ENVIRONMENTAL MANAGEMENT PROGRAMME R61 Caitlin 041017/EMPr.pdfBorrow Pit Manager: Individual who is responsible for ensuring that the borrow pit operates successfully. The Borrow Pit

SANRAL R61 Borrow Pit – January 2018

EOH Coastal & Environmental Services EMPr i

ENVIRONMENTAL MANAGEMENT PROGRAMME

REHABILITATION OF NATIONAL ROUTE R61 SECTION 6: BORROW PIT

DMR REF: EC 30/5/1/3/3/2/1/00089 BPEM

Prepared for:

South African National Roads Agency Ltd (SANRAL)

Prepared by:

EOH Coastal & Environmental Services

EAST LONDON 25 Tecoma Street

East London 5214

043 726 7809 Also in Grahamstown, Cape Town, Johannesburg, Port Elizabeth and Maputo

www.cesnet.co.za

January 2018

http://www.cesnet.co.za/


EOH Coastal & Environmental Services EMPr 1

TABLE OF CONTENTS 1 INTRODUCTION ............................................................................................................................. 5

1.1 Objectives of an EMPr ...................................................................................................................... 5 1.2 Structure and Function of an EMPr ................................................................................................. 6 1.3 Legal requirements .......................................................................................................................... 7

2 DETAILS OF THE ENVIRONMENTAL ASSESSMENT TEAM .................................................................. 8 3 PROPOSED ACTIVITY .................................................................................................................... 10

3.1 Description of proposed activity .................................................................................................... 10 4 SCOPE OF THE EMPR .................................................................................................................... 13

4.1 Layout of the EMPr ........................................................................................................................ 13 4.1.1 Planning and design phase .......................................................................................................... 13 4.1.2 Construction phase ...................................................................................................................... 13 4.1.3 Operational (mining) phase ......................................................................................................... 13 4.1.4 Decommissioning/closure phase ................................................................................................. 13

5 MITIGATION AND/OR MANAGEMENT MEASURES ........................................................................ 14 5.1 General mitigation measures for all phases of mining .................................................................. 17

5.1.2 General Rehabilitation Guidelines .............................................................................................. 26 6 ENVIRONMENTAL MONITORING .................................................................................................. 28

6.1 Construction phase ........................................................................................................................ 28 6.2 Operation/ Mining Phase ............................................................................................................... 28 6.3 Closure and decommissioning phase ............................................................................................. 28

7 ROLES AND RESPONSIBILITIES ...................................................................................................... 29 7.1 The Borrow Pit Manager ................................................................................................................ 29 7.2 The Borrow Pit Operator ................................................................................................................ 29 7.3 Environmental Manager ................................................................................................................ 29 7.4 Senior and Supervisory Personnel ................................................................................................. 30 7.5 Sub-contractors .............................................................................................................................. 30 7.6 Environmental Officer .................................................................................................................... 30

8 COMPLIANCE WITH THE EMPR ..................................................................................................... 31 8.1 Non-compliance ............................................................................................................................. 31 8.2 Emergency preparedness .............................................................................................................. 32 8.3 Incident reporting and remedy ...................................................................................................... 32 8.4 Penalties to contractors ................................................................................................................. 33

9 REPORTING .................................................................................................................................. 34 9.1 Good housekeeping ....................................................................................................................... 34 9.2 Record keeping .............................................................................................................................. 34 9.3 Document control .......................................................................................................................... 34

10 ENVIRONMENTAL AWARENESS .................................................................................................... 35 10.1 Monitoring of environmental training ........................................................................................... 36

11 CLOSURE PLANNING .................................................................................................................... 37 11.1 Content of the closure plan ........................................................................................................... 37

12 CONCLUSIONS ............................................................................................................................. 38



GLOSSARY OF TERMS Alien Vegetation: Alien vegetation is defined as undesirable plant growth which must include, but not be limited to all declared category 1 and 2 listed invader species as set out in the Conservation of Agricultural Resources Act (CARA) regulations. Other vegetation deemed to be alien must be those plant species that show the potential to occupy in number, any area within the defined construction area and which are declared to be undesirable. Borrow Pit Manager: Individual who is responsible for ensuring that the borrow pit operates successfully. The Borrow Pit Manager oversees all operations, both on site and in the office, manages staff, coordinates production and monitors all site systems. Borrow Pit Operator (s): Any firm or individual contracted by, or on behalf of the South African National Road Ltd. to perform services or provide goods to the mining operations associated with the R61 Road Upgrade and who has a presence on site and includes any Borrow Pit Operator, sub-contractors and suppliers. Environmental Management Programme: The Environmental Management Programme (EMPr) provides specific environmental guidance for the planning and design, construction, operation and decommissioning of the dolerite quarry. The EMPr consists of both a management system and environmental specifications which contain detailed specifications that need to be undertaken or adhered to by the Quarry Operator. Two types of specifications need to be complied with by the Quarry Operator namely; standard and specific. Standard specifications apply to all project components and specific specifications outline specific instructions for managing and minimising environmental impacts resulting from the actual activity. Environment: The surroundings within which humans exist and that are made up of:

The land, water and atmosphere of the earth

Micro-organisms, plant and animal life

Any part or combination of i) and ii) and the interrelationships among and between them

The physical, chemical, aesthetic and cultural properties and conditions of the foregoing that influence human health and well-being.

Environmental Officer (EO): A suitably qualified independent person contracted by the quarry/borrow pit who is tasked with annual auditing of the environmental performance and compliance with the EMPr as per Regulation 34 of NEMA, 2014 (amended 2017). Environmental Impact: An impact or environmental impact is the change to the environment, whether desirable or undesirable, that will result from the effect of a construction or mining activity. An impact may be the direct or indirect consequence of a construction or mining activity. Environmental Manager (EM): An EM is the mining site-based designated person responsible for implementing the environmental provisions of the Quarry Contract. The EM must record and communicate environmental issues (as they occur) to the Quarry Operator (and/or Manager) and maintain records thereof. Environmental Policy: A statement by the organisation of its intentions and principles in relation to its overall environmental performance which provides a framework for action and for the setting of its environmental objectives and targets.



Material Safety Data Sheets (MSDS): A form containing data regarding the properties of a particular substance. An important component of product stewardship and workplace safety, it is intended to provide workers and emergency personnel with procedures for handling or working with that substance in a safe manner, and includes information such as physical data (melting point, boiling point, flash point, etc.), toxicity, health effects, first aid, reactivity, storage, disposal, protective equipment, and spill handling procedures. Mitigate: The implementation of practical measures to reduce the adverse impacts, or to enhance beneficial impacts of a particular action. Pollution: According to the National Environmental Management Act, No. 107 of 1998 and amended in 2010, pollution can be defined as, “Any change in the environment caused by (i) substances; (ii) radioactive or other waves; or (iii) noise, odours, dust or heat emitted from any activity, including the storage or treatment of waste or substances, construction and the provision of services, whether engaged in by any person or an organ of state, where that change has an adverse effect on human health or well-being or on the composition, resilience and productivity of natural or managed ecosystems, or on materials useful to people, or will have such an effect in the future” Potentially Hazardous Substance: A substance which, in the reasonable opinion of the Quarry Manager or EO, can have a detrimental effect on the environment. Restoration: The process of reconstituting a degraded system to its original state. Replacement: The establishment of a different type of vegetation on the degraded environment following construction or mining, for example agriculture. Re-vegetation: The physical process of establishing a vegetation cover. Rehabilitation: A general term that encompasses the three processes, restoration, replacement and re-vegetation, and is the process or programme implemented to achieve restoration or replacement. Site: The area in which construction or mining activity is taking place. Solid Waste: Refers to all solid waste, including construction debris, chemical waste, excess cement/concrete, wrapping materials, timber, tins and cans, drums, wire, nails, food and domestic waste (e.g. plastic packets and wrappers). Species of Special Concern (SSC): Those species listed in the Rare, Indeterminate, or Monitoring categories of the South African Red Data Books, and/or species listed in Globally Near Threatened, Nationally Threatened or Nationally Near Threatened categories (Barnes, 1998). Subsoil: Refers to all soil that occurs deeper than the first 200 mm of soil. Threatened species: Threatened species are defined as: (a) species listed in the Endangered or Vulnerable categories in the revised South African Red Data Books or listed in the Globally Threatened category; (b) species of special conservation concern (i.e. taxa described since the relevant South African Red Data Books, or whose conservation status has been highlighted subsequent to 1984); (c) species which are included in other international lists; or (d) species included in Appendix 1 or 2 of the Convention of International Trade in Endangered Species (CITES). Topsoil: Refers the top 200mm of soil and may include top material e.g. vegetation and leaf litter.



Watercourse: According to NWA (No. 36 of 1998) “watercourse” means (a) a river or spring; (b) a natural channel in which water flows regularly or intermittently; (c) a wetland, lake or dam into which, or from which, water flows; and (d) any collection of water which the Minister may declare to be a watercourse, and a reference to a watercourse includes, where relevant, its bed and banks.



1 INTRODUCTION

1.1 Objectives of an EMPr The Environmental Management Programme (EMPr) has been compiled to provide recommendations and guidelines according to which compliance monitoring can be done during the construction, operation and decommissioning of the proposed borrow pit (Figure 1.1). The objective of the EMPr is also to ensure that all relevant factors are considered to ensure environmentally responsible construction and mining activity. The purpose of the EMPr is to provide specifications for "good environmental practice" for application during all the phases of mining.

Figure 1.1: Locality map of the borrow pit. This EMPr informs all relevant parties which are in this case, the Borrow Pit Operator (BPO) (contractor), Borrow Pit Manager (BPM), the Environmental Manager (EM), Environmental Officer (EO) and all other staff employed by the Contractor and SANRAL at the site as to their duties in the fulfilment of the legal requirements for the construction, operation and decommissioning phases of the project with particular reference to the prevention and mitigation of anticipated potential environmental impacts. The objectives of an EMPr are to:

Ensure compliance with regulatory authority stipulations and guidelines which may be local, provincial, national and/or international;

Ensure that there is sufficient allocation of resources on the project budget so that the scale of EMPr-related activities is consistent with the significance of project impacts;

Verify environmental performance through information on impacts as they occur;

Respond to unforeseen events;

Provide feedback for continual improvement in environmental performance;

Identify a range of mitigation measures which could reduce and mitigate the potential impacts to minimal or insignificant levels;

Detail specific actions deemed necessary to assist in mitigating the environmental impact of the borrow pit;



Identify measures that could optimize beneficial impacts;

Create management structures that address the concerns and complaints of I&APs with regards to the borrow pit;

Establish a method of monitoring and auditing environmental management practices during all phases of the activity;

Ensure that safety recommendations are complied with;

Specify time periods within which the measures contemplated in the final environmental management programme must be implemented, where appropriate;

1.2 Structure and Function of an EMPr An EMPr is focused on sound environmental management practices, which will be undertaken to minimise adverse impacts on the environment through the lifetime of a development. In addition, an EMPr identifies what measures will be in place or will be actioned to manage any incidents and emergencies that may occur during operation of the borrow pit. As such the EMPr provides specifications that must be adhered to, in order to minimise adverse environmental impacts associated with all phases of mining. The content of the EMPr is consistent with the requirements as set out in Appendix 4 of the EIA regulations (2014; amended 2017) stated below, for the planning and design, construction, operation and decommissioning phases.

According to APPENDIX 4 of GN R 326, an environmental management programme must include:

(a) Details of – (i) The EAP who prepared the environmental management programme; and (ii) The expertise of the EAP to prepare an environmental management programme, including

a curriculum vitae; (b) A detailed description of the aspects of the activity that are covered by the environmental

management programme as identified by the project description; (c) A map at an appropriate sale which superimposes the proposed activity, its associated structures,

and infrastructure on the environmental sensitivities of the preferred site, indicating any areas that should be avoided, including buffers;

(d) A description of the impact management outcomes, including management statements, identifying the impacts and risks that need to be avoided, managed and mitigated as identified through the environmental impact assessment process for all phases of the development including –

(i) Planning and design; (ii) Pre-construction activities; (iii) Construction activities; (iv) Rehabilitation of the environment after construction and where applicable post closure;

and (v) where relevant, operation activities;

(f) a description of proposed impact management actions, identifying the manner in which the impact management outcomes contemplated in paragraphs (d) will be achieved, and must, where applicable include actions to –

a. Avoid, modify, remedy, control or stop any action, activity or process which causes pollution or environmental degradation;

b. Comply with any prescribed environmental management standards or practices; c. Comply with any applicable provisions of the Act regarding closure, where applicable; d. Comply with any provisions of the Act regarding financial provisions for rehabilitation,

where applicable; (g) The method of monitoring the implementation of the impact management actions contemplated in

paragraph (f); (h) The frequency of monitoring the implementation of the impact management actions contemplated

in (f);



(i) An indication of the persons who will be responsible for the implementation of the impact management actions;

(j) The time periods within which the impact management actions contemplated in paragraph (f) must be implemented;

(k) The mechanism for monitoring compliance with the impact management actions contemplated in paragraph (f);

(l) A program for reporting on compliance, taking into account the requirement as prescribed by the regulations;

(m) An environmental awareness plan describing the manner in which – a. The applicant intends to inform his or her employees of any environmental risk which may

result from their work; and b. Risks must be dealt with in order to avoid pollution or the degradation of the environment;

and (n) Any specific information that may be required by the competent authority.

1.3 Legal requirements

The mining activities must be carried out according to the best industry practices. This EMPr, which forms an integral part of the contract documents, informs the BPO as to his/her duties in the fulfilment of the project objectives, with particular reference to the prevention and mitigation of environmental impacts caused by construction and mining activities associated with the project. The BPO should note that obligations imposed by the approved EMPr are not legally binding in terms of environmental statutory legislation, but if not implemented may lead to environmental damage that could be in direct contravention of environmental legislation, and should therefore form part of the general conditions of contract that pertain to this project. In the event that any rights and obligations contained in this document contradict those specified in the standard or project specifications then the latter must prevail. The BPO must identify and comply with all South African national and provincial environmental legislation, including associated regulations and all local by-laws relevant to the project. The list of applicable legislation provided below is intended to serve as a guideline only and is not exhaustive:-

Mineral and Petroleum Resources Development Act (No. 28 of 2002)

Constitution Act (No. 108 of 1996)

National Environment Management Act (No. 107 of 1998)

National Environment Management Act : EIA Regulations (2014)

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

National Water Act (No. 36 of 1998)

National Environmental Management: Waste Management Act (No. 59 or 2008)

National Heritage Resources Act (No. 25 of 1999)

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

Health Act (No. 63 of 1977)

Occupational Health and Safety Act (No. 85 of 1993)

Hazardous Substances Act (No. 15 of 1973) Municipal policy

The Engcobo Local Municipality Integrated Development Plan (2014/2015)



2 DETAILS OF THE ENVIRONMENTAL ASSESSMENT TEAM According to APPENDIX 4 of GN R 326, an environmental management programme must include:

(a) Details of – (i) The EAP who prepared the environmental management programme; and (ii) The expertise of the EAP to prepare an environmental management programme, including a

curriculum vitae;

Environmental Assessment Practitioner (EAP): EOH Coastal & Environmental Services 25 Tecoma Street, Berea, East London, 5214 PO Box 8145, Nahoon, East London, 5210 Tel: 043 726 7809/8313 Fax: 043 726 8352 e-mail: [email protected] www.cesnet.co.za Project Team: • Dr Alan Carter • Ms Caitlin Smith EOH Coastal & Environmental Services (EOH) was established in 1990 as a specialist environmental consulting company and has considerable experience in terrestrial, marine and freshwater ecology, the Social Impact Assessment (SIA) process, State of Environment Reporting (SOER), Integrated Waste Management Plans (IWMP), Environmental Management Plans (EMPs), Spatial Development Frameworks (SDF), public participation, as well as the management and co-ordination of all aspects of the Environmental Impact Assessment (EIA) and Strategic Environmental Assessment (SEA) processes. Dr Alan Carter Alan is the executive of the East London Office. He holds a PhD in Marine Biology and is a certified Public Accountant, with extensive training and experience in both financial accounting and environmental science disciplines with international accounting firms in South Africa and the USA. He has 25 years’ experience in environmental management and has specialist skills in sanitation, coastal environments and industrial waste. Dr Carter is registered as a Professional Natural Scientist under the South African Council for Natural Scientific Professions (SACNASP). He is also registered as an EAP by the Environmental Assessment Practitioners of South Africa (EAPSA).



Ms Caitlin Smith, Senior Environmental Consultant. Caitlin holds a BSc degree with majors in Geology and Geography and a BSc Honours Degree (with distinction) in Geology both obtained from Nelson Mandela Metropolitan University. Caitlin is a qualified geologist and has managed and been involved in various Environmental Impact Assessments. Her interest lies in the water sector, specifically in wetland related studies. She has completed various Aquatic and Wetland assessments for road and infrastructure projects. She is currently studying her MSc degree in Hydrology at Rhodes University focusing on the groundwater and surface water interactions of the Krom River wetlands.



3 PROPOSED ACTIVITY According to APPENDIX 4 of GN R 326, an environmental management programme must include:

(b) A detailed description of the aspects of the activity that are covered by the environmental management programme as identified by the project description;

(c) A map at an appropriate sale which superimposes the proposed activity, its associated structures, and infrastructure on the environmental sensitivities of the preferred site, indicating any areas that should be avoided, including buffers;

3.1 Description of proposed activity SANRAL will be constructing various safety improvements on Section 6 of the R61 National Route from Qumanco River to Engcobo in the Eastern Cape Province. A mudstone borrow pit is required to supply the necessary rock material for road construction. A suitable borrow pit site has been identified approximately 750 m off the R61 at KM 52.6 in the Beyele Administrative Area in the Engcobo Local Municipality, Eastern Cape.

A perimeter fence will be constructed around the borrow pit site (Figure 3.1). The borrow pit area is approximately 8.8 hectares in size. The fence has a perimeter of approximately 1,285 m. Approximately 45,129 m3 of topsoil will be taken off the borrow pit site and stockpiled. The topsoil stock pile area is 0.30 Ha in size. The borrow pit should yield approximately 405,394.16 m3 of mudstone rock for crushing. Rock will only be stored temporarily in stockpiles on site (taking up a total area of 0.54 Ha) before being crushed and taken off site.



Figure 3.1 Layout of the borrow pit



Sensitivity map A sensitivity map of the study area is provided in Figure 3.2 below. This map was developed based on site visits and the relevant specialist reports. The majority of the borrow pit site and area immediately surrounding the site is considered to have a low sensitivity. Areas of high sensitivity surrounding the borrow pit site (indicated in red in the sensitivity map) include heritage sites and drainage lines. A moderate sensitivity buffer (of 50 m) surrounds the drainage lines. No construction or mining activities should take place within 50 m of the watercourses. All heritage sites must be clearly demarcated and avoided.

Figure 3.2 Sensitivity map



4 SCOPE OF THE EMPr In order to ensure a holistic approach to the management of environmental impacts during the planning and design, construction, operation and decommissioning phase of the borrow pit this EMPr sets out the methods by which proper environmental controls are to be implemented by the BPO Manager and all other parties involved. The EMPr is a dynamic document subject to influences and changes as are wrought by variations to the provisions of the project specification.

4.1 Layout of the EMPr

The EMPr is divided into four phases of development. Each phase has specific issues unique to that period of the planning and design, construction, operation and decommissioning of the borrow pit and associated infrastructure. The impacts are identified and given a brief description. The four phases of the mining activity are then identified as below: 4.1.1 Planning and design phase

This section of the EMPr provides management principles for the planning and design phase of the project. Environmental actions, procedures and responsibilities as required during the planning and design phase are specified. 4.1.2 Construction phase

This section of the EMPr provides management principles for the construction phase of the project. Environmental actions, procedures and responsibilities as required during the construction phase are specified. 4.1.3 Operational (mining) phase

This section of the EMPr provides management principles for the operational (mining) phase of the project. Environmental actions, procedures and responsibilities as required during the operation and maintenance phase are specified. 4.1.4 Decommissioning/closure phase

This section of the EMPr provides management principles for the decommissioning/closure phase of the project.



5 MITIGATION AND/OR MANAGEMENT MEASURES According to APPENDIX 4 of GN R326, an environmental management programme must include:

(d) A description of the impact management outcomes, including management statements, identifying the impacts and risks that need to be avoided, managed and mitigated as identified through the environmental impact assessment process for all phases of the development including–

(i) Planning and design; (ii) Pre-construction activities; (iii) Construction activities; (iv) Rehabilitation of the environment after construction and where applicable post closure;

and (v) where relevant, operation activities;

(e) A description of proposed impact management actions, identifying the manner in which the impact management outcomes contemplated in paragraphs (d) will be achieved, and must, where applicable include actions to –

(i) Avoid, modify, remedy, control or stop any action, activity or process which causes pollution or environmental degradation;

(ii) Comply with any prescribed environmental management standards or practices; (iii) Comply with any applicable provisions of the Act regarding closure, where applicable; (iv) Comply with any provisions of the Act regarding financial provisions for rehabilitation,

where applicable;

The following section provides measures to mitigate environmental risks associated with the quarry, including: • Mitigation measures for specific issues identified in the Environmental Impact Assessment Report

(EIR). • General environmental mitigation measures for all phases of mining. 5.1 Issue Specific Mitigation Measures. The following table provides mitigation measures for specific issues identified in the EIR.

Theme Mitigation measure

Planning and Design Phase

GENERAL Compliance with relevant

environmental legislation and policy

All relevant legislation and policy must be consulted and the proponent must ensure that the project is compliant with such legislation and policy.

These should include (but are not restricted to): MPRDA, NEMA, Local and District Spatial Development Frameworks, Eastern Cape Biodiversity Conservation Plan (ECBCP), Local Municipal bylaws.

Design of the borrow pit The borrow pit must be designed by an appropriately qualified engineer.

Disturbance to the topography of the study area

During the planning and design phase an appropriate mining rehabilitation and closure plan must be developed.

Stormwater management During the planning and design phase appropriate stormwater structures must be designed and implemented.

A stormwater management plan must be developed and all stormwater structures must be designed in line with SANRAL and DWS requirements.

Socio-economic An agreement has been reached between SANRAL and the affected community.

During the planning and design phase SANRAL must ensure that the



Theme Mitigation measure conditions of the agreement are planned for and met.

Invasion of alien species During the planning and design phase a Rehabilitation and Alien Vegetation Management Plan must be designed to reduce the establishment and spread of undesirable alien plant species.

HERITAGE Impact on sites of archaeological

and cultural significance During the planning and design phase the location of identified heritage

sites must be considered in the design of the borrow pit and layout of infrastructure.

Identified heritage sites should be clearly demarcated. PALEONTOLOGICAL

Impact on paleontological resources

During the planning and design phase the location of identified heritage sites must be considered in the design of the borrow pit and layout of infrastructure.

Identified heritage sites should be clearly demarcated. Construction Phase

GENERAL Visual intrusion associated with the establishment of the borrow

pit site

All construction activity should take place during daylight working hours (i.e. 7 – 5pm).

All construction activity and equipment must be limited to the demarcated areas.

Sanitation facilities During the construction phase sanitation facilities must NOT be located within 50m of any water resources or water drainage areas.

Sanitation facilities must be located within the borrow pit footprint.

The facilities must be regularly serviced to reduce the risk of surface or groundwater pollution.


and cultural significance During the construction phase if any graves/heritage features are

damaged then construction must stop immediately. Any damage to heritage features must be reported to the EM, Heritage

Specialist and SAHRA.

Should any heritage features be uncovered during the construction phase then the following is recommended: o If any heritage features are uncovered then all construction in the

immediate vicinity (50 m radius of the site) should cease. o The heritage practitioner and ECO should be informed as soon as

possible. o In the event of obvious human remains the South African Police

Services (SAPS) should be notified. o The area within 50 m of the heritage site should be cordoned off with

hazard tape. o Public access should be limited. o The area should be placed under guard. o No media statements should be released until the heritage

practitioner has had sufficient time to analyse the finds.

Operation Phase

GENERAL Compliance with relevant

environmental legislation and policy

During the operational phase the proponent must ensure that mining is compliant with the relevant legislation and policy.

These should include (but are not restricted to): MPRDA, NEMA, Local and District Spatial Development Frameworks, Eastern Cape Biodiversity Conservation Plan (ECBCP), Local Municipal bylaws.

Visual intrusion associated with mining activities

Mining activities must be limited to the designated area and not encroach into surrounding areas.

Sanitation facilities During the operational phase sanitation facilities must be located more than 50 m from any water resources or water drainage areas.

Sanitation facilities must be located within the borrow pit footprint.



Theme Mitigation measure The facilities must be regularly serviced to reduce the risk of surface or

groundwater pollution.

Demarcation of the borrow pit site The boundaries of the quarry site must be adequately demarcated to restrict mining and other activities. All plant, equipment and other materials must remain within the demarcated boundaries.

The site must be access controlled with a lockable gate and security monitoring movements

Stormwater management During the operation phase water runoff must be controlled and the stormwater management plan implemented.

Spillage of hazardous substances During the operation phase all oils, fuel and other maintenance equipment and supplies must be stored in a secure area with a compacted surface.

Maintenance of vehicles or machinery should not take place within 50 m of any watercourse and drip trays must be used.

Spill kits must be kept on-site and maintained.

Dust control During windy periods un-surfaced and un-vegetated areas should be dampened down.

Vegetation should be retained where possible as this will reduce dust travel.

Excavations and other clearing activities must only be done during agreed working times and permitting weather conditions to avoid drifting of sand and dust into neighbouring areas.

A speed limit of 30km/h must not be exceeded on dirt roads.

Any complaints or claims emanating from the lack of dust control must be attended to immediately.

Noise During the operation phase drilling, blasting and movement of heavy machinery should be limited to normal working hours (7 AM to 5 PM).

Ensure there is a facility for nearby residents to make complaints. These must be addressed and recorded.

Waste management During the operation phase sufficient waste containers must be available.

No waste must be buried on site.

Waste must be collected on a regular basis and disposed of at a licensed landfill site.

Impact on natural flora During the operational phase the borrow pit must be adequately demarcated. No mining activities or vehicles should encroach into surrounding areas.

An appropriate rehabilitation plan must be developed and implemented during closure.

Invasion of alien species During the operational phase an Alien Vegetation Management Plan must be implemented to reduce the establishment and spread of undesirable alien plant species.


and cultural significance During the operation phase if any graves/heritage features are damaged

then mining activity must stop immediately. Any damage to heritage features must be reported to the EM, Heritage

Specialist and SAHRA.

Should any heritage features be uncovered during the operation phase then the following is recommended: o If any heritage features are uncovered then all mining activity in the

immediate vicinity (50 m radius of the site) should cease. o The heritage practitioner and ECO (if appointed) should be informed

as soon as possible. o In the event of obvious human remains the South African Police

Services (SAPS) should be notified. o The area within 50 m of the heritage site should be cordoned off with

hazard tape. o Public access should be limited. o The area should be placed under guard.



Theme Mitigation measure o No media statements should be released until the heritage

practitioner has had sufficient time to analyse the finds.

Decommissioning/Closure Phase

GENERAL Final rehabilitation and

decommissioning During decommissioning all infrastructure, equipment, machinery and

other items used during the mining period must be removed from the site.

Waste material of any description, including receptacles, scrap, rubble and

tyres, must be removed entirely from the mining area and disposed of at a

recognized landfill facility. No waste must be buried or burned on the site.

The borrow pit, access roads, storm water control areas and any other

affected areas must be rehabilitated.

The site must be covered with locally occurring grass and shaped/ levelled

correctly.

All exposed areas must be re-vegetated where possible.

Mining areas must be inspected weekly for soil stability until rehabilitation

is complete.

Alien invasive plant species must be eradicated until rehabilitation is

complete.

The closed borrow pit must pose no safety risks.

Rehabilitation must be completed in such a manner that the land can be

optimally used for grazing post-mining.

Final rehabilitation must be completed within a period specified by the

Regional Manager (DMR).

Closure Closure must comply with the MPRDA (Act 28 of 2002), NEMA (Act 107 of

1998) and the NEMA Regulations (2014, amended 2017) requirements for

mine closure.

A closure plan must be compiled using the guidelines described in

Appendix 5 of the NEMA Regulations (amended 2017) and submitted to

DMR.

A closure certificate must be obtained from the Minister of Mineral

Resources.

5.1 General mitigation measures for all phases of mining The following general mitigation measures relate to all phases of mining (particularly

decommissioning/closure and rehabilitation): Vegetation clearing

The BPO must inform all staff of the need to be vigilant against any practice that will have a harmful effect on vegetation. This information must form part of the Environmental Education Programme to be effected by the BPO.

The natural vegetation encountered on the site must be conserved and left as intact as possible.

Where appropriate, these plants must be kept in an off-site nursery and used in the rehabilitation of the areas disturbed during construction and mining and any other areas requiring rehabilitation.

Re-vegetation of disturbed areas must be undertaken with site appropriate indigenous species.

Only trees and shrubs directly affected by the works must be felled or cleared.



Where necessary, sensitive areas adjacent to the construction/borrow pit site, including all potential habitats for threatened species, must be demarcated and no construction or mining activities must be permitted to occur across these demarcations. Demarcated areas must be fenced off and no personnel or equipment must be permitted to enter these areas.

Any proclaimed weed or alien species that germinates during the construction and mining period must be cleared by hand before flowering.

Fires must only be allowed in facilities or equipment specially constructed for this purpose.

A firebreak must be cleared and maintained around the perimeter of the site camp.

On-going monitoring and maintenance of re-vegetation works must be undertaken following construction and mining activities.

Slope stabilisation

The BPO must take measures to protect all areas susceptible to erosion by installing all the necessary temporary and permanent drainage works as soon as possible. The BPO must take any other measures that may be necessary to prevent surface water from being concentrated in streams and from scouring the slopes, banks or other areas.

If tunnels or erosion channels develop, they must be back-filled and compacted, and the areas restored to a proper condition. The BPO must not allow erosion to develop on a large scale before effecting repairs.

Where artificial slope stabilisers are used, these must be applied to the slope, preferably before top-soiling, but according to the detailed mining plan and as specified below: o Where the slopes are 1:3 to 1:6 they must be logged or otherwise stepped in order to prevent soil

erosion. Logs must be laid in continuous lines following the contours and spaced vertically 0.8 - 1.2 m apart, depending on the steepness of the slope. These logs must be secured by means of steel pegs and wire in rocky areas, and treated wooden pegs in other areas.

o In areas where slopes are less than 1:6, horizontal grooves, shallow steps or ledges parallel to contours must be made on the cut slopes. They must be made at random to appear natural.

o Shallow slopes must be stabilised by using brushwood to initially minimise soil erosion until re-vegetation has been successful.

Site Clearance

In all areas where the BPO intends to, or is required to clear the natural vegetation and soil, a plan of action must first be submitted to the BPM and EM for approval. The plan must contain a photographic record of the areas to be disturbed. This must be submitted to the BPM and EM for their records before any disturbance/stockpiling may occur. The record must be comprehensive and clear, allowing for easy identification during subsequent inspections.

The BPO must be responsible for the re-establishment of vegetation disturbed during construction and mining. This includes, for example, service roads, stockpile areas and wherever material generated for, or from, construction or mining has to be stored temporarily or otherwise within the site, or at designated or instructed areas outside the boundaries of the site.

All cleared areas must be stabilised as soon as possible. Areas that are, in the reasonable opinion of the EM are less stable, must be stabilised immediately following vegetation clearance.

The disposal of vegetation by burying or burning is prohibited.

Vegetation, apart from trees identified for retention on site, should be cleared by hand to minimise secondary damage from large machinery (bush cutters, bulldozers, etc.). Care must be taken to minimise disturbance to topsoil during this process.

During site clearance, any old concrete, rubble or refuse must be removed from the site, or stockpiled for disposal at an approved disposal site. All stockpiles must be managed so as to avoid damage to vegetation.

Indigenous mulch must be harvested in such a manner that loss of seed and biomass is at a minimum.



Topsoil Removal and Stockpiling

Prior to site establishment and any earthmoving operations, the BPO must strip and stockpile all topsoil within the work areas for subsequent use in the rehabilitation and re-vegetation of the site.

All topsoil must be stripped and stockpiled separately from subsoil for subsequent use during rehabilitation and re-vegetation.

Soil must be stripped in a phased manner, so as to retain vegetation cover for as long as possible.

The top 200 mm of topsoil must be stripped unless otherwise stipulated by the EM.

Topsoil from different soil types must be stockpiled separately and replaced in the same areas from which they were taken. This must be supervised by the EM.

The EM must identify a suitable site for stockpiling and this must be approved by the BPM.

Topsoil must be treated with care and precautions must be taken to prevent unnecessary handling and compaction. In particular, topsoil must not be subject to compaction greater than 1 500 kg/m² and must not be pushed by a bulldozer for more than 50 m. Trucks may not drive over the stockpiles.

Unless otherwise instructed, topsoil must not be mixed with any other type of material, nor contaminated with machine oils or any other pollutant.

Topsoil stockpiles must be convex and should not exceed 2 m in height to minimise wind and water erosion. The BPO must ensure that the material does not blow or wash away. If the topsoil is in danger of being washed or blown away, or requires storage for more than 2 weeks, the BPO must cover it with a suitable material, such as mulch and/or seed it with a fast-growing annual grass.

Topsoil areas must be demarcated in order to ensure the safekeeping of topsoil and to separate different stockpile types.

Soil must be stockpiled for as short a period as possible.

Stockpiles must be monitored at weekly intervals to identify invasive plants, which must be removed when they germinate, to prevent contamination of the seed bank. The EM must assist in the identification of alien plants.

Stockpiles must not be covered with materials such as plastic that may cause it to compost, or kill any seeds. The soil in the stockpiles contains a valuable seed bank reserve which can be used in rehabilitation of the area.

The BPO must remove alien invasive weeds present within the mining area before indigenous vegetation clearing or soil removal for stockpiling begins.

Protection of Flora and Fauna

Except to the extent necessary for the carrying out of the works flora must not be removed, damaged or disturbed nor must any vegetation be planted, other than as specified in the re-vegetation specifications.

Trapping, poisoning and/or shooting of animals is strictly forbidden. No domestic pets or livestock are permitted on site.

Where the use of herbicides, pesticides and other poisonous substances is required, the BPO must submit a Method Statement (with product MSDS’s) for approval by the EM and BPM.

Construction and mining activities must remain within defined areas.

No construction / mining disturbance must occur outside these areas. Workshop, Equipment Maintenance and Storage

Where practical, all maintenance of equipment and vehicles must be performed in a workshop.

The BPO must ensure that there is no contamination of water, soil or vegetation.

The BPO must ensure the workshop (if present on site) is kept neat and clean at all times.

The workshop must have a smooth impermeable (concrete or thick plastic covered with sand) floor. The floor must be bunded and sloped towards an oil trap or sump to contain any spillages of substances (e.g. oil).

Drip trays must be provided in construction/mining areas for stationary and “parked” plant.



All vehicles and equipment must be kept in good working order and serviced regularly. Leaking equipment must be repaired immediately or removed from the site.

The workshop must be appropriately ventilated and vehicle exhaust fumes must be discharged to the open air (not indoors).

Materials Handling, Use and Storage

The BPO must ensure that drivers are informed of all procedures and restrictions required to comply with the specifications.

The BPO must ensure that these drivers are supervised during off-loading by someone with an adequate understanding of the requirements of the specifications.

Materials must be appropriately secured to ensure safe passage between destinations. Loads including, but not limited to, sand, stone chip, fine vegetation, refuse, paper and cement, must have appropriate cover to prevent spillage from the vehicle during transit.

The BPO must be responsible for any and all clean-up resulting from the failure by his employees or suppliers to properly secure transported materials.

All manufactured and/or imported material must be stored within the BPO’s camp, preferably out of the rain.

All lay-down areas must be subject to the BPM and EM’s approval, which must not be withheld unreasonably.

Solid Waste Management

No on-site burying, dumping or burning of any waste materials, vegetation, litter or refuse must occur.

Bins, with lids, must be positioned within the working areas and must be emptied daily.

All solid waste must be disposed of at a designated public disposal site.

Receipts for hazardous waste disposal must be copied to the EM.

Waste and litter must be disposed of into scavenger- and weather-proof bins. The BPO must remove the refuse collected from the working areas from site at least once a week.

The BPO must, where possible, limit the amount of waste produced on site, and ensure that wherever possible, waste materials are re-used or recycled, donated or sold to an organisation for this purpose.

Biodegradable items should be separated from other waste and used either in composting or mulching.

Hazardous Substances

If potentially hazardous substances are to be stored on site, the BPO must provide a Method Statement to the EM and BPM, detailing the substances/materials to be used, together with the storage, handling and disposal procedures of the materials.

The relevant Material Safety Data Sheets (MSDS) must be available on site. Procedures detailed in the MSDS must be followed in the event of an emergency situation.

Paint

No paint products may be disposed of on site.

Brush / roller wash facilities must be established to the satisfaction of the BPM and EM.

Oil based paints and chemical additives and cleaners such as thinners and turpentine must be strictly controlled. A Method Statement, approved by the BPM and EM, is required.



Spillages

Downstream water courses and wetlands must be protected from direct or indirect spillage of pollutants such as refuse, garbage, cement, concrete, sewage, chemicals, fuels, oils, aggregate, tailings, wash water, and organic materials. In the event of a spillage, the BPO will be liable to arrange for professional service providers to clean the affected area.

Responsibility for spill treatment lies with the BPO. The individual responsible for, or who discovers a hazardous waste spill must report the incident to BPM/EM. The EM must assess the situation in consultation with the BPM and act as required. In all cases, the immediate response must be to contain the spill. The exact treatment of polluted soil / water must be determined by the BPO in consultation with the EM. Areas cleared of hazardous waste must be re-vegetated according to the BPM’s and EM’s instructions.

Should water downstream of the spill be polluted, and fauna and flora show signs of deterioration or death, specialist hydrological or ecological advice will be sought for appropriate treatment and remedial procedures to be followed. The requirement for such input must be agreed with the BPM. The costs of containment and rehabilitation must be for the BPO’s account, including the costs of specialist input.

Servicing/fuelling of equipment

Servicing and fuelling must preferably occur off-site. If these activities occur on-site, the BPO must ensure that it takes place in designated areas. All waste generated during these activities must be collected and disposed of at an appropriate off site facility capable of handling such waste. All equipment that leaks must be repaired immediately. In the case of changing oil or lubricants on-site, the BPO must have Drizit pads (or equivalent) and/or drip trays available to collect any oil, fluid, etc.

The BPO must take all reasonable precautions to prevent the pollution of the ground and/or water resources by fuels and chemicals as a result of construction and mining activities. No oil, diesel, petrol, etc., must be discharged onto the ground. Pumps and other machinery requiring oil, diesel, petrol, etc. that are to remain in one position for longer than two days must be placed on drip trays. The drip trays must be emptied regularly and the contaminated water disposed of offsite at a facility capable of handling such waste water. Drip trays must be cleaned before any possible rain events that may result in the drip trays overflowing and before weekends and holidays.

The BPO must remove all oil, petrol and diesel-soaked sand immediately and must dispose of it as hazardous waste. Tanks containing fuel must have lids and must remain firmly shut. Fuel stores must be placed on a bunded seal base, and waste water or spilled fuel collected within the bund must be disposed of as hazardous waste. Only clean, empty tanks may be stored on the ground.

The BPO must take the necessary precautions to prevent fires or spills at the fuel stores. No smoking or other activities that can initiate fires must be allowed in the vicinity of the stores. Any hazardous waste substances must be disposed of off-site at a licensed landfill site.

Fuel Storage

Fuel should preferably not be stored on site, but if this is required, fuel storage must comply with the specifications presented in this section.

The fuel storage area must be located in an area approved by the BPM and EM, and must not be located in or be less than 100 m from any surface or underground water source.

The BPO must ensure that all liquid fuels (petrol and diesel) are stored in tanks with lids, which are kept firmly shut.

The tanks must be situated on a smooth impermeable surface (plastic or concrete) base with an earth bund (plastic must have sand on top to prevent UV degradation). The impermeable lining must extend to the crest of the bund and the volume inside the bund must be 110 % of the total capacity of all the storage tanks. The floor of the bund must be sloped towards an oil trap or sump to enable any spilled fuel and/or fuel-soaked water to be removed, or the bunded area must be covered.



The BPO must keep fuel under lock and key at all times, and the fuel storage area should preferably be fenced.

Smoking or naked flames must not be allowed in the vicinity of the stores.

Only empty and externally cleaned tanks may be stored on the bare ground. All empty and externally dirty tanks must be sealed and stored in an area where the ground has been protected. In addition, if fuel is dispensed from 200 litre drums, the proper dispensing equipment must be used, and the drum must not be tipped in order to dispense fuel. The dispensing mechanism of the fuel storage tank must be stored in a water proof container when not in use.

Symbolic safety signs depicting “No Smoking”, “No Naked Lights” and “Danger” must be provided, and they must conform to local standards. The volume capacity of the tank must be displayed.

The product contained within the tank must be clearly identified, using an appropriate emergency information system.

Any electrical or fuel-driven pump must be equipped and positioned so as not to cause any danger of ignition of the product.

Areas for storage of fuels and other flammable materials must comply with fire safety regulations.

The BPO must ensure that there is adequate fire-fighting equipment at the fuel stores. Eating Areas

The BPO must designate eating areas which must contain bins with lids and cooking facilities, if necessary.

Eating outside of these designated areas is prohibited.

The feeding or leaving of food for wild animals is strictly prohibited. Ablution Facilities

Washing, whether for personal hygiene or of personal effects, and acts of excretion and urination are strictly prohibited other than at the facilities provided.

The BPM and EM must approve the exact location of temporary toilets prior to establishment, should these be required.

The BPO must ensure that temporary toilets are emptied and serviced regularly and that no spillage occurs when the toilets are cleaned or emptied.

Discharge of waste from toilets into the environment and burial of waste is strictly prohibited.

Sanitation facilities must be located within 100 m from any point of work, but not closer than 50 m to any water body.

Toilet facilities supplied by the BPO for the workers must occur at a maximum ratio of 1 toilet per 15 workers. Toilet paper must be provided.

Contaminated Water

The BPO must set up a contaminated water management system.

Refuse screens and oil traps must be installed at runoff concentration points from where litter and/or oil will gather as a result of the construction and mining activities.

These facilities must be serviced and monitored at the discretion of the EM.

Wash areas must be placed and constructed in such a manner so as to ensure that the surrounding areas are not polluted. The EM must approve the location of wash areas.

Non-phosphorous detergents and no chlorinated solvents must be used except where no suitable alternative exists.

The BPO must prevent discharge of any pollutants, such as cements, concrete, lime, chemicals and fuels into any water sources.



Dust

The BPO is responsible for the control of dust.

The BPO must take all reasonable measures to minimise the generation of dust, as a result of construction activities, to the satisfaction of the EM.

Removal of vegetation must be avoided until such time as soil stripping is necessary. Exposed surfaces must be re-vegetated or stabilised as soon as is practically possible, as per the rehabilitation specifications provided below.

Where possible, soil stockpiles must be located in sheltered areas where they are not exposed to the erosive effects of the wind. Where erosion of stockpiles becomes a problem, erosion control measures must be implemented. These could include grassing, reducing the size of stockpiles or positioning them in areas where they are protected from wind erosion.

Vehicle speeds must not exceed 20km/hr on site.

Appropriate dust suppression measures must be used during high dust conditions e.g. dampening with water or the use of other suppression measures.

Stabilisation methods using mulch, straw, etc. should be applied to areas where earthworks are complete and the area is left exposed.

Noise

The BPO must endeavour to keep noise generating activities to a minimum.

Noises that could cause a major disturbance, for instance blasting and crushing activities, should only be carried out between 8h00 and 17h00.

The BPO must limit noise levels (e.g. install and maintain silencers on machinery).

Appropriate directional and intensity settings are to be maintained on all hooters and sirens.

No amplification equipment must be allowed on site.

Should noise generating activities have to occur at night the people in the vicinity of the drilling and blasting must be warned about the noise well in advance and the activities kept to a minimum.

Compliance with the appropriate legislation with respect to noise must be mandatory.

Access Roads

Only roads and tracks allocated as access roads must be used (no informal tracks or roads to be created).

The BPO must control the movement of all vehicles and plant (including that of his suppliers) so that they remain on designated routes, are distributed so as not to cause an undue concentration of traffic, and that all relevant laws are complied with.

In addition, such vehicles and plant must be so routed and operated as to minimise disruption to regular users of the routes not on the site.

In the event of a vehicle getting stuck or bogged down in a wet section or road, any damage from digging and attempts to extract the vehicle (holes, deep ruts, etc.) must be repaired.

Fire Control

No fires may be lit on site, other than in designated areas.

A Fire Officer must be appointed by the BPO and must be responsible for establishing a fire drill, fire procedures and ensuring that all fire-fighting equipment is readily accessible and in good working order.

Any fires that occur must be reported to the EM immediately.

Smoking must not be permitted in those areas where there is a fire hazard e.g. workshop, fuel storage areas and in the vicinity of dry vegetation.

Smoking must only be permitted in clearly marked designated areas.



Storm Water Controls

The BPO must take reasonable measures to control the erosive effects of storm water runoff at the construction/mining areas by creating storm water channels and berms, if deemed necessary by the EM.

The BPO will be liable for any damage to downstream areas caused by the diversion of overland storm water flows.

The BPO must use silt screens to prevent overland flowing water from causing erosion and must use bales of straw as filters, if necessary.

The BPO must ensure that erosion or pollution of ground water, drainage courses, wetlands and rivers does not occur as a result of site activities. Pollution could result from the release, accidental or otherwise, of contaminated runoff from construction camps, discharge of contaminated water, chemicals, oils, fuels, sewage, run off from stockpiles, solid waste, litter, etc. All equipment and machinery, e.g. cement mixers, generators etc., must be placed on drip trays.

The BPO must ensure that any polluted runoff is collected in a lined sump and not discharged overland. Natural run-off must be diverted away from the work site and storage areas. The BPO must take appropriate measures e.g. the erection of silt traps, or drainage retention areas, to prevent silt and sand entering drainage courses, rivers and wetlands.

Erosion

The removal of the natural vegetation cover must be avoided and where this cannot be done, minimised.

Agricultural drainage methods must be used in fill materials to remove water that could trigger slumping.

Perched water tables must be identified early and adequate drainage for these trigger points provided.

The disturbance of the natural soil structure must be prevented and excavations planned carefully.

The moving of heavy machinery into areas unnecessarily must be avoided.

All fill material must be very well compacted and innovative use of geo-textile materials in the retention of soil fill areas followed.

Rainwater runoff from cut slopes must be prevented as far as possible.

Cut off drains in areas above cut slopes must be created and these cut off drains must be lined in such a way that they do not create, rather than, alleviate problems.

Sufficient storm water take off points must be created in such a way that water does not have an opportunity to gather momentum.

Storm water ditches must contain structures that will reduce velocity of the run off.

The use of vegetated swales must be investigated in less steep areas.

Only local indigenous vegetation must be used for mulching. Access to Site and Safety

The BPO must ensure that access to the various work sites and associated infrastructure and equipment is off-limits to the public (especially children) at all times during mining.

Additional areas restricted to the public and suggested detours must be clearly marked on information boards to the satisfaction of the EM.

Any access to site that may pose a danger to the public must be suitably provided with warnings. Cement and Concrete Batching

Concrete (if required for any construction activity) must not be mixed directly on the ground, or in any area where runoff may pose a pollution threat.

Any concrete batching activity must be located in an area of low environmental sensitivity.

The cement/concrete batching works must be kept neat and clean at all times.

No batching activities must occur on unprotected substratum of any kind.



Contaminated water storage facilities must not be allowed to overflow and appropriate protection from rain and flooding must be implemented.

Used bags must be stored in weather-proof containers to prevent windblown cement dust and water contamination. Used bags must be disposed of on a regular basis and must not be used for any other purpose.

Spillage of concrete must not occur during batching and laying.

With respect to exposed aggregate finishes: the BPO must collect all contaminated water and fines and store it in sumps for disposal at an approved waste site.

All visible remains of excess concrete must be physically removed on completion of the plaster or concrete pour section and disposed of. Washing the remains into the ground is not acceptable. All excess aggregate must also be removed.

Earthworks

The excavation of any material (if required) must be done in accordance with applicable standards.

All earthworks must be undertaken in such a manner so as to minimise the extent of any impacts caused by such activities.

Prior to earthworks, a search and rescue operation must be initiated to ensure all plants, cuttings and seeds of value are removed.

Soil removed during earthworks must be removed and replaced in the same order in which it is found.

No equipment associated with the earthworks activity must be allowed outside of these areas unless expressly permitted by the BPM/EM.

Power Tools

The BPO must take preventative measures, such as screening, muffling, dust control, timing and pre-notification of affected parties to minimise complaints regarding dust, noise and vibration nuisances.

Pumping and Sumping

Pumps must be placed over a drip tray in order to prevent fuel spills and leaks from contaminating the water in the pumped area.

Contaminated water must not be discharged into existing watercourses or streams.

Silt-laden water must be cleaned by filtering through a drum containing sand and stone or by ensuring that the overland flow of water disperses widely through vegetation.

Settlement ponds should be used for large amounts of silt-laden water.

Site closure and rehabilitation All disturbed areas will require rehabilitation after mining. The BPO is responsible for rehabilitating any areas cleared or disturbed for mining purposes at the completion of mining. The BPO will also be responsible for repairing any damage to fences and other infrastructure as a result of mining activities. All equipment, machinery and excess aggregate, stone, gravel, concrete, etc. must be removed from the site upon completion of work. No discarded materials must be buried. Only locally indigenous vegetation must be used for rehabilitation. The BPO, BPM and EM should agree on how long the BPO will be responsible for erosion control.

The BPO is responsible for the elimination of alien plants and weeds in the disturbed areas for the duration of the contract, and the first month thereafter, after which time the project proponent will be responsible.



If there is a need for the establishment of additional access roads, the BPO will be responsible for their rehabilitation. Further, if additional access tracks are required in the more sensitive sections of the proposed activity they must be approved by an appointed botanist or EM who will establish the presence of any species of special concern in order to mitigate their disturbance. Also, selective clearing must be implemented. For example, not clearing larger woody thicket species that can be used for screening purposes must be considered. Re-vegetation of disturbed areas disturbed during the construction and operation phase consists of the following steps: 1. Spreading of stored topsoil i.e. that which has been removed from the site during construction and

mining activity. 2. Planting. Indigenous grasses should be planted on steep slopes. 3. Watering of newly planted plants. The amount and duration of watering will be dependent on the

season in which the plants are planted. 4. Regular audits and maintenance programmes to ensure that plants are growing and serving the

purpose for which they were planted (i.e. to prevent erosion). 5.1.2 General Rehabilitation Guidelines Indigenous vegetation sods 1. Sods (or clumps) of indigenous vegetation must be obtained from areas where they are removed

during clearing for mining. 2. Indigenous vegetation sods must be clean of weeds or invasive plants in specified areas before

planting. 3. Re-vegetation sods must be planted in strips to reduce erosion. 4. Sodding must take place on moist, rock free topsoil that has been scarified. 5. Sods, once harvested, must not be allowed to dry out and must be planted within 30 hours of being

removed from the soil or growing medium. If necessary, they must be lightly watered prior to planting. 6. Sods must be planted so they abut tightly against one another. The first row must be in a straight line

with subsequent rows planted so that the joints are staggered. Any gaps must either be planted with a sod reduced to the gap size or filled with topsoil.

7. Where grass sods are planted on slopes steeper than 1:2, wooden stakes of 500 mm diameter must be used to anchor the sods in position.

8. In the absence of rain, sods must be well watered after planting and not be allowed to deteriorate through a lack of moisture.

Harvested seed 1. Indigenous seed must be harvested in areas which are free of alien/invasive vegetation, either at the

site prior to clearance or from suitable neighbouring sites. 2. Following harvesting, the seed must be dried under cool airy conditions. The seed must be insect-free

and must be stored in containers under cool conditions that are free of rodents or insects. No wet, mouldy or otherwise damaged seed is acceptable. Seed harvested by hand from selected species, should be treated and stored separately.

3. Seed gathered by vacuum harvester or other approved mass collection method, from suitable shrubs or from the plant litter surrounding the shrubs must be kept apart from individually harvested seed.

4. Harvested seed obtained by means of vacuum harvesting, must be free of excessive quantities of organic and/ or substrate material.

Monitoring



All areas disturbed during mining must be monitored for a two to three year period until a suitable vegetation cover is obtained.



6 ENVIRONMENTAL MONITORING According to APPENDIX 4 of GN R 326, an environmental management programme must include:

(g) The method of monitoring the implementation of the impact management actions contemplated in paragraph (f);

(h) The frequency of monitoring the implementation of the impact management actions contemplated in (f);

A monitoring programme should be implemented for the duration of the construction, operation and decommissioning of the borrow pit. This programme must include:

6.1 Construction phase

The EM must establish a baseline of pre-construction site conditions validated with photographic evidence.

Monitoring must take place at the start of construction.

Thereafter monthly audits are acceptable (if necessary).

A final audit should take place after construction has stopped.

The EM must ensure compliance with the EMPr conditions, and where necessary, make the necessary recommendations for corrective action.

• The EM must keep a photographic record of the demarcated site and construction area. All audit reports must be available on site, and made readily available for any authority or member of public to review.

6.2 Operation/ Mining Phase

The EM must conduct regular site inspections (should be daily but if not must be weekly).

The EM must submit monthly environmental reports to management for the duration of the mining phase to ensure compliance with the EMPr. Copies of these reports must be kept in an environmental file onsite for review by the EO.

A register must be kept of all complaints from the community. All complaints / claims must be handled immediately to ensure timeous rectification / payment by the responsible party.

An annual audit report must be submitted to DMR (in terms of Section 24P (3)(b) of NEMA (Act 107 of 1998) and its amendment) by an independent EO. This audit report should contain the information as set out in Appendix 7 of the NEMA Regulations (2014; amended 2017) and the audit should be undertaken by an independent competent person.

An annual assessment of the environmental liability must take place and financial provision for rehabilitation must be increased, if necessary (using the Quantum Calculation).

6.3 Closure and decommissioning phase • The EM must conduct regular site inspections during the decommissioning and closure phase. • A final audit must be conducted by a qualified independent person (EO) and submitted to DMR.



7 ROLES AND RESPONSIBILITIES According to APPENDIX 4 of GN R 326, an environmental management programme must include:

(i) An indication of the persons who will be responsible for the implementation of the impact management actions;

7.1 The Borrow Pit Manager The Borrow Pit Manager (BPM) has the following responsibilities:

Ensuring that the necessary environmental authorisations and permits have been obtained.

Monitoring and verifying that the EMPr is adhered to at all times and taking action if the specifications are not followed.

Monitoring and verifying that environmental impacts are kept to a minimum.

Assisting the BPO in finding environmentally responsible solutions to problems.

Keeping records of all activities/incidents concerning the environment onsite in the Site Diary.

Keepng a register of complaints in the Site Office and recording and dealing with any community comments or issues.

Ordering the removal of person(s) and/or equipment not complying with specifications.

7.2 The Borrow Pit Operator The responsibility for ensuring compliance lies with the Borrow Pit Operator (BPO) and the BPM. The BPO must ensure that:

All staff members, sub-contractors and suppliers understand and adhere to the EMPr.

That all sub-contractors and suppliers are contractually bound to adhere to the EMPr and Environmental Code of Conduct.

7.3 Environmental Manager The BPM must identify and designate a representative as the Environmental Manager (EM). The EM must be based on-site and must be the responsible person for implementing the environmental provisions of the mining contract. It may be necessary to have more than one EM. The EM’s duties must include, inter alia, the following:

Ensuring that all the environmental authorisations and permits required in terms of the applicable legislation have been obtained prior to construction and mining activity commencing.

Assisting SANRAL in finding environmentally responsible solutions to problems.

The EM must conduct regular site inspections (should be daily but if not must be weekly).

Keeping accurate and detailed records of all activities on site.

Compile monthly site reports. These reports must be submitted to the BPM on a monthly basis & discussed at the site meetings. Copies of these reports must be kept in an environmental file for review by the EO on his annual audit.

Keeping a register of complaints on site and recording community comments and issues, and the actions taken in response to these complaints.

Ensuring that the correct actions are/were taken in response to these complaints

Ensuring that the required actions are undertaken to mitigate the impacts resulting from non-compliance.

Reporting all incidences of non-compliance to the BPM.



Conducting weekly and monthly site inspections for compliance with the EMPr.

Ordering the removal of, or issuing spot fines for person/s and/or equipment not complying with the specifications of the EMPr.

Undertaking a continual internal review of the EMPr.

The EM must have the following skills:

o The ability to manage public communication and complaints; o The ability to think holistically about the structure, functioning and performance of environmental

systems; and o The EM must be fully conversant with EMPr for the borrow pit and all relevant environmental

legislation. o A good working knowledge of all relevant environmental policies, legislation, guidelines and

standards. o The EM should also have the ability to amicably and diplomatically deal with the public as outlined in

bullet point one above.

7.4 Senior and Supervisory Personnel

All of the BPO’s senior and supervisory staff members must familiarise themselves with the full contents of the EMPr.

They must understand and know how to implement the control measures of the EMPr, and must be able to assist other staff members in matters relating to the EMPr.

7.5 Sub-contractors

A representative of all sub-contractors must receive a copy of the EMPr.

A representative of the sub-contractor must sign the Environmental Code of Conduct to give assurance that they understand the EMPr and that they undertake to comply with conditions therein.

7.6 Environmental Officer

It is recommended that an Environmental Officer (EO) or an independent person with the relevant environmental expertise be appointed to conduct annual environmental audits (for submission to DMR). The EO can also conduct monthly/quarterly audits if required by SANRAL.

The EO must have the following skills:

Relevant qualifications in environmental management i.e. a relevant degree (BSc. Environmental, Dip. etc.) as well as relevant working experience (minimum 2 years).

Good working knowledge of all relevant environmental policies, legislation, guidelines and standards;

The ability to conduct inspections and audits and to produce thorough, readable and informative reports;

The ability to think holistically about the structure, functioning and performance of environmental systems; and

Proven competence in the application of the following integrated environmental management tools: o Environmental Impact Assessment. o Environmental Management Programmes. o Mitigation and optimisation of impacts. o Monitoring and evaluation of impacts.



8 COMPLIANCE WITH THE EMPr

According to APPENDIX 4 of GN R 326, an environmental management programme must include: (j) The time periods within which the impact management actions contemplated in paragraph (f) must

be implemented; (k) The mechanism for monitoring compliance with the impact management actions contemplated in

paragraph (f);

A copy of the EMPr must be kept on site at all times during the construction and operation period. The EMPr will be binding on all borrow pit staff operating on the site. It should be noted that in terms of Section 28 of the National Environmental Management Act (No. 107 of 1998) those responsible for environmental damage must pay the repair costs both to the environment and human health and the preventative measures to reduce or prevent further pollution and/or environmental damage (The ‘polluter pays’ principle).

8.1 Non-compliance The BPO must act immediately when notice of non-compliance is received and take corrective action. Complaints received regarding activities on the borrow pit site pertaining to the environment must be recorded in a dedicated register and the response noted with the date and action taken. The EM should be made aware of any complaints. The BPO is deemed not to have complied with the EMPr if, inter alia:

There is evidence of contravention of the EMPr specifications within and outside the borrow pit;

The BPO fails to comply with corrective or other instructions issued by the BPM within a time specified by the BPM.

Environmental damage ensues due to negligence;

Quarry activities take place outside the defined boundaries of the site; and/or

The BPO fails to respond adequately to complaints from the public, as determined by the BPM and the EM.

Any non-compliance with the agreed procedures of the EMPr is a transgression of the various statutes and laws that define the manner by which the environment is managed. The BPM’s decision with regard to what is considered a violation, its seriousness and the action to be taken against the BPO must be final. It is recommended that the BPM institute penalties for the following less serious violations and any others determined during the course of work, as detailed below:

Littering on site.

Lighting of illegal fires on site.

Persistent or unrepaired fuel and oil leaks.

Any persons, vehicles or equipment related to the found within the designated “no-go” areas.

Excess dust or excess noise emanating from site.

Possession or use of intoxicating substances on site.

Any vehicles being driven in excess of designated speed limits.

Removal and/or damage to fauna, flora or cultural or heritage objects on site.

Urination and defecation anywhere except at designated facilities.



8.2 Emergency preparedness The BPO must compile and maintain environmental emergency procedures to ensure that there will be an appropriate response to unexpected or accidental actions or incidents that will cause environmental impacts, throughout the construction and operation period. Such activities must include, inter alia:

Accidental waste water discharges to water and land.

Accidental exposure of employees to hazardous substances.

Accidental fires.

Accidental spillage of hazardous substances.

Specific environmental and ecosystem effects from accidental releases or incidents. These plans must include:

Emergency organisation (manpower) and responsibilities, accountability and liability.

A list of key personnel and contact details.

Details of emergency services available (e.g. the fire department, spill clean-up services, etc.).

Internal and external communication plans, including prescribed reporting procedures where required by legislation.

Actions to be taken in the event of different types of emergencies.

Incident recording, progress reporting and remediation measures required to be implemented.

Information on hazardous materials, including the potential impact associated with each, and measures to be taken in the event of accidental release.

Training plans, testing exercises and schedules for effectiveness. The BPO must comply with the emergency preparedness and incident and accident-reporting requirements, as required by the Occupational Health and Safety Act (No. 85 of 1993), NEMA (No. 107 of 1998) and the National Water Act (No. 36 of 1998) and/or any other relevant legislation.

8.3 Incident reporting and remedy

An Environmental Incidents Register and an Environmental Complaints Register must be kept on site at all times and be maintained by the BPM.

If a leakage or spillage of hazardous substances occurs on site, the local emergency services must be immediately notified of the incident. The following information must be provided:

o The location; o The nature of the load; o The extent of the impact; and o The status at the site of the accident itself (i.e. whether further leakage is still taking place, whether

the vehicle or the load is on fire).

Written records must be kept on the corrective and remedial measures decided upon and the progress achieved therewith over time. Such progress reporting is important for monitoring and auditing purposes. The written reports may be used for training purposes in an effort to prevent similar future occurrences.



8.4 Penalties to contractors Where environmental damage is caused or a pollution incident, and/or failure to comply with any of the environmental specifications contained in the EMPr, the relevant contractor will be liable to pay a penalty fine. The following violations, and any others determined during the course of work, should be penalised:

Hazardous chemical/oil spill and/or dumping in non-approved sites.

Working outside the boundaries of the approved layout plan as per figure 3.1.

Carrying out any activity that will trigger Section 21 [c] & [i] within the extent of any watercourse (i.e. riparian & instream habitat or 1:100 year floodline).

Damage to sensitive environments.

Damage to cultural and historical sites.

Unauthorised removal/damage to indigenous trees and other vegetation, particularly in identified sensitive areas.

Uncontrolled/unmanaged erosion.

Unauthorised blasting activities.

Pollution of water sources.

In addition to the above, where the contractor inflicts non-repairable damage upon the environment or fails to comply with any of the environmental specifications, they will be liable to pay a penalty fine over and above any other contractual consequence. Depending on the nature or extent of a transgression, a penalty imposed could also carry jail time (although very rare), this is usually decided by the court of law in an event that court proceedings become unavoidable. The contractor is deemed NOT to have complied with this specification if:

Within the boundaries of the site, site extensions and haul/access roads and servitudes there is evidence of contravention of the specification.

Environmental damage ensues due to negligence.

The contractor fails to comply with corrective or other instructions issued by the EM or the BPM within a specific timeframe.

The contractor fails to respond adequately to complaints from the public, as determined by the BPM and the EM to require action on the part of the BPO.

The amount of the penalty fine must be determined by the EM and the BPM.

Payment of any fines in terms of the contract will not absolve the offender from being liable from prosecution in terms of any law.

The BPM has the power to remove from site, any person who is in contravention of the EMPr, and if necessary, the BPM can suspend part or all of the works, as required.



9 REPORTING According to APPENDIX 4 of GN R 326, an environmental management programme must include:

(l) A program for reporting on compliance, taking into account the requirement as prescribed by the regulations;

9.1 Good housekeeping The BPO must undertake “good housekeeping” practices during construction and operation. This will help avoid disputes on responsibility and allow for the smooth running of the contract as a whole. Good housekeeping extends beyond the wise practice of construction and mining methods to include the care for and preservation of the environment within which the construction is situated.

9.2 Record keeping The BPM and the EM will continuously monitor the BPO’s adherence to the approved impact prevention procedures and the BPM must issue to the BPO a notice of non-compliance whenever transgressions are observed. The EM should document the nature and magnitude of the non-compliance in a designated register, the action taken to discontinue the non-compliance, the action taken to mitigate its effects and the results of the actions. The non-compliance must be documented and reported to the BPM in the monthly report.

9.3 Document control The BPO and BPM must be responsible for establishing a procedure for document control. The document control procedure must comply with the following requirements:

Documents must be identifiable by organisation, division, function, activity and contact person.

Every document must identify the personnel and their positions, i.e. who drafted and compiled the document, who reviewed and recommended approval, and who finally approved the document for distribution.

All documents must be dated, provided with a revision number and reference number, filed systematically, and must be retained for at least a five year period.

The BPO must ensure that documents are periodically reviewed and revised, where necessary, and that current versions are available at all locations where operations essential to the functioning of the EMPr are performed. All documents must be made available during auditing.



10 ENVIRONMENTAL AWARENESS According to APPENDIX 4 of GN R 326, an environmental management programme must include:

(m) An environmental awareness plan describing the manner in which – (i) The applicant intends to inform his or her employees of any environmental risk which may

result from their work; and (ii) Risks must be dealt with in order to avoid pollution or the degradation of the environment;

and

The BPO must ensure that adequate environmental training takes place. All employees must have been given an induction presentation on environmental awareness. Where possible, the presentation needs to be conducted in the language of the employees. The environmental training must, as a minimum, include the following:

The importance of conformance with all environmental policies.

The environmental impacts, actual or potential, of their work activities.

The environmental benefits of improved personal performance.

The potential consequences of departure from specified operating procedures.

The mitigation measures required to be implemented when carrying out their work activities.

Environmental legal requirements and obligations.

The importance of not littering.

The importance of using supplied toilet facilities.

The need to use water sparingly.

Details of, and encouragement to, minimise the production of waste and re-use, recover and recycle waste where possible.

Details regarding archaeological and/or historical sites which may be unearthed during construction and mining activities and the procedures to be followed should these be encountered.

Details regarding flora of special concern, including protected/endangered plant species and the procedures to be followed should these be encountered.

In the case of permanent staff, the BPO must provide evidence that such induction courses have been presented. In the case of new staff (including contract labour) the BPO must inform the BPM when and how he intends concluding his environmental training obligations. A training needs analysis must be conducted by the BPM and/or EM to identify the appropriate environmental and health training programmes, and the appropriate target groups amongst the employees of the BPO. Environmental and health awareness training programmes must be targeted at three distinct levels of employment, i.e. the executive, middle management and labour. Environmental awareness training programmes should contain the following information:

The names, positions and responsibilities of personnel to be trained.

The framework for appropriate training plans.

The summarised content of each training course.

A schedule for the presentation of the training courses. The EM/BPO must ensure that records of all training interventions are kept in accordance with the record keeping and documentation control requirements as set out in this EMPr. The training records must verify each of the targeted personnel’s training experience.



10.1 Monitoring of environmental training The BPO must monitor the performance of mine and workers to ensure that the points relayed during their introduction have been properly understood and are being followed. If necessary, the EM and / or a translator should be called to the site to further explain aspects of environmental or social behaviour that are unclear. Toolbox talks are recommended.



11 CLOSURE PLANNING Final site cleaning - the BPO must clear and clean the site and ensure that all equipment and residual materials is removed from site on cessation of mining. Rehabilitation - the BPO (landscape architect/horticulturist) is responsible for rehabilitating and re-vegetation of all areas disturbed/areas earmarked for conservation during construction and mining to the satisfaction of the BPM and/or the EM.

11.1 Content of the closure plan

The final closure plan must include all the information outlined in Appendix 5 of the NEMA Regulations (2014; amended 2017): a) Details and expertise of the EAP who prepared the closure plan. b) Closure objectives. c) Proposed mechanisms for monitoring compliance with and performance assessment against the

closure plan and reporting thereon. d) Measures to rehabilitate the environment affected by the undertaking of any listed activity or

specified activity and associated closure to its natural state or to a land use which conforms to the generally acceptable principle of sustainable development.

e) Information on any proposed avoidance, management and mitigation measures that will be taken to address the environmental impacts resulting from the undertaking of the closure activity.

f) A description of the manner it intends to- o Modify, remedy, control or stop any action, activity or process which causes pollution or

environmental degradation during closure. o Remedy the cause of pollution or degradation and migration of pollutants during closure. o Comply with any prescribed environmental standards or practices. o Comply with applicable provisions of the Act regarding closure.

g) Time periods within which the measures contemplated in the closure plan must be implemented. h) The process for managing any environmental damage, pollution, pumping and treatment of

extraneous water or ecological degradation as a result of closure. i) Details of the public participation process conducted in terms of Regulation 41 of the Regulations. j) Where applicable, details of any financial provisions for rehabilitation, closure and on-going post

decommissioning management of negative environmental impacts.



12 CONCLUSIONS Although all foreseeable actions and potential mitigations or management actions are contained in this document, the EMPr should be seen as a day-to-day management document. The EMPr thus sets out the environmental and social standards that would be required to minimise the negative impacts and maximise the positive benefits of the construction and mining activities. All attempts should be made to have this EMPr available, as part of any tender documentation, so that the Engineers and BPO’s are made aware of the potential cost and timing implications needed to fulfil the implementation of the EMPr, thus adequately costing for these. The EMPr will be reviewed by the EM/EO on an on-going basis. Based on observations during site inspections and issues raised at site meetings, the EM/EO will determine whether any procedures require modification to improve the efficiency and applicability of the EMPr on-site. Any such changes or updates will be registered in the EM & EO’s records, as well as being included as an annexure to this document. It is the responsibility of SANRAL to ensure the Planning and Design, Construction, Mining and Decommissioning Phase mitigation measures are followed and the borrow pit is audited at least on an annual basis by an independent qualified auditor (EO).