination sources on the site;

An identification of surface and groundwater uses in the area;

A determination of the current surface water quality of water bodies that may

be affected by the proposed development;

Preparation of a storm water management plan for the site. Describe the

procedure for dealing with excess run off during the construction and

operational phases of the project;

An estimation of the required storage volumes of the ponds proposed for storm

water and process water management on the basis of a water balance;

An identification of groundwater resources in the area and the quality of these;

Identify potential sources of groundwater pollution in the area;

Identify potential receptors for groundwater impacts;

The impacts in terms of surface and groundwater resources as a result of the

proposed development needs to be assessed;

Management recommendations need to be provided for the mitigation of the

water impacts. This will need to include a surface and groundwater monitoring

programme.

Traffic The proposed project is likely to result in an increase in traffic volumes within the

region, during the construction and operational phases of the project. Road

upgrades may therefore be required to the existing road network. It is therefore

recommended that a traffic assessment be undertaken to determine the possible

impact of the proposed private siding on the local road networks and general traffic

during construction and operation.

Undertake an initial site visit with the EIA team in order to obtain an overview of

the site;

Collection of background information and undertake traffic counts at each of

the sites to establish a baseline and peaks of traffic in the area;

Determine existing traffic flows on adjacent road network in order to quantify

the regional traffic assessment;

Trip generation;

Investigation regarding any required road upgrading in the area;

Determine public transport and pedestrian activities;

Reporting.

Wetland The assessment will be undertaken to best meet the requirements of the DWS in

order to supply specialist information in support of the mandatory supplementary

information required for Section 21 (c) & (i) licenses.

The assessment will be undertaken to best meet the requirements of the

DWAS in order to supply specialist information in support of the mandatory

supplementary information required for Section 21 (c) & (i) licenses.

Delineation of the wetland zones will take place according to “DWAF, 2005: A

practical Guideline Procedure for the Identification and Delineation of Wetlands

and Riparian Zones”. Aspects such as soil morphological characteristics,

vegetation types and wetness will be used to delineate the various zones of the

wetland (permanent and temporary) according to the guidelines.

All wetlands encountered will be classified according to the National Wetland

Classification System for South Africa.

The wetland services provided by the resources on the subject property will be

assessed according to the Method of Kotze et. al. (2009) in which services to

the ecology of the site will be defined and services to the people of the area will



Specialist Study

Scope

be defined.

The wetlands will also be assessed according to the DWAF (2007) Manual for

the assessment of a Wetland Index of Habitat Integrity (IHI) for South African

floodplain and channelled valley bottom wetland types or according to the

Wetland Health according or to the resource directed measures guideline as

advocated by Macfarlane et al., (2011) depending on which approach is most

applicable.

The wetland and riparian areas will be mapped according to the ecological

sensitivity of each wetland area.

The wetland EIS will be determined making use of the DWA 1999 method. Any

applicable mitigation measures to minimise potential impacts on the wetland

resources within the subject property will be highlighted.

SASS 5 assessments on macro invertebrates and fauna will be conducted.

Rehabilitation and Closure

This will be done for the proposed private siding and associated infrastructure

using baseline information collected during the compilation of the EIA, with this

used to identify possible opportunities and constraints at closure. This information

will also be utilised to identify potential post closure land uses. A short closure and

rehabilitation plan for the site will be developed to mitigate the potential risks

associated with the site at closure.

The approach to calculating the closure liability as described in the Department of

Mineral Resources “Guideline document for the evaluation of the quantum of

closure related financial provisions provided by a mine” will be used to calculate

the expected closure liability for the operation, with this being the figure used to

raise a provision for closure for the project.

The rehabilitation plan will include the following:

A detailed list of the various steps that need to be undertaken to return an

activity and its sub-units to its post mining land use;

Determine the various actions required to demolish the infrastructure.

5.2 Methodology of the Impact Assessment

The assessment of the anticipated impacts relating to the proposed new Rietkuil Private

Railway Siding and associated infrastructure was done according to the SRK’s standard

methodology for impact assessment.

The first stage of impact assessment is the identification of environmental activities, aspects

and anticipated impacts. This is supported by the identification of receptors and resources,

which allows for an understanding of the impact pathway and an assessment of the sensitivity

to change. The above terms, used in relation to significance, are defined in Table 5-2.

The cut-off points have been defined in relation to characteristics of exploration, but those for

Probability, Severity/Intensity and Significance are subjective, based on experience.

The significance of the impact is then assessed by rating each variable numerically according

to defined criteria as outlined in Table 5-2. The purpose of the rating is to develop a clear

understanding of influences and processes associated with each impact. The severity, spatial

scope and duration of the impact together comprise the consequence of the impact and when

summed can obtain a maximum value of 15. The frequency of the activity and the frequency

of the impact together comprise the likelihood of the impact occurring and can obtain a

maximum value of 10. The values for likelihood and consequence of the impact are then read

off a significance rating matrix as shown in Table 5-3 and Table 5-4.



The assessment of significance should be undertaken twice. Initial significance should be

based on only natural and existing mitigation measures (including built-in engineering

designs). The subsequent assessment should take into account the recommended

management measures required to mitigate the impacts.

Table 5-2: Criteria for Assessing Significance of Impacts

SEVERITY OF IMPACT RATING

Insignificant / non-harmful 1

Small / potentially harmful 2

Significant / slightly harmful 3

Great / harmful 4

Disastrous / extremely harmful 5

SPATIAL SCOPE OF IMPACT RATING

Activity specific 1

Project specific (within the project boundary) 2

Local area (within 5 km of the activity boundary) 3

Regional 4

National 5

DURATION OF IMPACT RATING

One day to one month 1

One month to one year 2

One year to ten years 3

Life of operation 4

Post closure / permanent 5

FREQUENCY OF ACTIVITY / DURATION OF ASPECT

RATING

Annually or less / low 1

6 monthly / temporary 2

Monthly / infrequent 3

Weekly / life of operation / regularly / likely 4

Daily / permanent / high 5

FREQUENCY OF IMPACT RATING

Almost never / almost impossible 1

Very seldom / highly unlikely 2

Infrequent / unlikely / seldom 3

Often / regularly / likely / possible 4

Daily / highly likely / definitely 5

CONSEQUENCE

LIKELIHOOD



Table 5-3: Significance Rating Matrix

Table 5-4: Positive/Negative Mitigation Ratings

Color Code

Significance Rating

Value Negative Impact Management Recommendation

Positive Impact Management Recommendation

Very high 126-150

Improve current management Appropriate mitigation strategy to be implemented

High 101-125

Improve current management Appropriate mitigation strategy to be implemented as soon as possible

Medium-high 76-100 Improve current management Appropriate mitigation strategy to be implemented

Low-medium 51-75 Maintain current management

Monitor Risk, no further mitigation required

Low 26-50 Maintain current management


Very low 1-25 Maintain current management


5.3 Impact significance

This section provides a detailed description of the potential impacts that may occur as a result

of the implementation of this proposed project. These potential impacts have been subjected

to detailed assessment by credible independent specialists and include the biophysical, social

and economic impacts which may arise during the construction phase (i.e. short term), the

operational phase (i.e. long term impacts) as well as the decommissioning phase (i.e.

rehabilitation and closure) of the proposed development, and takes into consideration

cumulative impacts. Furthermore impacts are assessed prior to mitigation and with mitigation

measures implemented.

It is a requirement of the NEMA EIA Regulations that the impact assessment takes

cognisance of cumulative impacts. In fulfilment of this requirement the impact assessment

will take include the assessment of any existing impact sustained by the operations, any

mitigation measures already in place, any additional impact to environment through continued

and proposed future activities, and the residual impact after mitigation measures.

It is important to note that cumulative impacts at the national or provincial level will not be

considered in this assessment, as the total quantification of external companies / projects on

resources is not possible at the project level due to the lack of information and research

documenting the effects of existing activities. Such cumulative impacts that may occur across

CONSEQUENCE (Severity + Spatial Scope + Duration)

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15

2 4 6 8 10 12 14 16 18 20 22 24 26 28 30

3 6 9 12 15 18 21 24 27 30 33 36 39 42 45

4 8 12 16 20 24 28 32 36 40 44 48 52 56 60

5 10 15 20 25 30 35 40 45 50 55 60 65 70 75

6 12 18 24 30 36 42 48 54 60 66 72 78 84 90

7 14 21 28 35 42 49 56 63 70 77 84 91 98 105

8 16 24 32 40 48 56 64 72 80 88 96 104 112 120

9 18 27 36 45 54 63 72 81 90 99 108 117 126 135 LIK

EL

IHO

OD

(F

requen

cy o

f ac

tivit

y

+ F

requen

cy o

f im

pac

t)

10 20 30 40 50 60 70 80 90 100 110 120 130 140 150



industry boundaries can also only be effectively addressed at Provincial and National

Government levels.

The environmental impact assessment section of the report outlined the potential impacts

identified by the respective specialists. These impacts were given a significance rating before

and after implementation of the mitigation measures. The impact after mitigation measures

(residual impacts) were combined with the impact before mitigation measures (initial impacts)

to describe the cumulative impact to the environment.

5.3.1 Pre-construction phase

No impacts are anticipated to take place during the pre-construction phase of the project.

5.3.2 Construction phase

The following impacts are anticipated to occur during the construction phase of the Rietkuil

private railway siding project:

Biodiversity (Fauna & Flora)

It is anticipated that construction of the proposed new Rietkuil Private Railway Siding and

associated infrastructure will have a ‘Low’ to ‘Low-Medium’ impact on the ecological receiving

environment post implementation of the recommended mitigation measures. A complete list

of the floral species, South African threatened RDL species (including Invertebrates,

Amphibians, Reptile, Avifaunal, Mammalian) and the potentially occurring faunal species are

included in Appendix E as part of the EMPr. Adequate recommendations were included in

the specialist study to mitigate impacts on the receiving environment. These

recommendations and mitigation measures form part of the EMPr.

Table 5-5: Impacts on Habitat for Floral Species

Impact

Consequence Likelihood Significance

Rating Mitigation

Rating Severity Spatial Duration Frequency of Activity

Frequency of Impact

Impact before management

3 2 5 5 3 80 Medium-

High

Key management measures:

The boundaries of the development footprint areas are to be clearly defined and it should be ensured that all activities remain within defined footprint areas and that no vegetation is cleared outside the development footprint area.

Edge effects of all construction and operational activities, such as erosion and alien plant species proliferation, which may affect flora habitat, need to be strictly managed.

Vehicles should be restricted to travelling only on designated roadways to limit the ecological footprint of the proposed Rietkuil Private Railway Siding development activities.

It must be ensured that construction related waste or spillage and effluent do not affect the immediate and surrounding habitat boundaries.

Proliferation of alien and invasive species is expected within any disturbed areas. These species should be eradicated and controlled to prevent their spread beyond the development footprint areas. Alien plant seed dispersal within the top layers of the soil within footprint areas, has to be controlled.

Recommended mitigation measures:

All soils compacted as a result of construction activities falling outside of development footprint areas should be ripped and profiled. Special attention should be paid to alien and invasive control within these areas. Alien and invasive vegetation control should take place throughout all development phases including rehabilitation phases to prevent loss of floral habitat in surrounding areas.

Impact after 2 1 5 4 2 48 Low



Impact


Rating Mitigation


Frequency of Impact

management

Status (+/-) Low (-)

Cumulative impact

If the abovementioned mitigation measures are implemented successfully the cumulative impacts of the construction of the Rietkuil private railway project should not result in an impact larger than was assessed initially.

Table 5-6: Impacts on Flora Diversity

Impact


Rating Mitigation

Rating Severity Spatial Duration

Frequency of Activity

Frequency of Impact


3 2 5 4 2 60 Low-

Medium


All development footprint areas and areas affected by the proposed Rietkuil Private Railway Siding development should remain as small as possible and should not encroach onto surrounding areas. It must be ensured that these areas are off-limits to construction vehicles and personnel to prevent impacts on vegetation.

Removal of the alien and weed species encountered on the property must take place in order to comply with existing legislation (amendments to the regulations under the Conservation of Agricultural Resources Act, 1983 and Section 28 of the National Environmental Management Act, 1998, and the National Environmental Management: Biodiversity Act, 2004). Removal of species should take place throughout the construction, operational and rehabilitation/ maintenance phases.

Species specific and area specific eradication recommendations:

o Care should be taken with the choice of herbicide to ensure that no additional impact and

loss of indigenous plant species occurs due to the herbicide used.

o Footprint areas should be kept as small as possible when removing alien plant species.

Informal fires in the vicinity of development area should be prohibited during all development phases.


It must be ensured that all roads and construction areas are regularly sprayed with water in order to curb dust generation. This is particularly necessary during the dry season when increased levels of dust generation can be expected. These areas should not be over-sprayed causing water run-off and subsequent sediment loss in the vicinity of the study area.

Impact after management

2 1 3 3 2 30 Low


Cumulative impact




Table 5-7: Impacts on Flora Species of Conservation concern

Impact


Rating Mitigation


Frequency of Impact


3 3 5 2 2 44 Low


All proposed Rietkuil Private Railway Siding development footprint areas and areas affected by the proposed development should remain as small as possible and should not encroach onto surrounding areas. It must be ensured that these areas are off-limits to construction vehicles and personnel.


Should any RDL or protected flora species, be encountered within study area, the following should be ensured:

If any threatened species, or nationally or provincially protected flora will be disturbed, ensure effective relocation of individuals to suitable similar habitat. Arrangement with the relevant authorities needs to take place to rescue and relocate the species.expected. These areas should not be over-sprayed causing water run-off and subsequent sediment loss in the vicinity of the study area.


2 2 5 2 2 36 Low


Cumulative impact

The cumulative impact of the current activities and the future activities will not increase the impact rating from a Low Impact as rated in the initial impact assessment

Based on the above assessment it is evident that there are three possible impacts on the

floral ecology within the study area. In the consideration of mitigation it is assumed that a

high level of mitigation takes place but which does not lead to prohibitive costs. From the

abovementioned tables it is evident that prior to management measures being put in place,

one Medium-High, one Medium-Low and one Low significance impact is likely. If effective

management takes place, all impacts could be reduced to low significance impacts.

Table 5-8: Impacts on Faunal Habitat

Impact


Rating Mitigation


Frequency of Impact


4 3 5 5 3 96 Medium-

High


All development footprint areas should remain as small as possible and should not encroach onto surrounding undisturbed and natural areas. It must be ensured that these areas are off-limits to construction vehicles and personnel.

If it is absolutely unavoidable that wetlands will be impacted, especially during bridge construction, disturbance to any wetland crossings must be minimised and suitably rehabilitated.

It must be ensured that any wetland crossings allow fauna species to continue to migrate through the wetlands which act as migratory corridors.

In the event of a breakdown, maintenance of vehicles must take place with care and the recollection of spillage should be practiced near the surface area to prevent ingress of hydrocarbons into topsoil.

Vehicles should be restricted to travelling only on designated roadways to limit encroachment in the study area and onto adjacent habitats.


Demarcation of construction footprints should be considered.



Impact


Rating Mitigation


Frequency of Impact

Rehabilitate all fauna habitat areas to ensure that the faunal ecology is re-instated.


2 2 5 4 3 56 Low-

Medium

Status (+/-) Low-Medium (-)

Cumulative impact:


Table 5-9: Impacts on Faunal Diversity

Impact


Rating Mitigation


Frequency of Impact


4 3 5 4 3 84 Medium-

High


No trapping or hunting of fauna is to take place.

All development footprint areas should remain as small as possible and should not encroach onto surrounding sensitive wetland areas. It must be ensured that these areas are off-limits to construction vehicles and personnel.


Vehicles should be restricted to travelling only on designated roadways to limit the ecological footprint of the proposed Rietkuil Private Railway Siding development activities


3 2 3 3 3 48 Low-

Medium


Cumulative impact


Table 5-10: Impact on RDL and Protected Fauna Species

Impact


Rating Mitigation


Frequency of Impact


3 3 3 2 2 45 Low


Erect roadside signs warning motorists of potential RDL bird species, especially at wetland crossings.

All development footprint areas should remain as small as possible and should not encroach onto surrounding sensitive wetland areas. It must be ensured that these areas are off-limits to construction vehicles and personnel.

If it is absolutely unavoidable that wetlands will be affected, disturbance to any wetland crossings must be minimised and suitably rehabilitated.


Vehicles should be restricted to travelling only on designated roadways to limit the ecological footprint of the proposed construction activities.

No trapping or hunting of fauna is to take place. Access control into more sensitive habitat areas



Impact


Rating Mitigation


Frequency of Impact

must be implemented to ensure that no illegal trapping or poaching takes place.

Should any RDL species be encountered within the study area, these species should be monitored and if required, relocation of these species to similar habitat within or in the vicinity of the study area with the assistance of a suitably qualified specialist must be considered.

Recommended mitigation measures

Rehabilitate all fauna habitat areas to ensure that faunal ecology is re-instated during all phases.


3 3 3 2 2 36 Low


Cumulative impact


Based on the above assessment it is evident that there are three possible impacts on the

faunal ecology within the study area. From the tables above it is evident that if effective

management takes place, all potential faunal impacts may be reduced.

Wetlands

It is anticipated that construction of the proposed new Rietkuil Private Railway Siding and

associated infrastructure will have a ‘Low’ to ‘Low-Medium’ impact on the wetlands post

implementation of the recommended mitigation measures. This will ensure that the wetland

ecology of the proposed construction areas as well as surrounding areas are being protected

or adequately rehabilitated in order to minimize impacts on the wetlands. Adequate

recommendations were included in the specialist study to mitigate impacts on the wetlands.

These recommendations and mitigation measures form part of the EMPr.

Table 5-11: Impacts on Loss of Wetland Habitat and Ecological Structure

Impact


Rating Mitigation


Frequency of Impact


3 4 5 5 3 96 Medium-

High

Essential mitigation measures:

All development footprint areas should remain as small as possible and should, ideally, not encroach onto wetland areas.

If it is absolutely unavoidable that wetlands will be affected, especially during bridge or culvert construction, disturbance to any wetland crossings must be minimised and suitably rehabilitated. The design of such culverts / bridges should allow for wetland soil conditions to be maintained both upstream and downstream of the crossing to such a degree that wetland vegetation community structures upstream and downstream of the crossing are maintained. In this regard, special mention is made of:

o The design of such culverts and/or bridges should ensure that the permanent wetland

zone should have inundated soil conditions throughout the year extending to the soil

surface.

o The design of such culverts and/or bridges should ensure that the seasonal wetland zone

should have water-logged soils within 300mm of the soil surface at all times.

o Temporary wetland zone areas should have waterlogged soil conditions occurring to

within 300m of the land surface during the summer season.

Ensure that no incision and canalisation of the wetland system takes place as a result of the



Impact


Rating Mitigation


Frequency of Impact

construction of the culverts.

It must be ensured that flow connectivity along the wetland features is maintained.

Re-profiling of the banks of disturbed wetland areas.

Reinforce banks and drainage features where necessary with gabions, reno mattresses and geotextiles.

It must be ensured that all hazardous storage containers and storage areas comply with the relevant SABS standards to prevent leakage. All vehicles must be regularly inspected for leaks. Re-fuelling must take place on a sealed surface area to prevent ingress of hydrocarbons into topsoil.

All spills should be immediately cleaned up and treated accordingly.

Appropriate sanitary facilities must be provided and all waste removed to an appropriate waste facility.

Implement alien vegetation control program within wetland areas.

Monitor all systems for erosion and incision.

Recommended mitigation measures

Restrict construction to the drier winter months if possible to avoid sedimentation of wetland features in the vicinity of the proposed mine development areas.

Re-vegetate all disturbed areas with indigenous wetland species


3 3 2 2 5 54 Low-

Medium


Cumulative impact


Table 5-12: Changes to Wetland Ecological and Sociocultural Service provision

Impact


Rating Mitigation


Frequency of Impact


4 4 5 4 3 91 Medium-

High


If it is absolutely unavoidable that wetlands will be affected, especially during bridge construction, disturbance to any wetland crossings must be minimised and suitably rehabilitated.




Monitor all systems for erosion and incision.

Edge effects of activities including erosion and alien / weed control need to be strictly managed in the wetland areas.

As much vegetation growth as possible should be promoted within the wetland areas in order to protect soils. In this regard, special mention is made of the need to use indigenous vegetation species where hydroseeding, wetland and rehabilitation planting (where applicable) are to be implemented.

Implement alien vegetation control program within wetland areas associated with the proposed development.


Restrict construction to the drier winter months if possible to avoid sedimentation of wetland features in the vicinity of the proposed development areas.

Re-vegetate all disturbed areas with indigenous wetland species.



Impact


Rating Mitigation


Frequency of Impact


2 3 5 3 3 60 Low-

Medium


Cumulative impact


Table 5-13: Impacts on Wetland Hydrological Function

Impact


Rating Mitigation


Frequency of Impact


4 4 5 4 3 91 Medium-

High


The boundaries of development footprint areas are to be clearly defined and it should be ensured that all activities remain within these defined areas.

If it is absolutely unavoidable that wetlands will be affected, especially during construction, disturbance to any wetland crossings must be minimised and suitably rehabilitated.




All vehicles should remain on designated roads with no indiscriminate driving through area.

Rehabilitate the wetland zone to ensure that the watercourse functions are re-instated.

Implement alien vegetation control program within wetland areas.


Revegetate all disturbed areas with indigenous wetland species.


2 2 5 2 3 45 Low


Cumulative impact


Based on the above assessment it is evident that there are three possible impacts that may

affect the wetland ecology of the study area. In the consideration of mitigation it is assumed

that a high level of mitigation takes place but which does not lead to prohibitive costs. From

the tables above it is evident that prior to mitigation all of the impacts are medium-high level

impacts. If mitigation and effective management takes all impacts will be reduced to a low

level.


Land use after decommissioning should aim to re-establish the cattle farming and crop

production potential of the land. No serious soil chemical issues such as soil salinity or

sodicity occur on site.

It is anticipated that proposed construction of the proposed new Rietkuil Private Railway

Siding and associated infrastructure will have a ‘Low’ to ‘High’ impact on the soils, land use



and land capability post implementation of the recommended mitigation measures. Adequate

recommendations were included in the specialist study to mitigate impacts on the receiving

environment. These recommendations and mitigation measures form part of the EMPr.

Table 5-14: Impacts Relating to Soil Compaction

Impact


Rating Mitigation


Frequency of Impact


5 4 4 3 5 108 High

Mitigation measures:

When stripping machinery is used for stripping, stockpiling and ‘topsoiling’ operations, it should operate when the soil moisture content is below approximately 8 % (during the dry winter months) in order to limit soil compaction and machinery getting stuck.

For use on site, tracked vehicles are more desirable than wheeled vehicles due to their lower point loading and slip, while vehicle speed should be maintained in order to reduce the duration of applied pressure, thereby minimizing compaction.

The width of the levelled or disturbed area for haul roads must be minimized as much as possible. Unnecessary dirt tracks (outside of the area to be disturbed) should be avoided during the construction of the haul road.

Impact beyond the site boundary can be reduced by using existing roads and reducing new roads to a minimum.


2 3 5 4 4 80 Medium-

High

Status (+/-) Medium-High (-)

Cumulative impact


Table 5-15: Impacts Relating to Soil Erosion

Impact


Rating Mitigation


Frequency of Impact


4 3 5 5 4 108 High


Stripping of topsoil should not be conducted earlier than required (maintain grass cover for as long as possible) in order to prevent the erosion (wind and water) of organic matter, clay and silt.

Stripped soils should be stockpiled as a berm upslope (majority) and surrounding the disturbed area.

Soil stockpiles must be sampled, ameliorated (fertilized) and re-vegetated as soon after construction as possible. This is in order to limit raindrop and wind energy, as well as to slow and trap runoff, thereby reducing soil erosion. Grassland and shrub species indigenous to the area are preferred, given both their hardy nature as well as their lower maintenance requirements.

The soils stripped for levelling purposes must be stockpiled as a berm along the entire length of haul roads (upslope).

Erosion control measures such as intercept drains and toe berms must be constructed where necessary.

Gravel roads must be well drained in order to limit soil erosion.

The vegetative (grass) cover on the soil stockpiles (berms) must be continually monitored in order to maintain a high basal cover. Such maintenance will limit soil erosion by both the mediums of water (runoff) and wind (dust).

The layered haul road drainage system and surface must be well maintained in order to limit soil erosion



Impact


Rating Mitigation


Frequency of Impact


2 3 4 4 4 72 Low-

Medium


Cumulative impact


Table 5-16: Impacts Associated With the Sterilization of Topsoil Layer

Impact


Rating Mitigation


Frequency of Impact


4 3 4 5 5 110 High


The measurable effect of the construction and operational phase on this resource and the likeliness of preventing or reducing the effect by utilizing mitigation measures are negligible


4 3 4 5 5 110 High

Status (+/-) High (-)

Cumulative impact

Even with the implementation measurable effect of the construction and operational phase on this resource and the likeliness of preventing or reducing the effect by utilizing mitigation measures are negligible. The cumulative effect of the construction of the Rietkuil private railway project should not result in an impact larger than was assessed initially as the area is transformed and already impacted upon.

Table 5-17: Impacts associated with Chemical Soil Pollution

Impact


Rating Mitigation


Frequency of Impact


4 3 4 5 5 110 High


An intercept drain should be constructed upslope of construction and operational areas, in order to re-direct clean water away to avoid soil chemical pollution to clean groundwater resources.

An intercept drain should possibly be constructed downslope of polluted areas, in order to drain potentially polluted water into a pollution control dam.

Drains and intercept drains should be maintained to ensure that it continue to redirect clean water away from the polluted areas.

Conduct proper chemical waste management to avoid spillage of chemicals during all the phases of the project cycle.


3 1 3 2 3 35 Low


Cumulative impact




Table 5-18: Impacts on the loss of current Land Capability

Impact


Rating Mitigation


Frequency of Impact


2 3 5 5 5 100 High


Although the stockpiles will be re-vegetated, it is not anticipated that areas where arable land capability was lost will be remediated to such an extent that the land capability will return. At most, the site will be rehabilitated to grazing land capability. However, it is still recommended that the natural vegetation be re-established once the coal loading operations have ceased and that the grazing capacity is restored as good as possible. Should the land capability be re-established, the impact after mitigation is considered to be medium-low


2 3 4 4 4 72 Low-

Medium


Cumulative impact



The surface water impact of the construction of the proposed new Rietkuil Private Railway

Siding and associated infrastructure will be limited as the area impacted represents a loss off

catchment of less than 1%, therefore the loss of runoff from this catchment is not likely to

significantly impact flows in the Bosmanspruit. The proposed construction of the proposed

new Rietkuil Private Railway Siding and associated infrastructurewill not impact negatively on

the surface and groundwater quality of the receiving environment. Adequate


environment. These recommendations and mitigation measures form part of the EMPr. It is

anticipated that proposed construction of the proposed new Rietkuil Private Railway Siding

and associated infrastructure will have a ‘Very Low’ to ‘Low-Medium’ impact on the surface

and groundwater post implementation of the recommended mitigation measures. Adequate


environment. These recommendations and mitigation measures form part of the EMPr.

Table 5-19: Surface and Groundwater Related Impacts

Impact


Rating Mitigation


Frequency of Impact

Impact on groundwater quality


4 3 4 5 4 99 Medium-

High


Best practice and good housekeeping


4 2 3 4 4 72 Low-

Medium

Impact on Bosmanspruit



Impact


Rating Mitigation


Frequency of Impact


4 3 4 5 4 99 Medium-

High


Remove seepage with drains, channels, toe paddocks to pollution control dam, contain dirty water and reduce infiltration with stormwater control. Re-use dirty water


2 2 4 5 4 72 Low-

Medium

Change in catchment runoff


2 3 4 4 3 63 Low-

Medium


Separate clean water from dirty water. Divert clean water to natural water courses.


1 2 4 4 3 49 Low

Erosion


2 2 2 4 4 48 Low


Construct gabions to prevent erosion


1 1 2 3 3 24 Very Low

Status (+/-) Low-Medium to Very-Low (-)

Cumulative impact


Heritage

The construction of the proposed new Rietkuil Private Railway Siding and associated

infrastructure will not impact negatively on the cultural, heritage and archaeological nature of

the receiving environment. Adequate recommendations were included in the specialist study

to mitigate impacts on the receiving environment. It is anticipated that construction of the

proposed new Rietkuil Private Railway Siding and associated infrastructure will have a ‘Very

Low’ impact on heritage resources post implementation of the recommended mitigation

measures. Adequate recommendations were included in the specialist study to mitigate

impacts on the receiving environment. These recommendations and mitigation measures

form part of the EMPr.



Table 5-20: Heritage Related Impacts

Impact


Rating Mitigation


Frequency of Impact

Road Construction - Damage to farmhouse


5 2 2 2 3 45 Low


Site 2: Farm homestead and outbuildings

If impact cannot be avoided, mitigation will entail documentation of the structure.

Total figure after mitigation: All direct impact on the structure is avoided

The site is located peripheral


1 2 2 2 1 15 Very Low

Road Construction - Damage to the buildings


5 4 2 2 3 55 Low


Site 4 &5: Farm homestead with dilapidated buildings



1 4 2 2 1 21 Very Low

Road Construction - Damage to kraals


5 3 2 2 3 50 Low


Site 6: Stone

Kraal foundations



1 3 2 2 1 18 Very Low

Road Construction - Damage to graves


5 3 2 2 3 50 Low


Site 7 & 8: Graveyard

Mitigation will entail social consultation, exhumation and reburial



1 3 2 2 1 18 Very Low

Road Construction - Damage to Houses


5 2 2 2 3 45 Low


Site 9: Historical farmstead with outbuildings

If impact cannot be avoided, mitigation will entail documentation of the structure.

Total figure after mitigation: All direct impact on the structure is avoided



Impact


Rating Mitigation


Frequency of Impact



1 2 2 2 1 15 Very Low

Status (+/-) Very-Low (-)

Cumulative impact


Traffic

Based on the findings of the Traffic Impact Assessment conducted for proposed new Rietkuil

Private Railway Siding and associated infrastructure it is evident that the traffic volumes

generated by the proposed Belfast Coal Mine development will not have a significant impact

on the external road network. However, the interaction (turning movements) between public

transport and privates vehicles might impose some safety hazardous to the vehicles drivers.

It is anticipated that the proposed construction of the proposed new Rietkuil Private Railway

Siding and associated infrastructure will have a ‘Low-Medium’ impact on traffic post

implementation of the recommended mitigation measures. Adequate recommendations were

included in the specialist study to mitigate traffic related impacts. These recommendations

and mitigation measures form part of the EMPr.

Table 5-21: Traffic Related Impacts

Impact


Rating Mitigation


Frequency of Impact



4 4 5 5 5 130 Very High


Surfacing of D1110 Road and D1770 Road between the N4 Road / D1110 Road intersection and the access to the Belfast mine approximately 13km.

Ensure that the existing lighting at the intersections of the N4 Road / D1110 Road and N4 Road / P15-1 are at sufficient standards to improve safety.

No on-street pick up/drop off’s at the intersections of the D1110 and D1770 Roads and the access to the mine should be allowed (drop-offs / pickup should be done on site).


2 3 4 1 5 54 Low-

Medium

D1110 / D1770 Intersection


4 4 5 5 5 130 Very High







Impact


Rating Mitigation


Frequency of Impact


2 3 4 1 5 54 Low-

Medium

N4 Road / D1110 Road Intersection (safety)


4 4 5 5 5 130 Very High






2 3 4 1 5 54 Low-

Medium



2 3 4 1 5 54 Low-

Medium






2 3 4 1 5 54 Low-

Medium


Cumulative impact


Noise

The construction of the proposed new Rietkuil Private Railway Siding and associated

infrastructure will not impact negatively on the noise quality of the receiving environment. It is

anticipated that proposed construction of the proposed new Rietkuil Private Railway Siding

and associated infrastructure will have a ‘Very-Low’ to ‘Low’ noise impact post implementation

of the recommended mitigation measures. Adequate recommendations were included in the

specialist study to mitigate impacts on the receiving environment. These recommendations

and mitigation measures form part of the EMPr.



Table 5-22: Noise Related Impacts

Impact


Rating Mitigation


Frequency of Impact

Removal and hauling of top soil from the site


2 3 2 4 2 48 Low


Machinery with low noise levels to be used;

Vehicles with low noise levels to be used;

Construction activities to take place during daytime period only;

Generators must be placed in such a manner that it is away from noise sensitive areas or acoustically screened off;

Baseline noise monitoring (EMPr).


1 2 3 3 1 24 Very-Low

Earthmoving equipment at the foot print area


2 3 2 4 2 48 Low








1 2 3 3 1 24 Very-Low

Hauling of material to and from the specific area


2 3 2 4 2 48 Low








1 2 3 3 1 24 Very-Low

Construction of the pollution control dam and/or structures


2 3 2 4 2 48 Low





Generators must be placed in such a manner that it is away from noise sensitive areas or



Impact


Rating Mitigation


Frequency of Impact

acoustically screened off;



1 2 3 3 1 24 Very-Low

Upgrade of the existing gravel roads between the railway siding and the Belfast


2 3 2 4 2 48 Low








1 2 3 3 1 24 Very-Low

Diesel emergency generators.


2 3 2 4 2 48 Low



Vehicles with low noise levels to be used

Construction activities to take place during daytime period only; and

Generators must be placed in such a manner that it is away from noise sensitive areas or acoustically screened off.

Baseline noise monitoring (EMPr)


1 2 3 3 1 24 Very-Low


Cumulative impact


Socio-economic

It is anticipated that the proposed development will contribute to the local employment market

through the creation of various temporary and permanent employment opportunities. The

proposed development could also contribute to the potential generation of export earnings for

South Africa and contribute towards reducing South Africa’s negative trade balance and

current account deficit, whilst being a source of foreign revenue.

Table 5-23: Creation of Temporary Employment Opportunities

Impact


Rating Mitigation


Frequency of Impact


2 3 2 1 5 42 Low



Impact


Rating Mitigation


Frequency of Impact

No mitigation measures are recommended.


2 1 1 4 1 80 Medium-

High

Status (+/-) Medium-High (+)

Cumulative impact

The cumulative impacts of the construction of the Rietkuil private railway project will result in indirect impacts such as local economic contribution/expenditure and it as a result the impact will be a larger positive impact on the environment that was assessed initially.

Table 5-24: Creation of permanent Employment Opportunities

Impact


Rating Mitigation


Frequency of Impact


2 3 2 1 5 42 Low

No mitigation measures are recommended.


2 1 1 4 1 80 Medium-

High

Status (+/-) Medium-High (+)

Cumulative impact

The cumulative impacts of the construction of the Rietkuil private railway project will result in indirect impacts such as local economic contribution/expenditure and it as a result the impact will be a larger positive impact on the environment that was assessed initially.

5.3.3 Operational phase

In addition to the abovementioned impacts the following additional impacts are anticipated to

occur during the operational phase of the Rietkuil private railway siding project:


Table 5-25: Surface and Groundwater

Impact


Rating Mitigation


Frequency of Impact



2 3 4 4 4 72 Low-

Medium


Compact base, clay lining, remove seepage with drains to pollution control dam, contain dirty water with stormwater control.


1 2 4 4 3 49 Low

Impact on groundwater quality (Leachate seeping from pollution control dam to underlying aquifers)



Impact


Rating Mitigation


Frequency of Impact


2 3 4 4 4 72 Low-

Medium


Line dam with clay/HDPE material. Re-use water in pollution control dam, remove silt to maintain capacity. Groundwater monitoring


1 2 4 4 3 47 Low

Impact on groundwater quality (Leakage of hydrocarbon fuels into underlying aquifers)


4 3 4 5 4 99 Medium-

High


Best practice and good housekeeping


4 2 3 4 4 72 Low-

Medium



4 3 4 5 4 99 Medium-

High


Remove seepage with drains to pollution control dam, contain dirty water and reduce infiltration with stormwater control. Re-use dirty water


4 3 3 1 1 20 Low



4 3 4 5 4 99 Medium-

High


Remove seepage with drains to pollution control dam, contain dirty water and reduce infiltration with stormwater control. Re-use dirty water


2 2 4 5 4 72 Low-

Medium



2 3 4 4 3 63 Low-

Medium


Separate clean water from dirty water. Divert clean water to natural water courses.


1 2 4 4 3 49 Low

Erosion



Impact


Rating Mitigation


Frequency of Impact


2 2 2 4 4 48 Low


Construct gabions to prevent erosion.


1 1 2 3 3 24 Very Low


Cumulative impact


Traffic

Table 5-26: Traffic Related Impacts

Impact


Rating Mitigation


Frequency of Impact



2 3 4 1 5 54

Very High






2 3 4 1 5 54 Low-

Medium

D1110 / D1770 Intersection


2 3 4 1 5 54 Very High






2 3 4 1 5 54 Low-

Medium

N4 Road / D1110 Road Intersection (safety)


2 3 4 1 5 54 Very High



Ensure that the existing lighting at the intersections of the N4 Road / D1110 Road and N4 Road /



Impact


Rating Mitigation


Frequency of Impact

P15-1 are at sufficient standards to improve safety.



2 3 4 1 5 54 Low-

Medium



2 3 4 1 5 54 Low-

Medium






2 3 4 1 5 54 Low-

Medium


Cumulative impact


Noise


Impact


Rating Mitigation


Frequency of Impact

Removal and hauling of top soil from the site


2 2 4 4 3 56 Low-

Medium


Vehicles to comply with the standards as provided in the IFC’s Environmental Health & Safety Regulations.

Earthmoving and hauling vehicles with low noise levels to be used.

Generators must be placed in such a manner that it is away from noise sensitive areas

Conveyor to be screened off.

Maintenance plan in place for regular maintenance of conveyor and electric motors.

Baseline noise monitoring on an annual basis


1 2 3 3 1 24 Very-Low

Earthmoving equipment at the foot print area


2 2 4 4 3 56 Low-

Medium


Vehicles to comply with the standards as provided in the IFC’s Environmental Health & Safety



Impact


Rating Mitigation


Frequency of Impact

Regulations.







1 2 3 3 1 24 Very-Low

Hauling of material to and from the specific area


2 2 4 4 3 56 Low-

Medium









1 2 3 3 1 24 Very-Low



2 2 4 4 3 56 Low-

Medium









1 2 3 3 1 24 Very-Low



2 2 4 4 3 56 Low-

Medium










Impact


Rating Mitigation


Frequency of Impact


1 2 3 3 1 24 Very-Low

Diesel emergency generators


2 2 4 4 3 56 Low-

Medium









1 2 3 3 1 24 Very-Low

Stockpile management


2 2 4 4 3 56 Low-

Medium









1 2 3 3 1 24 Very-Low

Status (+/-) Very Low (-)

Cumulative impact


Air Quality

The construction of proposed new Rietkuil Private Railway Siding and associated

infrastructure will not impact negatively on the air quality of the receiving environment and will

be compliant against the standards and will have a low impact on the closest receptors and

surrounding environment. It is anticipated that construction of the proposed new Rietkuil

Private Railway Siding and associated infrastructure will have a ‘Low’ air quality post

implementation of the recommended mitigation measures. Adequate recommendations were

included in the specialist study to mitigate impacts on the receiving environment. These

recommendations and mitigation measures form part of the EMPr.



Table 5-28: Impacts associated with PM10

Impact


Rating Mitigation


Frequency of Impact


2 1 2 4 2 30 Low-

Medium


In places of high vehicular traffic, dust suppression measures on the roads may be implemented to reduce dust levels from the entrainment of dust. These measures will range from watering of roads, application of a chemical dust suppressant and/or paving of roads.

Reduce vehicle speeds on roads to less than 40 km/hr within the project area.

If possible a chemical dust suppressant should be used to suppress dust emissions on the coal stockpiles if 12% moisture content cannot be maintained over a long period of time to lower dust emissions.


1 1 1 4 1 15 Low


Cumulative impact


Table 5-29: Impacts Associated with Dust Fallout

Impact


Rating Mitigation


Frequency of Impact


2 1 2 4 2 30 Low-

Medium


In places of high vehicular traffic, dust suppression measures on the roads may be implemented to reduce dust levels from the entrainment of dust. These measures will range from watering of roads, application of a chemical dust suppressant and/or paving of roads.


If possible a chemical dust suppressant should be used to suppress dust emissions on the coal stockpiles if 12% moisture content cannot be maintained over a long period of time to lower dust emissions from the handling processes.


1 1 1 4 1 15 Low


Cumulative impact


Table 5-30: Impacts Associated with PM2.5

Impact


Rating Mitigation


Frequency of Impact


2 1 2 4 2 30 Low-

Medium


In places of high vehicular traffic, dust suppression measures on the roads may be implemented to



Impact


Rating Mitigation


Frequency of Impact

reduce dust levels from the entrainment of dust. These measures will range from watering of roads, application of a chemical dust suppressant and/or paving of roads.


If possible a chemical dust suppressant should be used to suppress dust emissions on the coal stockpiles if 12% moisture content cannot be maintained over a long period of time to lower dust emissions.


1 1 1 4 1 15 Low


Cumulative impact


Geochemical

The geochemical study concluded that the proposed coal stockpile will not generate acidic

drainage but rather a neutral drainage. This is because the coal has excess neutralisation

potential in the form of calcite and dolomite that buffers the pH at neutral conditions of 6.7.

However, there is still an expectation that secondary minerals that may have formed as a

result of the oxidation of pyrite and subsequent neutralisation of the acidity may be mobilised

to form a neutral but saline runoff or seepage, depending on the period in which the coal is

retained in the stockpile.

It is anticipated that the proposed new Rietkuil Private Railway Siding and associated

infrastructure will not impact negatively on the geochemical composition of the receiving

environment. In order to mitigate any impacts arising from secondary minerals,

recommendations are included the specialist study contained in Appendix C. These

recommendations and mitigation measures form part of the EMPr. These recommendations

include the following:

Appropriate stockpile management should be enforced at the siding, where the residence

time of the material in stockpile is minimised. Furthermore, stockpile management should

include mechanisms to ensure that the entire volume of material is removed periodically,

rather than retaining a layer at the base of the stockpile which does not get removed. This

will minimise the time period in which pyrite oxidation can occur which in turn should limit

the salinity of runoff and seepage from the stockpiles.

The liners below the stockpile and the PCD should be engineered in a manner to ensure

that the potential permeability through the liners is minimised with runoff and seepage

flow into the PCD maximised.

The stockpiles and PCD should be operated in a manner to ensure that the integrity of

the liners included in the design is maintained and regular monitoring of the integrity of

the liners is undertaken.

The level in the PCD should be maintained to ensure that there is adequate flood buffer

zone in the facility to store the design flood event without overtopping as the quality of

water in the PCD is likely to be saline.

If the PCD water is used for dust suppression as intended, then spraying should only

occur on areas lined to minimise the potential of the salinization of the soils not covered

by liners.

The concentrations of the constituents of concern, Ca, Cl, TDS and Zn, should be

monitored as a minimum analytical suite.



5.3.4 Decommissioning / Rehabilitation phase

In addition to the abovementioned impacts the following additional impacts are anticipated to

occur during the decommissioning/rehabilitation phase of the Rietkuil private railway siding

project:


Table 5-31: Impacts associated with Soil Compaction

Impact


Rating Mitigation


Frequency of Impact


5 4 4 3 5 108 High


When stripping machinery is used for stripping, stockpiling and ‘topsoiling’ operations, it should operate when the soil moisture content is below approximately 8 % (during the dry winter months) in order to limit soil compaction and machinery getting stuck.

For use on site, tracked vehicles are more desirable than wheeled vehicles due to their lower point loading and slip, while vehicle speed should be maintained in order to reduce the duration of applied pressure, thereby minimizing compaction.

The width of the levelled or disturbed area for haul roads must be minimized as much as possible. Unnecessary dirt tracks (outside of the area to be disturbed) should be avoided during the construction of the haul road.

Impact beyond the site boundary can be reduced by using existing roads and reducing new roads to a minimum.


2 3 5 4 4 80 Medium-

High

Status (+/-) Medium-High (-)

Cumulative impact



Table 5-32: Surface and Groundwater Related Impacts

Impact


Rating Mitigation



Frequency of Impact



2 3 4 4 3 2 Low-

Medium


Ensure that all coal removed from site prior to removal of liner. Liner to be removed in a manner where efflorescence that may have formed on the liners is not released to the environment


3 2 2 1 3 28 Low

Impact on groundwater quality


3 4 3 2 4 3 Low-

Medium


Evaporate surplus water in the dam, prior to decommissioning. Once dry, remove accumulated



Impact


Rating Mitigation



Frequency of Impact

sediments prior to liner removal.


2 2 3 2 3 35 Low



3 2 2 2 3 3 Low


Phase closure to ensure that contact water can be separated from non-contact water and contact water contained during all phases.


2 2 2 2 3 30 Low



3 3 1 1 3 3 Low


Phase closure to ensure that contact water can be separated from non-contact water and contact water contained during all phases.


2 1 1 1 3 16 Very Low



1 3 4 1 3 1 Low


Rehabilitation of site


1 1 1 1 2 9 Very Low

Status (+/-) Very Low - Low (-)

Cumulative impact


Noise


Impact


Rating Mitigation



Frequency of Impact

Rehabilitation of railway siding


2 2 4 4 3 56 Low-

Medium





Impact


Rating Mitigation



Frequency of Impact


1 2 4 4 2 42 Low

Demolition of plant and infra-structure


2 2 4 4 3 56 Low-

Medium




1 2 4 4 2 42 Low

Diesel emergency generators


2 2 4 4 3 56 Low-

Medium




1 2 4 4 2 42 Low


Cumulative impact


5.4 Uncertainties, assumptions and gaps in knowledge

This section provides a description of the assumptions, risks, and gaps in knowledge

associate with the proposed project. Assumptions made by the specialist during their

assessments are detailed in the section.

5.4.1 Uncertainties

No uncertainties were encountered on this project.

5.4.2 Assumptions

Various assumptions were made when compiling this report including:

The scope of work, methodologies and databases provided in the original Terms of

Reference (ToR) were updated and revised to be applicable to site specific conditions

and methodologies were employed according to best record the fauna and flora

assemblages, habitat integrity and wetlands on-site. However, all ecological parameters

on-site are considered to have been accurately recorded and sufficient ecological

baseline data was gathered to inform the impact assessment.

With conservation databases being regularly updated, other databases than those

indicated in the ToR may have been utilised during the study in order to ensure that the

most recent data informed the assessment.



The ecological assessment is confined to the study area and does not include the

neighbouring and adjacent properties; these were however considered as part of the

desktop assessment;

Due to the nature and habits of most faunal taxa it is unlikely that all species would have

been observed during a site assessment of limited duration. Therefore, site observations

are compared with literature studies where necessary;

With ecology being dynamic and complex, some aspects (some of which may be

important) may have been overlooked. It is, however, expected that most faunal and floral

communities have been accurately assessed and considered;

Sampling by its nature, means that not all individuals are assessed and identified. Some

species and taxa on the study area may therefore been missed during the assessment;

The wetland assessment is confined to the study area, as well as areas of relevance

immediately adjacent to the study area and does not include the neighbouring and

adjacent properties. The general surroundings were however considered in the desktop

assessment of the study area;

The wetland delineation as presented in this report is regarded as a best estimate of the

wetland boundary based on the site condition present at the time of the assessment and

limitations in the accuracy of the delineation due to disturbances created by grazing,

existing development and anthropogenic disturbances are deemed possible; and

Wetland and terrestrial areas form transitional areas where an ecotone is formed as

vegetation species change from terrestrial species to facultative and obligate wetland

species. Within the transition zone some variation of opinion on the wetland boundary

may occur, however if the Department of Water and Sanitation (DWS), 2005 method is

followed, all assessors should get largely similar results.

All the technical data and information provided by the proponent to the EAP and

specialists are accurate and up-to-date. The EAP and specialists have identified all

possible impacts based on the information provided and these have been assessed and

rated accordingly.

The public involvement process has been sufficiently effective in identifying the critical

issues that needed to be addressed through specialist investigations and/or by the EAP.

Specialist input has thus been appropriately scoped to investigate the critical issues.

The public involvement process has sought to involve key stakeholders and individual

landowners. It is assumed that where participation has been sought from the

organizational representative/s, that these parties have the authority to comment on

behalf of their organisation.

The stakeholder engagement process provided ample opportunity for stakeholders to

express any issues and concerns. It has thus been effective in identifying critical issues

that the specialist investigations and/or EAP needed to address.

All comments received from the authorities are informed and considered.

Exxaro and its contractors will implement the measures contained in the EMPr.

A monitoring and evaluation system, including auditing, will be established to track the

implementation of the EMPr to ensure that management measures are effective to avoid,

minimize and mitigate impacts; and that corrective action is being undertaken to address

shortcomings and/or non-performances.

Exxaro will adopt a process of continual improvement when managing and/or mitigating

negative environmental impacts arising from the project. The EMPr will be used as the

basis of environmental management and will be improved and refined regularly.



The monitoring required of the project will determine the validity and accuracy of the

predictions made. Any exceedance of parameters or complaints from stakeholders will

be investigated and remedied by the Exxaro when required to do so.

5.4.3 Gaps in knowledge

A number of the specialist studies undertaken make use of various predictive methods to

determine the extent and likely area of influence of their particular impacts. These studies

were undertaken by specialists in their fields using the best available technology. The

specialist’s opinions and the data provided in the current report are based on professional

opinion with the most conservative approach been taken. Thus the predictions and ratings of

impacts are unlikely to change or their impact increase.

5.4.4 Risks

While the development has been designed to significantly minimize risk through

implementation of the latest international technology using best practice industry standards,

the possibility of incidents resulting in fire, explosions and contamination of soil, surface and

groundwater cannot be ruled out.

6 Environmental Management Programme

6.1 Background

The purpose of the EMPr is to ensure that social and environmental impacts, risks and

liabilities identified during the EIA process are effectively managed during the construction,

operations and closure of the proposed new Rietkuil Private Railway Siding and associated

infrastructure. The EMPr specifies the mitigation and management measures to which

Exxaro is committed to and shows how the project will mobilise organizational capacity and

resources to implement these measures. It also shows how management measures aimed at

mitigation and enhancement will be scheduled.

In order to comply with the requirements of Regulation 31(2) (p) of GN R543 of 18 June 2010

an EMPr has been compiled as part of the EIAr. The content of the EMPr is structured in

such a way as to comply with the requirements of Regulation 33 of GN R543 of 18 June

2010.

6.2 Objectives of the EMPr

The key objectives of the EMPr are to:

Formalize and disclose the programme for environmental and social management;

Ensure that appropriate management and mitigation measures and requirements are

implemented from the start of the project;

Ensure compliance to environmental legislation;

Manage identified impacts;

Ensure precautions against damage and claims arising from damage are taken timeously;

Provide a framework for the implementation of environmental and social management

initiatives.

Best practice principles require that every reasonable effort be made to reduce and preferably

to prevent negative impacts, while enhancing positive benefits, especially within the



communities most directly affected by the proposed project. These principles have guided

the EIA process and the compilation of the EMPr.

The EMPr covers information on the management and mitigation measures that will be

implemented to address impacts in respect of:

Planning;

Construction;

Operation;

Rehabilitation;

Decommissioning;

Impact statement.

6.3 Approach to the EMPr

The responsibility of the EMPr implementation will ultimately reside with Exxaro. Table 6-1

illustrates the range of approaches used in the compilation of the EMPr in order to manage

potential impacts associated with the project activities.

Table 6-1: Approach to Impact Management

Avoidance Avoiding activities that could result in adverse impacts and/or resources or areas considered sensitive

Prevention Preventing the occurrence of negative environmental impacts and/or preventing such an occurrence having negative impacts

Preservation Preventing any future actions that might adversely affect an environmental resource

Minimization Limiting or reducing the degree, extent, magnitude or duration of adverse impacts through scaling down, relocating, redesigning and/or realigning elements of the project

Mitigation Measures taken to minimize adverse impacts on the environment

Enhancement Magnifying and/or improving the positive effects or benefits of a project

Rehabilitation Repairing affected resources, such as natural habitats or water resources

Restoration Restoring affected resources to an earlier (possibly more stable and productive) state, typically ‘background’ or ‘pristine’ condition

Compensation Compensating for lost resources, and where possible, the creation, enhancement or protection of the same type of resource at another suitable and acceptable location

6.4 Implementation of the EMPr

The full EMPr is presented in Appendix E. This document includes the roles and

responsibilities of all the role players during the different phases of the proposed new Rietkuil

Private Railway Siding and associated infrastructure.

Role players in the implementation of the EMPr management and mitigation measures

include:

Exxaro project management team;

Project implementers;

Contractors;

Environmental Control Officer (for construction phase).

6.5 Rehabilitation and Closure

The purpose of the rehabilitation plan is that it describes the activities associated with the

rehabilitation of the siding footprint and give guidelines on how rehabilitation must be



implemented to achieve the rehabilitation objectives, including infrastructure demolition, once

the siding is no longer required to support the proposed Belfast Coal Mine. This document

presents the rehabilitation plan for the site during the decommissioning of the siding.

Adequate recommendations were included in the specialist study to mitigate impacts on the

receiving environment. The ‘Rehabilitation and Closure Plan’ forms part of the EMPr for this

project and contained in Appendix E.

7 Public Participation Stakeholder engagement is the involvement of all parties who potentially have an interest in a

development or project, or may be directly or indirectly affected by the proposed

development. It is a process leading to a joint effort by stakeholders, technical specialists, the

authorities and the proponent/developer who work together to produce better decisions than if

they had acted independently.

The approach followed during PPP is focused on:

Obtaining most issues, including those from stakeholders early on in the process, with the

latter half of the process designed to provide environmental and technical evaluation of

these issues;

Personal contact with directly affected I&APs;

Raising a diversity of perspectives and opinions rather than forcing consensus among

I&APs. This approach also minimises project risks by building trust with I&APs;

Building capacity of I&APs to participate;

Clarifying I&APs roles and responsibilities at the start of the process, sanctioned by the

authorities, in terms of where and when a decision will be made and by whom.

The stakeholder engagement process is primarily aimed at affording I&APs the opportunity to

gain an understanding of the proposed project and the EIA process required for the EA

application. In addition, the purpose of consultation with the I&APs is to provide them with the

necessary information about the proposed project, in order for them to be able to make

informed decisions, as to whether the project could potentially affect them, and if so, to which

extent it could potentially affect them.

The objectives of the stakeholder engagement process include the following:

Obtaining issues, including those from stakeholders, early on in the process, with the

latter half of the process designed to provide environmental and technical evaluation of

these issues;

Commenting on the findings of the environmental assessment and proposed mitigation

measures;

Building capacity of I&APs in order for them to participate meaningfully;

Clarifying I&APs’ roles and responsibilities at the start of the process, sanctioned by the

authorities, in terms of where and when decisions will be made and by whom;

Verifying that stakeholder issues have been recorded, understood and interpreted

correctly;

Contributing relevant local and traditional knowledge towards the environmental

assessment.

The key steps and broad timeframes of the stakeholder engagement activities in each phase

of the environmental authorisation application process is outlined in Figure 7-1.



BRPM PROPOSED TAILINGS STORAGE FACILITY AND ASSOCIATED INFRASTRUCTURE

EA and Associated Stakeholder Engagement Process

Project No.

470328

Figure 7-1: Environmental Authorisation and Associated Stakeholder Engagement Process.

7.1 Methodology

7.1.1 Identification of I&APs

The NEMA Regulations, GN R543 of 18 June 2010, require the identification of and

consultation with communities and I&APs.

In terms of Section 24 O(2) of NEMA specific organs of state (state departments) were

identified and recognised as commenting authorities on aspects of this application for EA.

Representatives from these organs of state are included in the stakeholder database.

The SRK stakeholder engagement office started the PPP by utilising an existing database

linked to existing Exxaro stakeholder engagement processes. These existing stakeholder

details were verified and incorporated into the I&AP database developed for the proposed

project. This I&AP database contains a broad spectrum of sectors of society in and around

the proposed project area of the Mpumalanga Province. Representatives of groups were

informed on the proposed project and invited to participate in the PPP.

Directly affected and adjacent land-owners were identified by means of title deeds and

Geographic Information Systems search on the properties adjacent to and within the

proposed project. Contact details of existing contacts were further telephonically verified and

personally invited to attend the introductory public meeting.

These I&APs include, but not limited to:

The owners and occupiers of land within 100 metres of the boundary of the proposed site;



Adjacent land owners and occupiers;

Government organisations;

Municipal departments;

Local and district municipalities:

Non-governmental organizations, research and conservation groups;

Stakeholders;

Relevant national and provincial governmental officials;

Ward councillors.

Further, the NEMA Regulations, GN R543 of 18 June 2010 distinguishes between I&APs and

registered I&APs. For those purposes a I&AP register was opened, maintained and updated

as new I&AP register requests are received. This I&AP register contains names of all I&APs

that requested to be registered as I&AP for this project, including the details of the organs of

state Appendix D.

7.1.2 Announcement Phase

The opportunity to participate in the proposed new Rietkuil Private Railway Siding and

associated infrastructure and to register as an I&AP was announced on 31 January 2014.

This section presents the methods used to notify the I&AP and to solicit I&AP participation

and comment.

Site notices

Notice boards were fixed at places conspicuous to the public as listed in Table 7-1. A copy

and proof of placement of the site notices can be found in Appendix D.

Table 7-1: List and Location of the Site Notices placed for the proposed Project

Site Notice

Location Coordinates

Latitude Longitude

On-site site notices

1 Western edge of the siding and PCD 25.922161 S 27.766262 E

2 Coal loading facility 25.919747 S 29.772073 E

3 Beginning of alternative balloon 25.915798 S 29.781229 E

4 Rietkuil Public Library 25.945942 S 29.805630 E

5 Intersection of the N 4 and D 1110 25.812220 S 29.907949 E

6 Along the D 1110 25.955300 S 29.955297 E

7 Intersection of the D 1110 and D 1770 25.855623 S 29.962928 E

8 Along the D 1770 25.840091 S 29.974465 E

Public places where site notices were placed

9 Belfast Public Library 25.692582 S 30.034623 E

10 Middleburg Public Library 25.773431 S 29.455778 E

11 Emakhazeni Local Municipality 25.692994 S 30. 034911 E

12 Steve Tshwete Local Municipality 25.833300 S 29. 583300 E

13 Nkangala District Municipality 25.783588 S 29.441795 E

Advertising

An advertisement was placed in the Mpumalanga News and Lowvelder on 30 and 31 January

2014 respectively to inform I&APs of the proposed development and to solicit I&AP

participation and comment. A copy of the newspaper advert can be found in Appendix D.



Background Information Document, letter of invitation to register as a I&AP

Potentially affected landowners were notified of the proposed project prior to the submission

of the application form to the MDARDLEA. A cover letter, Background Information Document

(BID) as well as a response form was circulated to I&APs identified at the start of the project.

The BID aimed to inform the public of the proposed project and also provided I&APs with an

opportunity to raise issues of concern, for which a response sheet was included. BIDs were

further placed at the Middleburg, Rietkuil and Belfast public libraries. A copy of the BID can

be found in Appendix D.

Public Meeting / Public Open day

An introductory public meeting was held at the Belfast Golf club at 14H00 on Wednesday, 26

February 2014. I&APs were notified of the time, date and location of the public meeting in the

BID, newspaper adverts, site notices and invitation letters sent during the announcement

phase of the project. Draft minutes of the public meeting are included in this report for review

to ensure their comments were captured and then final minutes will be distributed to

attendees for review, if requested, to ensure their comments were captured. A copy of the

minutes of this meeting can be found in Appendix D.

Authorities’ Meeting

An authorities meeting with MDARDLEA was held on 14 May 2014 at the Exxaro Belfast

office. A presentation was presented to all the participants to illustrate the propose project

and the way forward regard Appendix D. The recommendations made during this meeting

were implemented during the impact assessment phase of this project.

7.1.3 Scoping Phase

Notification and consultation with I&APs

This section presents the methods used to notify the I&AP of the availability of the Draft and

Final Scoping Report/s and to solicit I&AP participation and comment on these reports and a

copy of this notification letter is contained Appendix D.

A notification letter was sent to all registered I&APs, offering them the opportunity to

review and comment on the Scoping Report/s. This notification letter also stated that

copies of the report/s was available on request and it listed the public places (same

places used during announcement phase of the project) where the Scoping Report/s was

available for perusal and comment;

The notification letter was sent to registered I&APs by means of their preferred way of

correspondence (sms, post, e-mail or fax);

The Scoping Report/s was placed d and the notification letter will be made available on

the SRK website (www.srk.co.za).



Review of documents

A 40 day commenting period was allowed for public review of the Draft Scoping Report (14

March 2014 to 25 April 2014) and a 21 day commenting period was allowed for public review

of the Final Scoping Report (16 May 2014 to 5 June 2014). Comment/s on the Final Scoping

Report was done by means of:

Written comment, including e-mail or by completing a comment sheet accompanying the

report and mailing, e-mailing or faxing it to the stakeholder engagement office; and

Verbal comment received during the public meeting that was held in the project area.

Copies of all correspondence with I&APs can be found in Appendix D.

7.1.4 Impact Assessment Phase

Notification and consultation with I&APs

This section presents the methods that will be used to notify I&AP of the availability of the

Draft EIAr and to solicit I&AP participation and comment this report and a copy of this

notification letter is contained Appendix D. The availability of the Draft EIAr will be announced

by means of:

A notification letter sent to all registered I&APs, offering them the opportunity to review

and comment on the Draft EIAr. This notification letter will state that copies of the

report/s are available on request and it will list the public places (same places used during

announcement phase of the project) where the Draft EIAr are available for perusal and

comment;

The notification letter will be sent to registered I&APs by means of their preferred way of

correspondence (sms, post, e-mail or fax);

The notification letter and the Draft EIAr will be made available on the SRK website

(www.srk.co.za).

As part of the notification letter I&APs will be of the public meeting scheduled to take place to

discuss the findings of the specialist studies conducted.

Public Meeting

A public meeting took place at the Belfast Golf club at 14:00 on 30 September 2014. All

registered I&APs were informed of this public meeting via e-mail notices. No members of the

public attended the public meeting. A copy of the presentation prepared for this meeting are

appended to the Draft EIAr and will were circulated to all registered I&APs.

Review of documents

A 40 day commenting period will be allowed for public review of the Draft EIAr. The public

comment period is from 21 October 2014 until 01 December 2014. Comment/s on the Draft

EIAr can be done by means of the following:

Written comment, including e-mail or by completing a comment sheet accompanying the

report and mailing, e-mailing or faxing it to the stakeholder engagement office; and

Verbal comment during the public meeting to be held in the project area.

Copies of all correspondence with I&APs can be found in Appendix D.

Once the commenting period on the draft EIAr concluded all comments/responses received

will be included in the Final EIAr and the Final EIAr will be made available to the I&APs again

for their perusal.

http://www.srk.co.za/



7.1.5 Comments and Responses

As stated above, copies of all correspondence with I&APs can be found in Appendix D. The

main issues raised during the public participation process relates to:

Requests to be kept up to date on the progress at the railway siding permitting;

Commenting on documents;

Timeframes for the NEMA EIA application process;

Ensuring that the Catchment Management Agencies are involved in the environmental

authorisation process;

The applicability of the NWA requirements;

Water uses associated with the PCD;

Data collection from weather stations;

Air pollution and traffic issues;

That the proposed haul road extends from the siding through the Celia Private Nature

Reserve on the farm Wonderfontein and then to Blyvooruitzight next to Zoekop that lies in

the proposed Steenkampsberg Wet Grassland Protected Environment;

Blockages and safety issues concerning the N 4;

The affected farm portions where the proposed Belfast Coal Mine operations would be

situated and whether any authorisations were granted for it to take place;

The fact that an appeal was lodged against the decision to grant authorisation for the

proposed construction of the proposed Belfast Coal Mine;

A request that a copy of the mining rights granted;

For which mine is this application.

Further, all comments received and issues raised to date are captured in the Comments and

Response Report (CRR). A copy of the CRR can be found in Appendix D.



7.2 Actions taken during the Public Participation Process

Table 7-2: Actions Taken during Public Participation Process

GN R. 543 Action required Action taken Dates

54(2)(a) Fixing a notice board at a place conspicuous to the public at the boundary or on the fence of—

The site where the activity to which the application relates is or is to be undertaken; and

Any alternative site mentioned in the application;

Announcement Phase:

Thirteen (13) site notices site notices, announcing the application for EA were placed at the following locations:

Western edge of the siding and PCD

Coal loading facility;

Beginning of alternative balloon;

Rietkuil Public Library;

Intersection of the N 4 and D 1110;

Along the D 1110;

Intersection of the D 1110 and D 1770;

Along the D 1770;

Belfast Public Library;

Middleburg Public Library;

Emakhazeni Local Municipality;

Steve Tshwete Local Municipality;

Nkangala District Municipality.

Appended to this report as Appendix D

2014/01/31

54(2)(b) Giving written notice to -

54(2)(b)(i) The owner or person in control of that land if the applicant is not the owner or person in control of the land;

The applicant 2014/01/31

54(2)(b)(ii) The occupiers of the site where the activity is or is to be undertaken or to any alternative site where the activity is to be undertaken;

The occupiers of land within 100 metres of the boundary of the proposed site

2014/01/31

54(2)(b)(iii) Owners and occupiers of land adjacent to the site where the activity is or is to be undertaken or to any alternative site where the activity is to be undertaken;

The owners of land and occupiers within 100 metres of the boundary of the proposed site

2014/01/31




54(2)(b)(iv) The municipal councillor of the ward in which the site or alternative site is situated and any organisation of ratepayers that represent the community in the area;

Municipal departments

Local and district municipalities;

Ward councillors

2014/01/31

54(2)(b)(v) The municipality which has jurisdiction in the area Municipal departments;

District and Local Municipalities;

Ward councillors.

2014/01/31

54(2)(b)(vi) Any organ of state having jurisdiction in respect of any aspect of the activity; and

Government organisations;

Non-governmental organizations, research and conservation groups;

Relevant national and provincial governmental officials.

2014/01/31

54(2)(b)(vii) Any other party as required by the competent authority Non-governmental organizations, research and conservation groups

2014/01/31

54(2)(c) Placing an advertisement in—

(i) one local newspaper; or

(ii) any official gazette that is published specifically for the purpose of providing public notice of applications or other submissions made in terms of these regulations

Lowvelder


2014/01/31

54(2)(d) Placing an advertisement in at least one provincial newspaper or national newspaper, if the activity has or may have an impact that extends beyond the boundaries of the metropolitan or local municipality in which it is or will be undertaken: Provided that this paragraph need not be complied with if an advertisement has been placed in an official Gazette referred to in [sub-regulation (c)(ii)] paragraph (c)(ii); and

Mpumalanga News


2014/01/30

54(2)(e) Using reasonable alternative methods, as agreed to by the competent authority, in those instances where a person is desiring of but unable to participate in the process due to—

(i) illiteracy;

(ii) disability; or

(iii) any other disadvantage.

N/A

54(3) A notice, notice board or advertisement referred to in sub regulation (2) must—

Notice boards, complying with these requirements, were placed, a copy of the notice boards can be found in

2014/01/31




(a) give details of the application which is subjected to public participation; and

(b) state—

(i) that the application has been submitted to the competent authority in terms of these Regulations[, as the case may be];

(ii) whether basic assessment or scoping procedures are being applied to the application, in the case of an application for environmental authorisation;

(iii) the nature and location of the activity to which the application relates;

(iv) where further information on the application or activity can be obtained; and

(vi) The manner in which and the person to whom representations in respect of the application may be made.

Appendix D.

54(4) A notice board referred to in sub-regulation (2) must—

(a) be of a size at least 60cm by 42cm; and

(b) display the required information in lettering and in a format as may be determined by the competent authority

Notice boards, complying with these requirements, were placed, a copy of the notice boards can be found in Appendix D.

2014/01/31

54(5) Where deviation from sub-regulation (2) may be appropriate, the person conducting the public participation process may deviate from the requirements of that sub-regulation to the extent and in the manner as may be agreed to by the competent authority.

N/A

54(6) Where a basic assessment report, scoping report or environmental impact assessment report as contemplated in regulations 22, 28 and 31 respectively is amended because it has been rejected or because of a request for additional information by the competent authority, and such amended report contains new information, the amended basic assessment report, scoping report or environmental impact assessment report must be subjected to the processes contemplated in regulations 21, 27 and 31, as the case may be, on the understanding that the application form need not be resubmitted

N/A.

No reports were rejected to date as the reports submitted to the Competent Authority complied with the minimum legal requirements.

54(7) When complying with this regulation, the person conducting All information are being available to potential interested and affected parties and are encouraged to take part in

2014/03/14 (Draft




the public participation process must ensure that—

(a) information containing all relevant facts in respect of the application is made available to potential interested and affected parties; and

(b) Participation by potential interested and affected parties is facilitated in such a manner that all potential interested and affected parties are provided with a reasonable opportunity to comment on the application.

the PPP


Scoping Report)

2014/05/16 (Final Scoping Report)

2014/10/20 (Draft EIAr)

54(8) Unless justified by exceptional circumstances, as agreed to by the competent authority, the applicant and EAP managing the environmental assessment process must refrain from conducting any public participation process during the period of 15 December to 2 January.

N/A

55(1) An EAP managing an application must open and maintain a register which contains the names, contact details and addresses of—

(a) all persons who, as a consequence of the public participation process conducted in respect of that application in terms of regulation 54, have submitted written comments or attended meetings with the applicant or EAP;

(b) all persons who, after completion of the public participation process referred to in paragraph (a), have requested the applicant or the EAP managing the application, in writing, for their names to be placed on the register; and

(c) All organs of state which have jurisdiction in respect of the activity to which the application relates.

An I&AP register was opened and is updated as new requests for I&AP registrations are received.


Ongoing

56(1) A registered interested and affected party is entitled to comment, in writing, on all written submissions, including draft reports made to the competent authority by the applicant or the EAP managing an application, and to bring to the attention of the competent authority any issues which that party believes may be of significance to the consideration of the application, provided that—

(a) comments are submitted within—

(i) the timeframes that have been approved or set by the competent authority; or

The I&APs were notified of the availability of the Draft Scoping Report for comment;

The I&APs were notified of the availability of the Final Scoping Report for comment;

The I&APs will be notified of the availability of the Draft EIAr for comment.


2014/03/14

2014/05/16

2014/10/20 (Draft EIAr)




(ii) any extension of a timeframe agreed to by the applicant or EAP;

(b) a copy of comments submitted directly to the competent authority is served on the EAP; and

(c) the interested and affected party discloses any direct business, financial, personal or other interest which that party may have in the approval or refusal of the application

56(2) Before the EAP managing an application for environmental authorisation submits a final report compiled in terms of these Regulations to the competent authority, the EAP must give registered interested and affected parties access to, and an opportunity to comment on the report in writing.

The Draft Scoping Report was made available for a 40 day commenting period;

The Final Scoping Report was made available for a 21 day commenting period.


2014/03/14

2014/05/16

56(3) and (4)

The draft versions of reports referred to in sub regulation (3) must be submitted to the competent authority prior to awarding registered interested and affected parties an opportunity to comment

The Draft Scoping Report was made available for a 40 day commenting period;

The Draft EIAr will be made available for a 40 day commenting period


2014/03/14

2014/10/20 (Draft EIAr)

56(5) Registered interested and affected parties must submit comments on draft reports contemplated in sub regulation (4) to the EAP, who should record it in accordance with regulations 21, 28 or 31


57(1)(6) The EAP managing an application for environmental authorisation must ensure that the comments of interested and affected parties are recorded in reports and that such written comments, including records of meetings, are attached to the report, submitted to the competent authority in terms of these Regulations




8 Conclusions and Recommendations

8.1 Summary of Key Findings

The construction and operation of the proposed new Rietkuil Private Railway Siding would enable

Exxaro to increase their coal exports via the RBCT. It could potentially generate export earnings for

South Africa and contribute towards reducing South Africa’s negative trade balance and current

account deficit, whilst being a source of foreign revenue.

Based on site observations, specialist studies and the impact assessment, the EAP was able to

conclude the following:

There are no environmental fatal flaws that should prevent the construction and operation of the

proposed new Rietkuil Private Railway Siding and associated infrastructure from proceeding;

The proposed new Rietkuil Private Railway Siding and associated infrastructure will remain

within existing disturbed areas/footprints within a disturbed and transformed area characterised

by mining and agricultural activities;

There will be no significant negative environmental impacts arising from proposed project

activities

All identified impacts can be adequately mitigated and managed (Appendix E);

Mitigation measures contained in the EMPr contained in Appendix E are implemented and

auditable;

Additional impacts sustained during the construction phase will not result in a more significant

cumulative impact to the environment if mitigation measures suggested in this Draft EIAr are

implemented

8.2 Environmental Impact Statement

Based on the nature and extent of the proposed project, the local level of disturbance predicted as a

result of the construction and operation of the private railway siding and associated infrastructure,

the findings of the Environmental Impact Assessment, and the understanding of potential

environmental impacts. It is evident that the application for Environmental Authorisation for the

proposed construction of the private railway siding and associated infrastructure can be mitigated to

an acceptable level.

The preferred railway siding alternative is considered to be the only reasonable and feasible

alternative from an environmental perspective. It is recommended that authorisation be granted for

the construction of a linear railway siding as it will comprise of a loading and run around railway line

parallel to the existing rail network in a disturbed and transformed area with no environmental

sensitivities.

The following conditions should be included within an authorisation issued for the project:

The Draft EMPr as contained within Appendix E of this report must be included to form part of

the Conditions of Authorisation should the EA be granted;

The Draft EMPr as contained within Appendix E of this report should form part of all contract with

the Contractors appointed to construct the proposed new Rietkuil Private Railway Siding and

associated infrastructure;

The Draft EMPr as contained within Appendix E of this report must be used to ensure

compliance with environmental specifications and management measures;



The Draft EMPr as contained within Appendix E of this report must be regarded as a living

document and must be amended and submitted to the competent authority as the need arises

prior to any amendments being reflected;

An independent Environmental Control Officer (ECO) must be appointed to ensure that the

mitigation measures contained in the EMPr are implemented and adhered to;

Applications for all other relevant and required permits/licences/agreements must be finalised

and the necessary approvals/authorisations be obtained from the relevant regulating authorities

prior to the commencement of any construction activities;

The construction area must be ground-truthed prior to the commencement of any construction

activities to ensure that the construction site/s are demarcated and that any unnecessary

disturbance to habitats must be kept to a minimum;

All ‘no-go’ areas identified by the independent ECO must be demarcated with temporary

permeable fencing to ensure that no activities extend into the ‘no-go’ areas;

No activities are allowed to take place in the ‘no-go’ areas, this includes the erection of

temporary site camps;

All camp sites must be demarcated and no open fires are permitted on site;

All areas designated for cooking purposes during the construction phase of the proposed

development must be approved by the independent ECO;

All batching must take place on non-permeable sheeting to avoid leaching into the receiving

environment;

No batching are permitted to take place within 32m of a stream, wetland or watercourse;

All upgrades associated with the haul roads and access roads must not extend beyond the road

reserves;

All areas disturbed during the construction phase must be rehabilitated as per the rehabilitation

and closure plan that forms part of the EMPr and an on-going monitoring programme should be

established to detect and quantify any alien species.

Prepared by

Toinette van der Merwe/Manda Hinsch

Environmental Scientists



Reviewed by

Manda Hinsch Pr. Sci Nat

Associate Partner/ Principal Scientist

Darryll Killian

Partner

All data used as source material plus the text, tables, figures, and attachments of this document

have been reviewed and prepared in accordance with generally accepted professional engineering

and environmental practices.



10 Bibliography

Acocks, J. P. H., 1988 . Veld Types of South Africa. Memoirs of the Botanical Survey of South Africa

No. 57, Botanical Research Institute, RSA. Third Edition ed. s.l.:s.n.

Eberhard, A., 2011. The Future of South African Coal: Market, Investment and Policy Challenges,

Cape Town: Freeman Spogli Institute For International Studies.

Emakhazeni Local Municipality , 2012. Integrated Development Plan, s.l.: Emakhazeni Local

Municipality .

Ferret Mining and Environmental Services, 2004. Arnot Colliery Environmental Management

Program Report - Leeuwpan 494 JS: Addendum to Mining License No. 1/2001 Report No. 06/09/04,

September 2004, s.l.: s.n.

Golder Associates, 2012. Hydrogeological Specialist Study to Support Consolidated EMP. Report

Number 10613233-11481-2, s.l.: s.n.

IUCN, 2013. The IUCN Red List of Threatened Species, s.l.: IUCN.

Kotze, D. et al., 2008. WET-EcoServices: A technique for rapidly assessing ecosystem services

supplied by wetlands. WRC Report No. TT 339/09, Pretoria: Water Research Commission.

Low & Rebelo , 1998. Vegetation of South Africa, Lesotho and Swaziland. Department of

Environmental Affairs & Tourism, Pretoria. s.l.:s.n.

Marsh (Pty) Ltd, 2010. Exxaro Coal Mpumalanga (Pty) Ltd – Revised Environmental Management

Programme Report (EMPR) Submitted in Support of a Mining Right Application in terms of the

Minerals and Petroleum Resources Development Act, Act 28 of 2002, Johannesburg: Marsh (Pty)

Ltd.

Middleton, B. & Bailey, A., 2011. Water resources of South Africa, 2005 STUDY (WR2005) - 2011

Update:, Pretoria: South African Watr.

Mpumalanga Department of Agriculture, C. a. E., 2003. Mpumalanga State of the Environment

Report, s.l.: s.n.

Mucina, L. & Rutherford, M., 2006. The Vegetation of Souoth Africa, Lesotho and Swaziland..

Pretoria: South African National Biodiveristy Institute.

Nkangala District Municipality, 2011. Integrated Development Plan, Middleburg: Nkangala District

Municipality.

Ollis, D. J. S. C. D. J. N. M. &. M. N., 2013. Classification System for Wetlands and other Aquatic

Ecosystems in SOuth Africa. User Manual: Inland Systems. Pretoria: SANBI Biodiversity Series 22.,

s.l.: South African Biodiversity Institute.

Pinetown, K. & Boer, R., 2004. A Quantitative Evaluation of the Modal Distribution of Minerals in

Coal Deposits in the Highveld Area and the Associated Impact on the Geneartion of Acid and

Neutral Mine Drainage. Project No. 1264:, s.l.: s.n.



SRK Consulting, 2014. Final Scoping Report, s.l.: s.n.

Steve Tshwete Local Muicipality, 2012. Integrated Development Plan 2012/2017, Middleburg:

Integrated Development Plan.

Vermeulen, D., Cruywagen, L. M., & Steyl, G., 2011. ABA and Kinetic Cells Report for Middelburg

Mine. University of the Free State, Institute for Groundwater Studies. Bloomfontein: Report No.

2011/12/PDV., s.l.: s.n.

Wates, M. a. B. (., 1996. Number 08 Shaft: Arnot Colliery Surface Water and Geohydrological

Aspects of the EMP for the Proposed High Extraction Mining Project, Report Number 3224/1187/1/E,

s.l.: s.n.



Appendices



Appendix A: Site Plans



Appendix B: Site Photographs



Appendix C: Specialist Studies and declarations of independence



Appendix D: Public Participation

I&AP Register

Site Notice

Advertisement

Background Information Document

Notification of Availability of Reports

Public Meeting/Open Day

Authorities’ Meeting

Comments and Response Report



Appendix E: EMPr



Appendix F: Project Team CV’s



Appendix G: Project Experience



Appendix H: Application Form with EAP Declaration of Independence



Appendix I: Authority Correspondence



SRK Report Distribution Record

Complete this form and include it as the final page for each copy of the report produced.

Report No. 467209/Draft EIAr

Copy No.

Name/Title Company Copy Date Authorised by

Mrs. Okwethu Fakude MDARDLEA

1-2 (HC) 3-4 (.pdf)

October 2014 M. Hinsch

Mrs M.M Skosana Nkangala District Municipality

5 October 2014 M. Hinsch

Ms D. Mahlangu Mpumalanga Department of Public Works, Roads and Transport


Mr. F Guma Mpumalanga Department Water Affairs (DWA)


Mr. Golden Mthembi Inkomati Catchment Management Agency - DWA


Malapane Marcia Olifants Catchment Management Agency - DWA


Mr. W.D. Fouché Steve Tshwete Local Municipality


Mrs. T. Shoba Emakhazeni Local Municipality


Ms R. Mahlangu Rietkuil Public Library


Mr. S. Hlatshwayo

Belfast Public Library 13 October 2014 M. Hinsch

Mrs. T Dale Exxaro Coal Mpumalanga (Pty) Ltd


SRK Library SRK


SRK File SRK


Approval Signature:

This report is protected by copyright vested in SRK (SA) Pty Ltd. It may not be reproduced or

transmitted in any form or by any means whatsoever to any person without the written permission of

the copyright holder, SRK.

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