Sigma Colliery: Mooikraal and 3 Shaft Environmental Audit...2020/01/29 · Digby Wells Environmental (hereafter “Digby Wells”) was appointed by Sasol Mining (Pty) Ltd to undertake

Digby Wells and Associates

(South Africa) (Pty) Ltd

Company Registration: 2010/008577/07

Turnberry Office Park,

Digby Wells House.

48 Grosvenor Road,

Bryanston,2191

Phone: +27 (0) 11 789 9495

Fax: +27 (0) 11 789 9495

E-mail: [email protected]

Website: www.digbywells.com

Directors: J Leaver (Chairman)*,

NA Mehlomakulu*, DJ Otto, M Rafundisani

*Non-Executive

Sigma Colliery: Mooikraal and 3 Shaft Environmental Audit

Audit Report

Prepared for:

Sigma Mooikraal Colliery

Project Number:

SAS5921

29 January 2020

mailto:[email protected]

DIGBY WELLS ENVIRONMENTAL

www.digbywells.com ii

This document has been prepared by Digby Wells Environmental.

Report Type: Audit Report

Project Name: Sigma Colliery: Mooikraal and 3 Shaft Environmental Audit

Project Code: SAS5921

Name Responsibility Signature Date

Puleng Chabeli Report Compiler

November 2019

Barbara Wessels Reviewer

November 2019

Mia Smith Reviewer

January 2020

This report is provided solely for the purposes set out in it and may not, in whole or in part, be used for any other purpose

without Digby Wells Environmental prior written consent.

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EXECUTIVE SUMMARY

Digby Wells Environmental (hereafter “Digby Wells”) was appointed by Sasol Mining (Pty) Ltd

to undertake an Environmental Audit for the Sigma Colliery: Mooikraal and the 3 Shaft

Operations (hereafter “Mooikraal”).

The audit was done in fulfilment of the performance assessment and environmental auditing

requirements specified in Regulation 55 of the Mineral and Petroleum Resources

Development Act, 2002 (Act No. 28 of 2002) (MRPDA) and associated MPRDA Regulations

(GN R527 of 23 April 2004); and Regulation 34 of the Environmental Impact Assessment (EIA)

Regulations, 2014 (GN R326 of 7 April 2017), as amended (EIA Regulations, 2014)

promulgated under the National Environmental Management Act, 1998 (Act No. 107 of 1998)

(NEMA), respectively.

Compliance with the conditions of the Environmental Authorisation (EA) and commitments of

the Environmental Management Programme (EMPR) was rated using the evaluation criteria

described in the evaluation criteria table below.

Evaluation Criteria

Non-Compliance

(NC)

These are areas were found non-compliant as observed during the site visit

to stated commitments of EMPR conditions.

Compliance (C)

These are areas which were found compliant as observed during the site

visit, and evidence provided, to the stated commitments of the EMPR

conditions.

Not Applicable

(N/A)

These are areas which were found not relevant to the operations at this

phase of the activity, i.e. construction and/or decommissioning phase

commitments.

Based on the evaluation criteria above, Mooikraal scored the following for compliance against

the EA and EMPR.

Compliance Calculations

Criteria EA

Conditions %

EMPR

Commitments %

Non-Compliance (NC) 7 11 12 19

Compliance (C) 55 89 52 81

Not Applicable (N/A) 14 - 16 -

Total Applicable 62 100 64 100

Based on site observations and the findings of the audit, the following recommendations were

made:

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● The eradication of invasive species is required in terms of the Alien and Invasive

Species Regulations (GN R 598 of 1 August 2014) promulgated under the National

Environmental Management Biodiversity Act, 2004 (Act No. 10 of 2004) (NEM:BA) and

any plan drafted in compliance with the legal requirements must be implemented.

Invasive species must be removed to prevent spreading to other areas around the site.

Mechanical methods should be used to remove the invasive species specifically at the

time of the year when the plants are not producing seeds which can result in the spread

of these species to other areas. The disposal of these species must be removed in a

controlled manner to prevent further spreading. Proof of training specific to the invasive

species identified on site must be provided either to the appointed contractor or the

person made responsible for the removal of alien invasive species;

● It is recommended that vehicles stored at the redundant storage area below the silo be

removed from site, ensure that they are fully drained of oils and stored within a

designated dirty water area; and

● Used tyres need to be removed and disposed of in accordance with the Waste Tyre

Regulations, 2017 (GN 1064 of 29 September 2017) (Waste Tyre Regulations)

promulgated under the National Environmental Management: Waste Act, 2008 (Act No.

59 of 2008).

The pressure of the fogger cannons installed at 3 Shaft needs to be checked to ensure that

the intended purpose of the fogger cannons is being achieved (i.e. dust suppression on the

coal stockpile area).

Mooikraal has appointed an Environmental Assessment Practitioner (EAP) to undertake a

Regulation 31 EMPR Amendment Process in terms of the EIA Regulations, 2014 and to apply

for a Water Use Licence (WUL) in terms of Section 21 of the National Water Act, 1998 (Act

No. 36 of 1998) (NWA). The authorisation of the Regulation 31 EMPR Amendment application

and WUL application will allow for most conditions identified as non-compliant in the audit to

be addressed.

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TABLE OF CONTENTS

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

1.1 Project Description .................................................................................................. 1

1.1.1 Current Mining Activities ................................................................................... 1

1.2 Objectives of the Audit............................................................................................. 3

2 Methodology ................................................................................................................. 3

3 Assumptions and Limitation .......................................................................................... 4

4 Auditor Details .............................................................................................................. 4

5 Auditor Declaration ....................................................................................................... 5

6 Site Observations ......................................................................................................... 7

6.1 Water Management ................................................................................................. 7

6.2 Waste Management ................................................................................................ 9

6.3 Fuel, Oil and Workshop Areas ................................................................................. 9

6.3.1 Fuel and Hydraulic Oil Areas ............................................................................ 9

6.3.2 Engineering Workshop ................................................................................... 11

6.4 Pollution Control Dams .......................................................................................... 11

6.5 Dust Suppression at 3 Shaft .................................................................................. 12

6.6 Sewage Treatment Plant ....................................................................................... 13

6.7 Laydown Area and Overburden Stockpile.............................................................. 14

6.8 3 Shaft ................................................................................................................... 16

6.9 Conveyor Belt between Mooikraal and 3 Shaft ...................................................... 18

7 Compliance Ratings ................................................................................................... 19

8 Financial Provision and Rehabilitation ......................................................................... 19

9 Recommendations & Conclusion ................................................................................ 20

LIST OF FIGURES

Figure 6-1: Concreted overflowing sump ............................................................................... 7

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Figure 6-2: Fenced overflowing sump ................................................................................... 7

Figure 6-3: Ponding near the sump near the workshop ......................................................... 8

Figure 6-4: Ponding near the hydraulic oil storage area ........................................................ 8

Figure 6-5: Sump with the oil skimmer .................................................................................. 8

Figure 6-6: Wood collection area........................................................................................... 9

Figure 6-7: Scrap metal collection area ................................................................................. 9

Figure 6-8:Bunded wall capacity ......................................................................................... 10

Figure 6-9: No oil spills ........................................................................................................ 10

Figure 6-10: Oil spill kit available at the hydraulic oil area ................................................... 10

Figure 6-11: The cleaned bunded area for the hydraulic oil ................................................. 10

Figure 6-12: Front of workshop area ................................................................................... 11

Figure 6-13: Machinery maintained at the workshop area ................................................... 11

Figure 6-14: North PCD ...................................................................................................... 12

Figure 6-15: Newly renovated PCD spill way ...................................................................... 12

Figure 6-16: Dust Suppression fogger cannon .................................................................... 12

Figure 6-17: Dust Suppression fogger cannons along the haul road ................................... 12

Figure 6-18: Aerator tank for the aeration process .............................................................. 13

Figure 6-19: Drying bed ...................................................................................................... 13

Figure 6-20: Bricks at the laydown area .............................................................................. 15

Figure 6-21: Redundant cars near the silo .......................................................................... 15

Figure 6-22: Used tyres ....................................................................................................... 15

Figure 6-23: Steel pipes ...................................................................................................... 15

Figure 6-24: Overburden stockpile ...................................................................................... 16

Figure 6-25: Unsuccessful vegetation on the overburden stockpile ..................................... 16

Figure 6-26: Stormwater management at 3 Shaft ................................................................ 17

Figure 6-27: Coal being stockpiled ...................................................................................... 18

Figure 6-28: Biomonitoring along the conveyor belt ............................................................ 19

Figure 6-29: Conveyor belt and water pipeline from Mooikraal ............................................ 19

LIST OF TABLES

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Table 2-1: Evaluation Criteria ................................................................................................ 4

Table 4-1: Senior Auditor ...................................................................................................... 4

Table 4-2: Assistant Auditor .................................................................................................. 5

Table 7-1: Summary Compliance for Mooikraal ................................................................... 19

Table 8-1: Financial Provision for Mooikraal Colliery (Jones and Wagener, 2019) .............. 20

LIST OF APPENDICES

Appendix A: EA Checklist

Appendix B: EMPR Checklist

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1 Introduction

Digby Wells Environmental (hereafter “Digby Wells”) was appointed by Sasol Mining (Pty) Ltd

to undertake an Environmental Audit for the Sigma Colliery: Mooikraal and the 3 Shaft

Operations (hereafter “Mooikraal”).

The audit was done in fulfilment of the performance assessment and environmental auditing

requirements specified in Regulation 55 of the Mineral and Petroleum Resources

Development Act, 2002 (Act No. 28 of 2002) (MRPDA) and associated MPRDA Regulations

(GN R527 of 23 April 2004); and Regulation 34 of the Environmental Impact Assessment (EIA)

Regulations, 2014 (GN R326 of 7 April 2017), as amended (EIA Regulations, 2014)

promulgated under the National Environmental Management Act, 1998 (Act No. 107 of 1998)

(NEMA), respectively.

1.1 Project Description

Sasol Mining commenced with its mining operations at Sasol Sigma Colliery in the 1950s with

the aim to supply coal to Sasol Chemical Industries, now referred to as Sasolburg Operations

(SO) from both its underground and strip-mining operations. The Wonderwater and Mohlolo

shafts ceased operations in 2006.

In 2005, Mooikraal became the operational shaft to supply coal to the SO. Mooikraal is located

approximately 17.7 km southwest of Sasolburg in the Fezile Dabi District Municipality, Free

State Province. Mooikraal has a Life of Mine (LoM) of 34 years and will be operational until

2039.

The Mooikraal operations include the incidental 3 Shaft coal handling complex (3 Shaft)

located within the town of Sasolburg.

The Environmental Audit was undertaken to determine compliance with the EMPR and EA for

Mooikraal, inclusive of 3 Shaft.

1.1.1 Current Mining Activities

Mooikraal is an underground mine that is currently mining five underground sections.

Underground workings are accessed via an incline shaft which was constructed utilising a box

cut method. The soil extracted from the incline shaft was stockpiled and allowed to be

vegetated naturally along the outside of the incline shaft. This soil will be utilised once LoM is

reached and rehabilitation commences.

The incline shaft is utilised to allow vehicles, machinery and personnel to both enter and exit

the underground workings. Mooikraal is extracting coal utilising the underground bord and

pillar mining method, however in some areas high extraction mining is taking place. The coal

is transported via conveyor belt underground and brought to surface via the same incline shaft

which is used to enter the mine. The coal is brought to surface and stored in a silo that has

capacity to store one day’s volume of coal, should supply issues be identified such as the

need to undertake maintenance activities. The coal is then conveyed from Mooikraal to 3 Shaft

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via an overland conveyer belt, where it is crushed and screened prior to being sent to SO for

further use.

The following infrastructure is present at Mooikraal:

● Incline Shaft;

● Pollution Control Dams (PCDs);

● Three sumps (Wash bay, fuel storage, shaft complex);

● Clean water channels;

● Soil stockpiles;

● Material laydown areas;

● One waste rock dump;

● Sewage Treatment Plant (STP);

● One waste storage area;

● Workshops;

● Bulk fuel and oil storage area;

● Conveyor belt;

● 10 ML Pipeline from Sigma Colliery: Mooikraal to SO;

● 7 ML Pipeline from Kleinvlei Shaft to SO; and

● Office Blocks.

The following infrastructure is present at 3 Shaft:

● Primary processing plant;

● Run of Mine (RoM) stockpile area;

● Stacker/ reclaimer;

● Chutes;

● Workshops;

● Waste storage area;

● Cement water transfer dam;

● Old Dams currently not in use and proposed to be demolished;

● Water reservoir for the fogger cannons;

● Conveyor belts; and

● Material storage yard.

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1.2 Objectives of the Audit

The objectives of the environmental audit are:

● To determine Mooikraal’ s level of compliance with the commitments contained in the

EA and approved EMPR; and

● To assess the appropriateness and suitability of the EA and EMPR to provide for the

mitigation of impacts associated with activities and future developments at Mooikraal.

2 Methodology

The methodology used in the undertaking of the environmental audit was as follows:

● A checklist of the EA conditions and EMPR commitments for Mooikraal;

● A site assessment was undertaken to assess compliance on 13 November 2019;

● Discussions took place prior, during and after the site assessment with Ms Lisa Grobler;

and

● Review of all documentation that was provided to Digby Wells during the site

assessment and via email thereafter was completed.

This audit report is compiled in accordance with the requirements of Regulations 34 and

Appendix 7 of the EIA Regulations, 2014 and will contain the following:

● Details and expertise of the independent person(s) who prepared the report;

● A declaration that the auditor is independent in a form as may be specified by the DMR;

● The scope of, and the purpose for which, the audit report was prepared;

● A description of the methodology adopted in preparing the audit report;

● An evaluation of compliance with the requirements of the EA and EMPR;

● A determination of whether the EA, EMPR and Closure Plan, if applicable, sufficiently

provide for the avoidance, management and mitigation of environmental impacts and

risks;

● An identification of potential shortcomings of the EA, EMPR and Closure Plan, if

applicable;

● A description of any assumptions made, and any uncertainties or gaps in knowledge;

and

● Recommendations on how identified deficiencies of and non-compliance to the EA and

EMPR EA requirements should be rectified.

Compliance with the commitments of the EA and EMPR were rated using the evaluation

criteria described in Table 2-1 below.

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Table 2-1: Evaluation Criteria

Non-Compliance

(NC)

These are areas were found non-compliant as observed during the site visit

to stated commitments of the EA and EMPR.

Compliance (C)

These are areas which were found compliant as observed during the site

visit, and evidence provided, to the stated EA conditions and commitments

of the EMPR.

Not Applicable

(N/A)

These are areas which were found not relevant to the operations at this

phase of the activity, i.e. construction, decommissioning phase

commitments.

3 Assumptions and Limitation

This report is subject to the following assumptions and limitations:

● The findings recorded in this report are limited to the site observations made and areas

visited during the site assessment undertaken on 13 November 2019;

● The auditors did not visit all areas of the operation and as a result, only areas identified

by the audit team in conjunction with the operation were visited and are referred to in

this audit report;

● The scope of work specifically excludes an audit referred to in the Regulations on Use

of Water for Mining and Related Activities aimed at the Protection of Water Resources

(GN 704 of 4 June 1999) (GN 704);1 and

● Although care was taken to audit as comprehensively as possible, auditing is done on

a sample basis and based on the conditions as they were found on the day of the audit.

4 Auditor Details

Table 4-1 and Table 4-2 below sets out the auditors’ details.

Table 4-1: Senior Auditor

Name and

qualifications

Ms Barbara Wessels

Barbara completed her B. Sc. in Geography and Environmental Management at the

University of Johannesburg in 2005. She manages the Environmental Services and

Ecology & Atmospheric Sciences Divisions, which include Environmental

Management, Compliance, GIS, Air Quality, Aquatics, Fauna and Flora, and

Wetlands.

She has over 10 years’ experience and is responsible for the management of

integrated projects both locally (South Africa) and internationally and is occasionally

involved in the undertaking of closure and rehabilitation studies, due diligences and

environmental auditing.

1 GN 704 in GG 20119 of 4 June 1999.

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Company Digby Wells and Associates (South Africa) (Pty) Ltd

Telephone: 011 789 9495 Email: [email protected]

Table 4-2: Assistant Auditor

Name and

qualifications

Ms Puleng Chabeli

BSc Environmental Science and Bachelor of Laws (LLB)

Puleng is an assistant auditor. She has experience within the public sector working

as an International Climate Change Relations and Negotiations Intern in the

Climate Change Division of the National Department of Environmental Affairs

(DEA). Puleng has experience working with international legislation, in particular,

the United Nations Framework Convention on Climate Change (UNFCCC) where

she provided assistance in the International Negotiation space writing opinions and

developing recommendations on policies on climate change; Article 6 of the Paris

Agreement and bi-lateral agreements between developing countries.

Company Digby Wells and Associates (South Africa) (Pty) Ltd

Telephone: 011 789 9495 Email: [email protected]

5 Auditor Declaration

The auditors declare that they acted independently and compiled this audit report using the

information furnished by the client.

I, Barbara Wessels, herewith declare that:

● I act as the independent environmental practitioner in this Audit;

● I will perform the work relating to the Audit in an objective manner, even if this results

in views and findings that are not favourable to the Holder;

● I declare that there are no circumstances that may compromise my objectivity in

performing such work;

● I have expertise in conducting environmental audits, including knowledge of the

standards, legislation and any guidelines that have relevance to the activity;

● I have no, and will not engage in, conflicting interests in the undertaking of the audit;

and

I declare that all the information furnished by me for this Audit is true and correct.

Signature of the Lead Auditor:

Date: January 2020



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I, Puleng Chabeli, herewith declare that:

● I act as the independent environmental practitioner in this Audit;

● I will perform the work relating to the Audit in an objective manner, even if this results

in views and findings that are not favourable to the Holder;

● I declare that there are no circumstances that may compromise my objectivity in

performing such work;

● I have expertise in conducting environmental audits, including knowledge of the

standards, legislation and any guidelines that have relevance to the activity;

● I have no, and will not engage in, conflicting interests in the undertaking of the audit;

and

I declare that all the information furnished by me for this Audit is true and correct.

Signature of the Lead Auditor:

Date: January 2020

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6 Site Observations

The observations that were made on site are discussed in the below sections.

6.1 Water Management

Mooikraal obtains potable water from the Metsimaholo Local Municipality for the office blocks

and for drinking water underground.

Three sumps are located at the Mooikraal operation to collect water generated around the

shaft complex. Two sumps are located near the wash bay and at the fuel and oil storage area

while the third sump is located at the incline shaft. The sumps separate hydrocarbons and

sludge from water. The water drains to the South Dam PCD which then flows to the North

Dam PCD.

It was observed on site, as seen in Figure 6-1 and Figure 6-2, that the stormwater

management sumps used for dirty water runoff prior to the water entering the PCDs were at

full capacity and overflowing and this is due to heavy rains the day before the site visit.

Maintenance and good housekeeping practices to be implemented to ensure these sumps

operate at optimal capacity.

Figure 6-1: Concreted overflowing sump

Figure 6-2: Fenced overflowing sump

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Ponding of water, due to rains the day before, was observed around the sump area near the

workshop and hydraulic oil area as shown in Figure 6-3 and Figure 6-4 below. The sump with

the oil skimmer is also at full capacity as seen in Figure 6-5 and should either be emptied or

the capacity increased.

Figure 6-3: Ponding near the sump near

the workshop

Figure 6-4: Ponding near the hydraulic

oil storage area

Figure 6-5: Sump with the oil skimmer

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6.2 Waste Management

Waste generated at Mooikraal is stored in a designated storage area which is separated into

various waste streams namely wood waste, scrap metal and hazardous waste as seen in

Figure 6-6 and Figure 6-7.

Figure 6-6: Wood collection area

Figure 6-7: Scrap metal collection area

Mooikraal considers general waste to be hazardous as all general waste is obtained from the

underground workings and anticipated to be contaminated with hydrocarbons. It was

communicated that hazardous waste is removed by EnviroServ and disposed at Holfontein

Landfill. Safe disposal certificates, purchase orders and invoices were provided as proof of

the safe disposal of waste. Oil drums were being removed on site at the time of the audit.

6.3 Fuel, Oil and Workshop Areas

6.3.1 Fuel and Hydraulic Oil Areas

Fuel and hydraulic oil are stored on site in bulk storage tanks. These tanks are stored within

a bunded area and on a concrete standing. The oil storage area contains a total of 73 000 litres

and has a bund wall capacity to store 150% of the total capacity of the bundwall which amounts

to 113 500 litres.

During the site visit, no oil spillages were identified, and this can be due to wet conditions due

to the rain the day before the site visit. The hydraulic oil bunded area was cleaned and an oil

spill kit was placed outside the bunded area.

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Figure 6-8:Bunded wall capacity

Figure 6-9: No oil spills

Figure 6-10: Oil spill kit available at the

hydraulic oil area

Figure 6-11: The cleaned bunded area

for the hydraulic oil

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6.3.2 Engineering Workshop

The workshop area was well maintained and clean.

Figure 6-12: Front of workshop area

Figure 6-13: Machinery maintained at the

workshop area

6.4 Pollution Control Dams

Two PCDs are located at the Mooikraal operation namely South Dam and North Dam. South

Dam is utilised as a settlement dam. The water, once settled, is then allowed to flow naturally

to North Dam.

Water is pumped to 3 Shaft where it is used for dust suppression at the stockpiles as well as

to the SO for disposal through their systems. Prior to the installation of the water pipeline the

North PCD overflowed regularly into the Kromelmboogspruit due to a lack of capacity in the

PCD.

In 2013 it was, determined that the both the South and North PCDs, which are clay lined, were

unable to contain the amount of water being pumped from the underground workings to the

dams which resulted in multiple overflows over the past few years. However, the PCDs have

had no overflows in recent years.

According to the Mooikraal water monitoring by IGS, the report indicated monitoring of various

boreholes and exceedances were identified and the quality of the groundwater was discussed

to be affected by either the geology of the area, tailings at the Waste Ash Site at Sasol 1, 3

Shaft coal stockpile, fertiliser on cultivated land and the borehole assessed being near it and

the proximity of boreholes to explosives used for blasting underground.

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Figure 6-14: North PCD

Figure 6-15: Newly renovated PCD spill

way

6.5 Dust Suppression at 3 Shaft

Dust suppression is being undertaken at 3 Shaft using fogger cannons installed along the haul

road.

Figure 6-16: Dust Suppression fogger

cannon

Figure 6-17: Dust Suppression fogger

cannons along the haul road

The dust suppression mechanisms employed at 3 Shaft as shown in Figure 6-16 and Figure

6-17 above were observed to not have the required pressure as the water was not reaching

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the stockpile area, this was due to the fogger cannons still being in testing phase and not fully

operational.

6.6 Sewage Treatment Plant

The STP located on site is utilised to treat all sewage from Mooikraal. The sewage water

collected from the office blocks and change houses via a sewage network is collected and

pumped into a bioreactor. The sewage is then pumped into an aeration tank shown in Figure

6-18. Aeration is utilised to assist in the promotion of microbial growth which helps in the

breakdown of wastewater. The sewage is then transferred to a surge tank where the sludge

is allowed to settle. The water is transferred to a baffle tank where the water is treated with

chemicals and dosed with chlorine and then discharged into the nearby watercourse namely

the Kromelmboogspruit in accordance with the approved Integrated Water Use Licence

(IWUL). The sludge that is removed from the aeration tanks is allowed to dry in drying beds

as shown in Figure 6-19, after which it is removed by EnviroServ. No incineration of sludge is

being undertaken on site. The STP is managed and monitored by Proxa.

Figure 6-18: Aerator tank for the aeration

process

Figure 6-19: Drying bed

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6.7 Laydown Area and Overburden Stockpile

The laydown area is well organised with material placed in batches. It is evident from Figure

6-20 and Figure 6-23 that the material will be used for continuous maintenance. Figure 6-21

and Figure 6-22 however show used tyres and redundant cars which can be classified as a

waste.

The used tyres need to be removed and disposed of in accordance with the Waste Tyre

Regulations, 2017 (GN 1064 of 29 September 2017) (Waste Tyre Regulations) promulgated

under the National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008).

The National Norms and Standards for Storage of Waste (GN R 926 of 2013) also apply to

the laydown area for any redundant material which would need to be disposed of. Best

environmental practice, as per the Norms and Standards, is defined as performing a particular

activity or activities in the most suitable, appropriate, advantageous or best advised manner

in order to achieve the highest standards while performing or exercising such activity or

activities.

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Figure 6-20: Bricks at the laydown area

Figure 6-21: Redundant cars near the

silo

Figure 6-22: Used tyres

Figure 6-23: Steel pipes

This overburden stockpile which is located near the silo will be used for rehabilitation purposes

when Mooikraal reaches its LoM. The overburden stockpile is located in a clean water area

and has a berm constructed around it. The vegetation of the overburden stockpile was not

successful, and erosion can be observed and this is due to the gradient of the slope being too

steep (Digby Wells Environmental Mooikraal Audit, 2018).

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Figure 6-24: Overburden stockpile

Figure 6-25: Unsuccessful vegetation on

the overburden stockpile

6.8 3 Shaft

The coal stockpile area at 3 Shaft is well maintained. The only concern at the area is the

stormwater management particularly the dirty water management. Dirty water generated from

the primary processing plant has a high probability of flowing to the Leeuspruit and cause

water contamination.

As identified in the 2019 WUL Audit for Mooikraal, stormwater management was flagged as

an issue. It was noted that the stormwater management measures as shown in Figure 6-26

below were insufficient to contain the potential runoff water from the primary plant is entering

into the Leeuspruit.

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Figure 6-26: Stormwater management at 3 Shaft

The proposed measure to address this concern is to upgrade the stormwater management at

the stockpile area by constructing silt traps and the possible re-use of water back into the dust

suppression system.

This upgrade was assessed in the Regulation 31 EMPR Amendment application that was

submitted to the DMR on 15 May 2019 and the WUL Application that was submitted to the

Department of Water and Sanitation (DWS) in November 2018.

Decisions are still pending by both authorities. Without granting the authorisation to undertake

these upgrades, the possibility of surface water contamination remains.

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Figure 6-27: Coal being stockpiled

6.9 Conveyor Belt between Mooikraal and 3 Shaft

A conveyer belt has been constructed between Mooikraal and 3 Shaft to convey the coal to

the primary processing plant at 3 Shaft. The conveyer belt is covered and utilises water

sprayers to reduce dust generation. A maintenance road (dirt road) has been constructed

along the conveyer belt.

Biomonitoring along the conveyor belt is conducted by Digby Wells Environmental on a bi-

annual basis as per authorised WUL requirements (WUL number 08/C22K/CIGJFAE/6981,

dated 10/01/2018).

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Figure 6-28: Biomonitoring along the

conveyor belt

Figure 6-29: Conveyor belt and water

pipeline from Mooikraal

7 Compliance Ratings

As shown in Table 7-1, Mooikraal was found 89% compliant with the EA conditions and 81%

compliant with the EMPR commitments.

Table 7-1: Summary Compliance for Mooikraal

Criteria EA

Conditions %

EMPR

Commitments %

Non-Compliance (NC) 7 11 12 19

Compliance (C) 55 89 52 81

Not Applicable (N/A) 14 - 16 -

Total Applicable 62 100 64 100

8 Financial Provision and Rehabilitation

Mooikraal is an underground operation therefore very limited concurrent rehabilitation is

undertaken during the operational phase of the mine. Once the shaft has reached its LoM,

rehabilitation will be undertaken to remove all infrastructure from the site and seal the box-

cut/adit.

After decommissioning, the box-cut and adit will be filled with rubble from the overburden

stockpiles and concrete generated from demolition of infrastructures. Jones and Wagener (Ref

No. JW047/15/E473 - Rev 4) updated the calculation of the financial provision for the various

Sasol operational areas in March 2019 and this included the Mooikraal Operations.

Audit Report


SAS5921



Table 8-1: Financial Provision for Mooikraal Colliery (Jones and Wagener, 2019)

Shaft Operational Status Financial Provision

MKR1 – Sigma No 3 Shaft Operational R 11 016 424.36

MKR2 – Mooikraal Operational R 74 063 714.64

MKR3 – Old Sigma Coal

Handling Operational R 35 213 788.19

Total R 120 293 927.19

9 Recommendations & Conclusion

Based on site observations and the findings of the audit, the following recommendations were

made:

● The eradication of invasive species is required in terms of the Alien and Invasive

Species Regulations (GN R 598 of 1 August 2014) promulgated under the National

Environmental Management Biodiversity Act, 2004 (Act No. 10 of 2004) (NEM:BA) and

any plan drafted in compliance with the legal requirements must be implemented.

Invasive species must be removed to prevent spreading to other areas around the site.

Mechanical methods should be used to remove the invasive species specifically at the

time of the year when the plants are not producing seeds which can result in the spread

of these species to other areas. The disposal of these species must be removed in a

controlled manner to prevent further spreading. Proof of training specific to the invasive

species identified on site must be provided either to the appointed contractor or the

person made responsible for the removal of alien invasive species;

● It is recommended that vehicles stored at the redundant storage area below the silo be

removed from site, ensure that they are fully drained of oils and stored within a

designated dirty water area; and

● Used tyres need to be removed and disposed of in accordance with the Waste Tyre

Regulations, 2017 (GN 1064 of 29 September 2017) (Waste Tyre Regulations)

promulgated under the National Environmental Management: Waste Act, 2008 (Act No.

59 of 2008).

The pressure of the fogger cannons installed at 3 Shaft needs to be checked to ensure that

the intended purpose of the fogger cannons is being achieved (i.e. dust suppression on the

coal stockpile area).

Mooikraal has appointed an Environmental Assessment Practitioner (EAP) to undertake a

Regulation 31 EMPR Amendment Process in terms of the EIA Regulations, 2014 and to apply

for a Water Use Licence (WUL) in terms of Section 21 of the National Water Act, 1998 (Act

No. 36 of 1998) (NWA). The authorisation of the Regulation 31 EMPR Amendment application

and WUL application will allow for most conditions identified as non-compliant in the audit to

be addressed.

Appendix A: EA Checklist

Compliance

2018Compliance 2019

C /NC/NA C /NC/NA

1.1

Sasol Mining (Pty) Ltd (herein referred to as

the holder) shall be responsible for ensuring

compliance with the conditions of this

approval letter and the environmental

management commitments/measures

contained in the EMPr. This includes any

person acting on the holder's behalf,

including but not limited to an agent, servant,

contractor, subcontractor, employee,

consultant or any person rendering a service

to mining area in which this EMPr relates to.

C No further action required

Mooikraal remains an entity of Sasol Mining and therefore still the relevant

holder in relation to the EA condition.

No changes since the previous audit. Therefore, no further action is

required.

C

The principles set out in section 2 of the

National Environmental Management Act,

1998 (Act 107 of 1998) (NEMA) applies to

your mining operation as stipulated 1n

section 37(1)(a) of the MPRDA.

C

The Mooikraal operation aims to ensure that Section 2 of the

NEMA is adhered to. This is undertaken through the various

environmental procedures which aim to prevent degradation to

the environment as well as to promote sustainable development.

These procedures include:

■ Emergency Preparedness and Response (Ref No. SIG IMS

447000);

■ Procedure for the Handling of Oil Spills and Oil Recycling

(Ref No. SIG (EM) IMS SOP/ 008);

■ Standard operating procedure for the handling of sewage at

Sigma Mooikraal mine (Ref No. SOP 4.4.6/07); and

■ Site Specific Standard Operating Procedure Waste

Management (Ref No. IMS(EM) 4.4.6 / SOP 001).

Additionally management of various aspects which include

water, waste, air quality, aquatic environments and heritage is

undertaken to prevent deterioration of the environment and aims

to minimise the impact of the mine.

No further action required

Audit Comments

DMR - Authorisation for the consolidation of EMP FS 221 MR and FS 224 MR, dated 12 April 2016, reference: FS 30/5/1/2/3/2/2 (221) ER

1) SCOPE OF AUTHORISATION

Activity Proposed Mitigation Measure Comments 2018Action Plan - Measures to be Implemented to

Achieve Compliance

Mooikraal is an entity of Sasol Mining which takes responsibility

to ensure the Environmental Authorisation (EA) and EMPr

conditions are adhered to while the mine is operational.

Environmental audits are undertaken by Mooikraal on an annual

basis as well as Water Use Licence (WUL) audits which

indicates Sasol’s compliance to their EA as well as the EMPr.

Digby Wells has been contracted by Sasol Mining to undertake

the 2018 external audit as the Independent Environmental

Assessment Practitioner (EAP). Additionally Mooikraal ensures

that the contractors undertaking work at the mine are informed of

the conditions of the EMPr and the requirement to abide by

these conditions.

1.2

All mining activities must adhere to the

provisions of regulations 56, 64, 66, 68, 69,

70, 71 and 73 of the Regulations of the

MPRDA.

C

The Mooikraal operation aims to abide by the following

provisions:

■ Regulation 56 (Principles for mine closure);

■ Regulation 64 (Air quality management and control);

■ Regulation 66 (Noise management and control);

■ Regulation 68 (Water management and pollution control);

■ Regulation 69 (Disposal of waste material);

■ Regulation 70 (Soil pollution and erosion control);

■ Regulation 71 (.Sanitation of surface); and

■ Regulation 73 (Management of residue stockpiles and

deposits).

This is undertaken through compliance with the conditions of the

EMPr as the EMPr has been compiled with consideration of the

MPRDA. Additionally management and monitoring plans are

undertaken with the aim to ensure aspects are kept within

acceptable standards. Internal legal compliance audits are

undertaken by head office. During the site assessment a legal

audit was being undertaken.


1.3

Mooikraal operates uth the parameteres of the MPRDA Regulations as per

the EA condition. Management and monitoring plans are still undertaken

with the aim to ensure aspects are kept within acceptable standards.

Internal legal compliance audits are undertaken by head office.


required.

C

Mooikraal has management plans in place that aim to ensure adhearance

to Section 2 of NEMA. The management plans ar

No changes since the previous audit.

Therefore, no further action is required.

C

1.4

The holder must at all times give effect to the

general objectives of the integrated

environmental management laid down in

Chapter 5 of NEMA as stipulated in section

38(1)(a) of the MPRDA.

NC

Based on the review of the EMP and correlated with

the legislative requirements of the EIA Regulations,

2014 (as amended) it is concluded that 3 Shaft which

includes the operation of the primary processing plant

is not sufficiently described, the impacts assessed

and mitigation measures provided in the EMPr to

confirm an environmental authorisation for the

activities or the area on which the activities are taking

place. The lack of detail in the EMPr with regard to 3

Shaft can be rectified by means of a Regulation 31

amendment application process. Mooikraal have

appointed Digby Wells to undertake the required

Regulation 31 amendment process to rectify the

issues identified by this audit report. This process has

however not commenced yet.

Mooikraal has appointed an Environmental Assessment Practitioner (EAP)

to undertake a Regulation 31 EMPR Amendment Process in terms of the

EIA Regulations, 2014 and to apply for a Water Use Licence (WUL) in

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

(NWA). The authorisation of the Regulation 31 EMPR Amendment

application and WUL application will allow for most conditions identified as

non-compliant in the audit to be addressed.

The authorisation has not been granted as yet and thus this EA

commitment remains non-compliant until such a time that the changes are

authorised.

NC

1.5

Any changes to, or deviation from the mining

project description set out in the EMPr and

the mining right must be approved in writing

by the Department before such changes or

deviation may be effected. In assessing

whether to grant such approval or not, the

Department may request any information as

is deems necessary to evaluate the

significance and impacts of such changes or

deviation and it may be necessary for the

holder to apply for further authorization in

terms of the applicable legislation of the

time.


Changes to the mining project description has been reflected into the

Regulation 31 Amendment Process. Until that is granted, the current

mining project description is that which is included in the current EMPR.


required.

C

1.6

Mining activities may only be carried out at

the properties covered by the mining right

indicate in which this EMPr is approved for.


Changes to the mining project description has been reflected into the

Regulation 31 Amendment Process. Until that is granted, the current

mining project description is that which is included in the current EMPR.


required.

C

1.7

Where any of the holder's contact details

change; including name of the responsible

person, physical or postal address/ or

telephonic details, the holder must notify the

Department as soon as the new details

become known to the holder.

NA No further action required

No changes with regards to the holder's contact details including name of

the responsible person, physical or postal address/ or telephonic details

have occurred.

If the change takes place, the DMR is to be informed.

NA

1.8

This approval and the approved EMPr do not

negate the responsibility of the holder to

comply with any other statutory requirements

that may be applicable to the undertaking of

mining and any mining related activities.


Mooikraal is held to approved EA conditions, EMPR commitments, NEMA,

NEM:WA, NEM:AQA, NEM:BA, NWA and all consequential laws and

regulations.

This has not changed since the previous audit and Moiikraal is

undertskaing a legal compliance audit to ensure complaince with all laws.

C

As per our evaluation of the EMPr it is noted that the project

description must be updated to reflect certain aspects which are

currently being undertaken at the Mooikraal Colliery and 3 Shaft.

Additionally Mooikraal are proposing to relocate the conveyer

belt as the underground mining operation is proposing to mine in

this area. The water management system is also proposed to be

upgraded to avoid further accidently discharges of contaminated

water into the Leeuspruit. A basic assessment and 31

amendment process is currently being undertaken to assess the

impacts associated with the proposed project and obtain the

required authorisation.

The mining activities undertaken for the Mooikraal operation

were confirmed to be undertaken within the mining right area.

The properties included in the mining right area are listed in the

mining right (FS 30/5/1/2/3/2/2 (221) MR). A mine plan was

provided during the site assessment which indicated where

mining had been undertaken and where mining would occur in

the future. It is however noted that 3 Shaft is currently not

incorporated within the Mooikraal Mining Right. It is as per a

number of legal options that the definition of Mining Operations

is “any operation relating to the act of mining and matters directly

incidental thereto”

It was communicated that no changes with regards to the

holder's contact details including name of the responsible

person, physical or postal address/ or telephonic details have

occurred. It was noted that should changes to the mining right

holder occur these changes will be communicated to the DMR.

Mooikraal are committed to ensuring the operation not only

abides by the MPRDA but by also complies with other

legislations with specific reference to the National Environmental

Management Act (Act 107 of 1998 (NEMA), National

Environmental Management: Waste Act (Act 59 of 2008)

(NEM:WA), National Environment Management: Air Quality Act

(Act 39 of 2004) (NEM:AQA), National Water Act (Act 36 of

1998) (NWA), National Heritage Resources Act (No. 25 of

1999) (NHRA) and National Environmental Management:

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

provincial and local legislation. A legal audit is undertaken every

second year to determine the compliance of the Mooikraal

Operations with the relevant legislation. At the time of the site

assessment an internal legal audit was being completed

The Mooikraal operation aims to ensure that Chapter 5 of NEMA

is complied with to ensure all environmental management is

undertaken correctly and all impacts that the mine may have on

the environment is assessed and mitigated. It is however note

that the Mooikraal EMPr has failed to assess and provide

mitigation measures for all aspect specific to 3 Shaft. A non-

compliance has been identified against Section 24N with

regards to the effectiveness of the EMPr. Please refer to

Section 8 of the audit report for further details regarding the non-

compliance. It can be concluded however that in accordance

with the NEMA and EIA Regulations 2014 (as amended), the

Mooikraal EMPr is substantively lacking with regard to 3 Shaft in

the following respects:

■ 3 Shaft and its associated activities are not included in Section

1.1 or 1.2 of the EMPr, the sections which give the project

background and description respectively;

■ The Mooikraal EMPr does not adequately incorporate the

activities, aspects, impacts and associated mitigation steps at 3

Shaft into Section 4 – Environmental Impact Assessment,

Section 5.3 Environmental Management Programme, or Section

7 Environmental Monitoring.

■ Infrastructure (figure 2) and locality plans (figure 1) do not

indicate the infrastructure at 3 Shaft, nor the physical location of

3 Shaft, the mining right boundary does not correlate with the

Plan of Land Amendment of a Mining Right (dated 05/02/2016).

1.9

The holder must ensure that all areas where

the authorized mining activities occur have

controlled access to ensure safety of people

and animals.


Mooikraal is fenced to minimise any potential threats between animals and

mine personnel.


required.

C

1.1

Mine waste will not be allowed to be

deposited in natural drainage lines or erosion

gullies


Mooikraal and 3 Shaft still stores waste in the ISO yards which has

designated waste storage areas, one at Mooikraal and one at 3 Shaft,

which is separated into various waste streams namely wood waste, scrap

metal and hazardous waste. The hazardous waste is stored in waste skips

and signage indicating the waste stream is placed above the waste skip.

Mooikraal considers general waste to be hazardous as general waste is

obtained from the underground workings and anticipated to be

contaminated with hydrocarbons. It was communicated that hazardous

waste is removed by EnviroServ and disposed at Holfontein. Safe disposal

certificates were provided for the safe disposal of this waste.


required.

C

1.11

Dump structures must not be left on the

surface, this includes topsoil stockpiles,

overburden stockpiles, waste rock

stockpiles, tailing dumps and slimes dams.

NA

It is recommended as part of the NEMA EIA

Regulations, 2014 Regulation 31 amendment

process that Condition 1.11 of the EA is removed or

amended.

This commitment is not applicable at the present phase. NA

1.12

All excavations must be backfilled to the

natural surface levels if a bulk factor exists it

must be accommodated on the total area of

disturbance.

NC

Although full rehabilitation will not be undertaken until

LoM is reached it is recommended that rehabilitation

of the borrow pits should be undertaken to prevent

ponding of water and the spread of alien invasive

species. The area should be ploughed to make the

surface level. Additionally alien invasive management

measures must be implemented

Full rehabilitation will not be undertaken until end of LoM for the mine.

The borrow pit has been made free draining, it is well vegetated and

stable.

Additionally alien invasive management measures will be implemented in

the new year.

C

A surveyed plan must be submitted every

year to the Regional Manager that indicates:

■ The positions, footprints and volumes of

all topsoil stockpiles, overburden dumps,

waste rock dumps and slimes dams (Any

structure that is above the natural surface);

■ The positions, surface areas and depths

of all open pits; and

■ The positions and surface areas of all

rehabilitated areas (please indicate the status

of rehabilitation-backfilled,

profiled/landscaped, top soiled, vegetated or

monitoring and managing.

During the operation of the mine stockpiles including an

overburden damp, soil stockpiles and PCDs are located within

the mining right area. The overburden and soil stockpile will be

utilised once the mine reaches closure which will assist with the

rehabilitation of the mine. Additionally the PCDs are required for

the operation of the mine and water management. This condition

is considered not applicable as these structures will only be

removed once LoM is reached and rehabilitation of the mine will

be undertaken.

All excavations that have been formed as a result of the

operating of the mine will be rehabilitated once LoM is reached.

Borrow pits were observed during the site assessment. It was

noted that rehabilitation efforts had been undertaken however

further effort is required to ensure the borrow pits are free

draining. Ponding of water was observed and alien invasive

species were noted within the disturbed area.

1.13 C

Evidence was provided that indicated that the surveyed plan was

submitted to the Reginal Manager at the DMR on 17 April 2018.

It was communicated that an updated plan is submitted on an

annual basis every September. These plans indicate the

progression of the mine and position of all surface infrastructure.






draining, and alien invasive species are controlled.

Consideration should be taken to rehabilitate these borrow pits

during the operational life of the mine.


The mine is access controlled to ensure no unauthorised

personnel are permitted into the mine. During the site

assessment the auditors were required to provide identification

documentation as well as permission from the Environmental

Practitioner was required to gain access to the mine. The

access to the Mooikraal Colliery is permitted through the main

gate which is access controlled. Access to 3 Shaft is also only

permitted by one gate. To gain entry, access cards as well as a

biometric systems have been implemented. Fencing has been

constructed around the entire Mooikraal Colliery and 3 Shaft and

no entry signage has been erected. Fencing has also been

erected around the PCDs (both Mooikraal and 3 Shaft) which are

required to prevent the possibility of drowning and restrict

access. Signage has also been erected to discourage people

from entering the restricted area. Additionally entry to the

underground workings is also restricted by means of a shaft

guard which requires proof that the individual is fit to work prior

to that individual proceeding.

During the site assessment it was observed that waste

generated at Mooikraal and 3 Shaft is stored in the ISO yards

which has designated waste storage areas, one at Mooikraal

and one at 3 Shaft, which is separated into various waste

streams namely wood waste, scrap metal and hazardous waste.

The hazardous waste is stored in waste skips and signage

indicating the waste stream is placed above the waste skip.

Mooikraal considers general waste to be hazardous as general

waste is obtained from the underground workings and

anticipated to be contaminated with hydrocarbons. It was

communicated that hazardous waste is removed by EnviroServ

and disposed at Holfontein. Safe disposal certificates are

provided for the safe disposal of this waste. During the audit a

safe disposal certificate for the disposal of hazardous waste

was provided (Ref No.GP-SP240100). Good housekeeping

measures are in place. All waste is stored and handled in

accordance with the National Environmental Management:

Waste Act, 2008 (Act 59 of 2008) (NEM:WA) Norms and

standards for the Storage of Waste, 2013 as well as the Site

Specific Standard Operating Procedure Waste Management

(Ref No. IMS (EM) 4.4.6 / SOP 001).

Updated surveyed plans are submitted on an annual basis and

rehabilitation of excavations (i.e. the borrow pit) will be rehabilitated at the

mine's end of LoM. For now, the borrow pit is made free draining and alien

invasives controlled.


required.

C

2.1

In order to ensure safety, all employees must

be given the necessary personnel protective

equipment (PPE).


PPE was worn by individuals on site during the time of the audit. The mine

still supplies the PPE to the workers as per Section 6 of the Mine Health

and Safety Act, 1996 (Act 29 of 1996). The auditors were required to wear

appropriate PPE while walking around the mine.


required.

C

2.2

This approval letter and the approved EMPr

must be provided to the site operator(s) and

the requirements thereof must be made fully

known to him or her.


Lisa Grobler remians the appointed Environmental Manager at Mooikraal

and she ensures that the conditions of the EA and EMPr are complied with.

Lisa undertakes regular internal assessments to ensure compliance to

these conditions, where non-compliances are identified these issues are

raised and measures are taken to rectify the issue. Continuous

environmental awareness is undertaken at the mine to ensure all individuals

are aware of the EA and the EMPr conditions.


required.

C

2.3

Hauling routes for construction vehicles and

machinery must be clearly marked and

appropriate signaling must be posted to that

effect. Furthermore, movement of

construction vehicles and machinery must be

restricted to areas outside of the drainage

line or wet areas.


The Mooikraal Mine has been operational since 2005. No construction

activities are currently being undertaken at the mine. Therefore, this

condition is considered to be not applicable.

NA

2.4

Appropriate notification sign must be erected

at the construction site, warning the public

(residents, visitors etc.) about the hazard

around the mining area and presence of

heavy vehicles and machinery.





NA

2.5

Construction must include design measures

that allow surface and subsurface movement

of water along the drainage lines so as not to

impede natural surface and subsurface water

flow, and drainage measures must promote

the dissipation of storm water runoff.





NA

2.6

Vegetation clearance must be limited on

areas where the individual activities will

occur, and mitigation measures must be

implemented to reduce the risk of erosion

and alien species invasion.





NA

2.7

The holder must note that in terms of the

National Forest Act, 1998 (Act No. 84 of

1998) protected plant species, also listed in

must not be cut, disturbed, damaged,

destroyed and their products must not be

possessed, collected, removed, transported,

exported, donated, purchased or sold unless

permission is granted by the Department of

Agriculture, Forestry and fisheries.





NA

2.8

Construction areas (e.g. material lay down

areas), topsoil and subsoil must be protected

from contamination or pollution. Stockpiling

must not take place in drainage lines or areas

where it will impede surface water runoff.





NA

3) COMMENCEMENT/ CONTINUATION OF MINING ACTIVITIES

The Mooikraal Mine has been operational since 2005. No

construction activities are currently being undertaken at the mine.

Therefore, this condition is considered to be not applicable.



No clearance of vegetation is currently being undertaken

therefore this condition is considered to be not applicable.







During the site assessment it was observed that individuals

working at the mine are required to have their own PPE. The

type of PPE required is dependent on the tasks which needs to

be conducted. The mine supplies the PPE to the workers as per

Section 6 of the Mine Health and Safety Act, 1996 (Act 29 of

1996). The auditors were required to wear appropriate PPE

while walking around the mine.

Lisa Grobler has been appointed by the mine to ensure the

conditions of the EA and EMPr are complied with. All operational

managers and contractors are aware of and must comply with

these conditions. Lisa undertakes regular internal assessments

to ensure compliance to these conditions, where non-

compliances are identified these issues are raised and

measures are taken to rectify the issue. Continuous

environmental awareness is undertaken at the mine to ensure all

individuals are aware of the EA and the EMPr conditions







2.9

If any soil contamination is noted at any

phase of mining, the contaminated soil must

be removed to a licensed waste disposal

facility and the site must be rehabilitated to

the satisfaction of this Department and the

Department of Water and Sanitation. The

opportunity for the onsite remediation and re-

use of contaminated soil must be

investigated prior to the disposal and this

Department must be informed in this regard.


A Contaminated Land Assessment was conducted in by Geo Pollution

Technologies - Gauteng (Pty) Ltd and the report compiled for August

2019.

The report held for the Mooikraal Operations that none of the compounds

measured in the samples exceeded the SSV2 and Anion screening levels

for these two areas. In the samples from Mooikraal and 3 Shaft copper,

manganese and lead exceeded SSV1 values, but when considering the

background soil quality from South Africa and manganese in a World

Health Organisation report, none of the values that are exceeding are

regarded as significant. The arsenic value in sample Mooikraal discard

dump should be assessed in groundwater and surface water. Should there

be groundwater or surface water monitoring data around the two sites

close to Sasolburg, it would be prudent to check the levels of these

compounds in the sampling data.

C

2.1

An integrated waste management approach

must be implemented that is based on waste

minimization and must incorporate

avoidance, reduction, recycling, treatment,

reuse and disposal where appropriate.

Uncontaminated rubble generated on the

premises can be re-used as backfilling

material on any relevant site (if this

requirement exist). Ensure that no refuse or

rubble generated on the premises is placed,

dumped or deposited on the adjacent

properties or public places and open space.

NC

It is recommended that the vehicles stored in the

designated clean water area below the silo and

conveyer belt at Mooikraal Colliery should be

removed from site or stored within a designated dirty

water area. Rehabilitation of the area where the

vehicles were discarded must also be undertaken to

remove any potential contamination as this area is

considered to be clean in accordance with GNR 704

of the National Water Act, 1998 (Act 36 of 1998)

(NWA) . Should Mooikraal wish to construct a new

designated waste storage area for additional waste

stored at Mooikraal Colliery, a review must be

undertaken to determine whether any listed activities

in terms of NEM:WA such as Category C are

triggered. Should no waste activities be triggered, a

31 amendment process must be undertaken and

appropriate mitigation measures implemented to

prevent further contamination.

A waste management procedure has been compiled to deal with the

handling and disposal of waste (Ref No. IMS(EM) 4.4.6 / SOP 001). The

procedures indicated that all waste must be recycled where possible and

the remaining waste must be disposed at permitted or licensed landfill

sites. During the site assessment it was observed that waste generated at

Mooikraal is stored in a designated waste storage area which is separated

into various waste streams namely wood waste, scrap metal and

hazardous waste. All waste is appropriately disposed off.

During the site visit, the waste material was being removed for disposal -

the oil drums to be specific.

C

2.11

In terms of sections 28 and 30 of NEMA, and

sections 19 and 20 of the National Water

Act, 1998 (Act 36 of 1998) as amended

(NWA), any costs incurred to remedy

environmental damage must be borne by the

person responsible for the damage. It is

therefore imperative that the holder reads

through and understand the legislative

requirements pertaining to mining. It is the

holder's responsibility to take reasonable

measures which include informing and

educating contractors and employees about

environmental risks of their work and training

them to operate in an environmentally

acceptable manner.


The mine aims to avoid impacts to the environment. Environmental

awareness is provided to all employees and contractors so as to avoid

potential environmental incidents. It is underst that should environmental

deterioration be identified it is the mines responsibility to rectify the impact.

The financial provision is for this purpose, the mine must ensure sufficient

funds are available for rehabilitation once LoM is reached (Jones and

Wagener (Ref No. JW047/15/E473 - Rev 4).

The lastest financial provisioning is March 2019.

C

2.12

Construction vehicle must be serviced and

maintained in the manner whereby no

excessive smokes are produced and noise

production is reduced to acceptable levels,

and to prevent oil leaks. Contaminated soil

must be remediated on site or removed to an

authorised landfill site.




condition is considered to be not applicable

NA

The mine aims to avoid impacts to the environment.

Environmental awareness is provided to all employees and

contractors so as to avoid potential environmental incidents. It is

understood however that should environmental deterioration be

identified it is the mines responsibility to rectify the impact.

Financial provision is updated on an annual basis and submitted

to the DMR to ensure sufficient funds are available for

rehabilitation once LoM is reached (Jones and Wagener (Ref

No. JW047/15/E473 - Rev 3).




Certain areas around the mine have been identified to be high

risk areas where soil contamination may have occurred during

the operational phase. These areas are specifically around the

STP, below the PCDs, around the ROM coal stockpile area and

the shafts. Soil samples taken by Digby Wels have been taken

and sent for analysis to determine the baseline soil condition

around Mooikraal and 3 Shaft. It is however noted unless

severe contamination is identified which will result in

contamination to the water courses, the soil will remain until the

mine has reached LoM where rehabilitation will occur and these

soils will be rehabilitated. To date no results from the soil survey

has been provided.

A waste management procedure has been compiled to deal with

the handling and disposal of waste (Ref No. IMS(EM) 4.4.6 /

SOP 001). The procedures indicated that all waste must be

recycled where possible and the remaining waste must be

disposed at permitted or licensed landfill sites. During the site

assessment it was observed that waste generated at Mooikraal

is stored in a designated waste storage area which is separated

into various waste streams namely wood waste, scrap metal and

hazardous waste. All waste is appropriately disposed off.

However, during the site assessment decommissioned

equipment which is no longer in use was observed to be

dumped within a designated clean water area located below the

silo and conveyer belt area. It was communicated that the

equipment had been drained of oil however the equipment is still

considered to be dirty and contained evidence of coal. Although

discussions regarding making this area the new waste

management area are being undertaken, decommissioned

equipment may not be permitted to be dumped in this area until

relevant mitigation measures have been implemented.

2.13

Residents (if any) on the property (ies) and

surrounding the mining areas must be

informed if any unusual noisy activities are

planned.


It was noted that the Mooikraal Colliery is not considered to be noisy as

only underground mining is being undertaken. Additionally the nearest

receptor is considered to be far away from the mining operation and would

not be considered to be impacted upon by noise.


required.

C

2.14

Dust suppression measures must be

implemented on all exposed surface to

minimize and control airborne dust.

NC

As the dust mitigation measures implemented at the

mine were found to be inadequate. An air quality

specialist study is currently being undertaken to

assess the impact of dust fall-out on the surrounding

community and to recommend measures to reduce

the impacts around 3 Shaft and the Mooikraal Colliery.

The mitigation measures proposed from this

specialist study must be implemented to ensure dust

levels are reduced and are brought in compliance with

air quality legislation.

Dust suppression measures have been put into place at Sigma Colliery: 3

Shaft in the form of fogger cannons. This was put in place to address dust

fall-out impacts to the surrounding community.

The dust monitoring report compiled by Godnwana Environmental

Solutions in October 2019 states that during the period of monitoring,

2019-09-30/2019-10-31 there were no exceedances for non-residential

standards.

The Mooikraal Opertaions are classified as non-residential. Therefore,

based on the lastes report provided to Digby Wells, this condition is met.

C

2.15

Should any heritage remains be exposed

during operation or any actions on the site,

these must immediately be reported to South

African Heritage Resources Agency

(SAHRA) and in accordance with the

applicable legislation. Heritage remains

uncovered or disturbed during earthworks

must not be further disturbed until the

necessary approval has been obtained from

SAHRA. This Department must also be

informed about such exposure in writing.


According to the EMPr approved by DMR on 12 April 2016, no

archaeological and/or cultural historical sites are found in the mining right

area. It is understood that should any additional activities be undertaken the

mine will notify the South African Heritage Resources Agency (SAHRA) in

terms of the National Heritage Resources Act, 1999 (No. 25 of 1999).

No archaeological and/or cultural historical sites have been found on site

and the sitautions remains unchanged since the previous audit.

C

2.16

Care must be taken to ensure that the

material and excavated soil required for

backfilling are free of contamination from

hydrocarbons.


Soil and overburden stockpiles are located at the Mooikraal Colliery and

will be utilised for rehabilitation once LoM is reached. The stockpiles were

located in designated clean areas and no contamination was observed. It

was observed that a berm has been constructed around the overburden

stockpile to prevent the loss of soil. Additionally the soil stockpile has been

vegetated and utilised as clean water berms.


required.

C

According to the EMPr approved by DMR on 12 April 2016, no

archaeological and/or cultural historical sites are found in the

mining right area. It is understood that should any additional

activities be undertaken the mine will notify the South African

Heritage Resources Agency (SAHRA) in terms of the National

Heritage Resources Act, 1999 (No. 25 of 1999). A heritage

study is currently being undertaken for the 31 amendment

process to ensure no heritage resources are impacted.

Soil and overburden stockpiles are located at the Mooikraal

Colliery and will be utilised for rehabilitation once LoM is

reached. The stockpiles were located in designated clean areas

and no contamination was observed. It was observed that a

berm has been constructed around the overburden stockpile to

prevent the loss of soil. Additionally the soil stockpile has been

vegetated and utilised as clean water berms. As the Mooikraal

Mine is an underground coal mine, limited rehabilitation is

undertaken on areas where mining or related activities have

been undertaken. It was reported that to date only minimal

rehabilitation activities had been undertaken. Once LoM is

reached, all infrastructure will be removed from site and

rehabilitation will commence in line with the rehabilitation

measures proposed in the approved EMPr, a rehabilitation

management plan will also be compiled at the time of closure.

Should rehabilitation be undertaken, the soil utilised to

rehabilitate the area will be free of contaminates from

hydrocarbons.

It was noted that the Mooikraal Colliery is not considered to be

noisy as only underground mining is being undertaken.

Additionally the nearest receptor is considered to be far away

from the mining operation and would not be considered to be

impacted upon by noise. Additionally although the ventilation

shaft is quiet noisy their are no close receptors to the ventilation

shaft. It is noted however that should a noisy activities be

planned to be undertaken at the mine, adjacent land owners will

be notified. No noise complaints for Mooikraal have been

received for 2017 and 2018 (Sasol Mining External Complaints

Register April 2018). It was however noted that issues regarding

noise generated by the crushing and screening plant has been

received. A noise specialist study is currently being undertaken

to address the issue of noise and implement measures to

reduce these impacts to the surrounding community

A dust monitoring programme has been implemented at

Mooikraal and 3 Shaft where dust buckets have been positioned

in all major and secondary wind directions. These dust buckets

are monitored on a monthly basis by Gondwana. Dust results

were provided for the months of August 2012 to May 2018. The

results indicated that the levels of dust did exceed the specified

limits associated with residential levels and in some month’s

industrial levels as per the National Dust Fallout Regulations.

Dust is considered to be an issue at 3 Shaft due to the handling

of coal. A number of complaints have also been raised

regarding the generation of dust around the conveyer belt and 3

Shaft (Refer to Complaints register, 2018).

2.17

Hydraulic fluid or chemicals required during

construction must be stored in a concrete

lined surface with bund walls and shall be

designed in such a manner that any spillage

can be contained and reclaimed without any

impact on the surrounding environment.

Should any spills occur it should be cleaned

immediately by removing spillage together

with the polluted solids and dispose it in the

authorised disposal site permitted of such

waste. The relevant regional office of the

Department of Water and Sanitation must be

notified within 24 hours of an incident that

may pollute surface and underground water

resources.




condition is considered to be not applicable. Therefore, no further action is

required.

NA

2.18

Chemical sanitation facilities or system such

as toilets that do not rely on the seepage of

liquids must be provided with a ratio of 1 for

every 15 workers. These must be placed

such that they prevent spills or leaks to the

environment and must be maintained

according to the operating instructions and

the content thereof must be disposed at an

authorised waste water treatment works.

NC

It is recommended that an investigation be

undertaken to determine the reason for the high

concentrations of NO3 and E Coli in the treated

effluent that is discharged from the STP. Measures

must be implemented to ensure that these non-

compliances are addressed and aim to comply with

the specified qualities of the IWUL.

The high concentrations of NO3 and E Coli found in the STP results in the

previous were investigated and addressed. C

Once the 7ML and 10ML pipeline is constructed water

will be transferred between Mooikraal PCDs to SO

PCDs which will prevent further discharge of dirty

water to the environment at Mooikraal. A Dam Safety

Inspection by a professional Registered Engineer on

the PCDs at Mooikraal must be undertaken to ensure

the PCDs are able to contain the required amount of

water without the potential of dam failure. Additionally

the incident is required to be reported to water affairs

if the reason for the overflow was due to the integrity

of the PCDs.

During the site assessment it was observed that the

PCD at 3 Shaft was at full capacity and above the 0.8

m recommended freeboard level. The water level

within the PCD at 3 Shaft must be reduced to be

within the recommended level.

■ The disposal of the effluent from the STP to the

Kromelmboogspruit triggers a Section 21 (f) water use:

Discharging waste or water containing waste into a water

resource,;

■ Disposal of water found underground to the North and the

South PCDs triggers a Section 21 (g) which is defined as the

disposing of waste in a manner which may detrimentally impact

on a water resource; and

■ Construction and operation of a pipeline over various water

courses (Section 21 c and i).




Toilets are located within office buildings as well as in the

change houses. A portable toilet is also located at the STP. It

was noted that the toilets are regularly cleaned and maintained.

Should an issue be detected such as a leak this will be reported

on and repaired. The sewage generated from the use of the

toilet is transported via pipeline to the STP. The STP is

authorized under the IWUL (Licence No

08/C22K/CIGJFAE/6981) approved on 16 January 2018. The

sewage is treated to an acceptable standard in accordance with

the IWUL and discharged to the Kromelmboogspruit. The water

qualities reported on from the STP are however not complying

with the water quality standards in the IWUL. High levels of

Nitrates and E-coli were detected in the monitoring data (STP

Water Quality, 2018). It was however observed during the site

assessment that maintenance of the STP was being undertaken

in an attempt to clean out the system and ensure the STP

operates efficiently.

2.19

The holder must ensure that any water uses

listed in terms of section 21 of NWA must

get authorization from Department of Water

and Sanitation prior to the commencement of

such activity (ies).

NC

Mooikraal has an approved WUL (Licence No

08/C22K/CIGJFAE/6981) which permits the following water

uses:

■ Abstraction of water from underground triggers a Section 21

(a) water use which is the taking of water from a water resource;

■ The removal of water found underground for the safe

continuation of mining triggers a Section 21 (j) water use.Pipelines transferring water from Mooikraal to other Sasol Operations are

installed, functional and operational.

All water uses are accounted for in the WUL.

C

2.2

This approval letter does not purport to

absolve the holder from its common law

obligations towards the owner of the surface

of land affected.


Mooikraal understands its responsibility to landowners. An external

complaints register is maintained which documents all complaints raised

by I&APs, landowners as well as adjacent landowners. On the day of the

audit, the Environmental Manager was dealing with an I&AP compliant

about a borehole on his land.

Mooikraal still has a working compliants register and issues are still logged

to be addressed.

C

2.21

The holder must ensure that rehabilitation of

the disturbed areas caused by mining and

mining related activities at all times comply

with the approved EMPr.


As the Mooikraal Mine is an underground coal mine, limited rehabilitation is

undertaken on areas where mining or related activities have been

undertaken. It was reported that to date only minimal rehabilitation activities

had been undertaken. Once LoM is reached, all infrastructure will be

removed from site and rehabilitation will commence in line with the

rehabilitation measures proposed in the approved EMPr, a rehabilitation


This remains the way the mine will undertake rehabilitation, thus nothing

has changed since the previous audit.

C

2.22

This approval letter may be amended or

withdrawn at any stage for non compliance

and provides no relief from the provisions of

any other relevant statutory or contractual

obligations.


Mooikraal acknowledges the importance of ensuring all conditions of this

authorisation and EMPR are adhered to. Should a non-compliance be

identified an action plan is compiled to provide measures to address the

non-compliance.

The non-compliances identified during this audit are dependent on the

approval of the Regulation 31 Amendment application that is still to be

approved by the DMR.

C

2.23

The holder must note that residue deposit

and residue deposit must be deposited and

managed in a prescribed manner on any site

demarcated for that purpose in the EMPr. No

person may temporary or permanently

deposits residue stockpile or residue deposit

on any area or site other than on site

indicated on the EMPr.


A number of soil and overburden stockpiles are located onsite. The

stockpiles are located at the Adit, PCD and silo and conveyer belt area.

The soil stockpiles are utilised for clean stormwater management. These

stockpiles will be utilised for rehabilitation once LoM is reached.


required.

C

Once the 7ML and 10ML pipeline is constructed water

will be transferred between Mooikraal PCDs to SO

PCDs which will prevent further discharge of dirty

water to the environment at Mooikraal. A Dam Safety

Inspection by a professional Registered Engineer on

the PCDs at Mooikraal must be undertaken to ensure

the PCDs are able to contain the required amount of

water without the potential of dam failure. Additionally

the incident is required to be reported to water affairs

if the reason for the overflow was due to the integrity

of the PCDs.


PCD at 3 Shaft was at full capacity and above the 0.8

m recommended freeboard level. The water level

within the PCD at 3 Shaft must be reduced to be

within the recommended level.

Mooikraal understands its responsibility to landowners. An

external complaints register is maintained which documents all

complaints raised by I&APs, landowners as well as adjacent

landowners. These complaints are reposted to the Sasol Mineral

Rights Departments. All issues raised are investigated and

specific actions are implemented to ensure the issue is

resolved (Mooikraal Complaints Register April 2018).

As the Mooikraal Mine is an underground coal mine, limited

rehabilitation is undertaken on areas where mining or related

activities have been undertaken. It was reported that to date only

minimal rehabilitation activities had been undertaken. Once LoM

is reached, all infrastructure will be removed from site and









draining, has ponding was observed and alien invasive species

are controlled. Consideration should be taken to rehabilitate

these borrow pits during the operational life of the mine.

Mooikraal acknowledges the importance of ensuring all

conditions of this authorisation and EMPR are adhered to.

Should a non-compliance be identified an action plan is

compiled to provide measures to address the non-compliance.

Additionally Mooikraal ensures both internal and external audits

are undertaken to ensure its compliance to the various

authorisation and EMPr conditions.

During the site assessment it was observed that a number of

soil and overburden stockpiles are located onsite. The

stockpiles are located at the Adit, PCD and silo and conveyer

belt area. The soil stockpiles are utilised for clean stormwater

management. These stockpiles will be utilised for rehabilitation

once LoM is reached.

During the site assessment it was observed that water was

overflowing uncontrolled from the PCD into the

Kromelmboogspruit. It was observed that the water was

overflowing beneath the spill way which may indicate issues

relating to structural integrity of the dam wall of the PCD. The

overflow of water from the PCDs to the environment is not

authorised in terms of the NWA and under the IWUL. Measures

have been put in place to manage the excess water. This

includes the construction of a 7 ML and 10 ML pipeline which will

direct the water from the PCDs to the Sasolburg Operations and

prevent the unauthorised discharge. The construction of the

pipeline received environmental authorisation in 2015 with the

IWUL being authorised in January 2018. The pipeline has been

constructed except in the areas where the pipeline will cross

watercourses. It is proposed that the pipeline will be fully

constructed by the end of 2018. It was observed that the PCD at

3 Shaft was also quiet full and above the 0.8 m recommended

level.

2.19

The holder must ensure that any water uses

listed in terms of section 21 of NWA must

get authorization from Department of Water

and Sanitation prior to the commencement of

such activity (ies).

NC

Pipelines transferring water from Mooikraal to other Sasol Operations are

installed, functional and operational.

All water uses are accounted for in the WUL.

C

2.24

The holder must note that no person may

commence, undertake or conduct a waste

management activity, except in accordance,

with the requirements of norms and

standards determined for that activity or a

waste management licence is issued in

respect of that activity if licence is required.

NC

It is recommended that the vehicles stored in the

designated clean water area below the silo and

conveyer belt at Mooikraal Colliery should be

removed from site or stored within a designated dirty

water area. Rehabilitation of the area where the

vehicles were discarded must also be undertaken to

remove any potential contamination as this area is

considered to be clean in accordance with GNR 704

of the National Water Act, 1998 (Act 36 of 1998)

(NWA) . Should Mooikraal wish to construct a new

designated waste storage area for additional waste

stored at Mooikraal Colliery, a review must be

undertaken to determine whether any listed activities

in terms of NEM:WA such as Category C are

triggered. Should no waste activities be triggered, a

31 amendment process must be undertaken and

appropriate mitigation measures implemented to

prevent further contamination.










authorised.

NC

2.25

The Department reserves the right to audit

and/or inspect the activity (ies) without prior

notification at any reasonable time and at

such frequency as may be determined by the

Regional Manager.


The mine permits any authority who wishes to conduct the audit provided

that previous arrangements have been made with the mine to ensure

appropriate health and safety procedures are followed.

No changes since the previous audit.

C

2.26

The waste storage site must have a firm,

impermeable, chemical resistant floors and a

roof to prevent direct sunlight and rain water

from getting in contact with the waste.

NC

As per the condition of the authorisation, it is a

requirement to ensure that the hazardous waste

storage area has a roof in order to prevent direct

sunlight and rainwater having direct contact with the

waste. It was communicated that it would be

impractical to construct a roof over the waste storage

area as it would create difficulties when contractors

come to remove the waste as the roof will hinder the

waste vehicles from accessing the skip. It is therefore

recommended that an application for an amendment

of the condition be included in the Regulation 31

amendment process.










authorised.

NC

2.27

The storage of hydrocarbons must have

bund walls with adequate capacity to contain

the maximum volume that is stored in the

area. Uncontaminated storm water must be

prevented from coming into contact with the

waste and must be diverted away from the

storage site.

C

Further maintenance and good housekeeping

practices must be implemented at the sump located

at the fuel and hydraulic oil storage area to ensure the

sump operates at optimal capacity.

Maintenance and good housekeeping practices have been implemented at

the fuel and hydraulic oil storage area. The hydraulic oil and diesel storage

area have bunded areas that can carry capacity of potential spills. C

2.28

Should there be any conflicting conditions

between this approval letter and other

approval granted by other authorities, it is

upon the holder to bring it to the attention of

this Department for resolution.


Mooikraal has confirmed that no conditions within this authorisation

contradict the conditions in the EMPr and any other authorisation Mooikraal

currently has been granted.


required.

C

Fuel and Hydraulic Oil is stored onsite at the Mooikraal operation

in bulk storage tanks. These tanks are stored within a bunded

area and on a concreted standing. It was noted that the bunded

area would be able to contain 1.5 times the amount of fuel

stored within these areas. The bunded areas have been

designed as per the South African National Standards (SANS)

10089 (for oils and transportation fuel) and SANS 310 (for

hazardous chemicals). The fuel storage area is located within a

dirty water area and therefore all water contained in this area is

diverted to the sump and discharged to the South PCD. It must

be noted that a new sump has being constructed and is

operational. It was however noted that an oil separator has not

yet been installed and water is being manually pumped out of

the sump. Ponding of water was observed around the sump

area and further maintenance and good housekeeping practices

is still required to ensure the sump operates at optimal capacity.

Mooikraal has confirmed that no conditions within this

authorisation contradict the conditions in the EMPr and any other

authorisation Mooikraal currently has been granted.

Mooikraal has one waste storage area. It was confirmed that this

waste area does not exceed 100 m3

for general waste and 80

m3

for hazardous waste. Therefore no listed activities in

accordance with the NEM:WA are triggered and no waste

licence is required. However, as best practice the NEM:WA

Norms and standards for the Storage of Waste, 2013 are

utilised as a guideline to ensure the storage area is

management in accordance with applicable legislation. It is

noted that no waste activity may commence without a waste

management licence should it trigger the listed activities in

accordance with Government Notice 921 in Government

Gazette 37083 dated 29 November 2013 of NEM:WA.

However, during the site assessment decommissioned

equipment which is no longer in use was observed to be

dumped within a designated clean water area located below the

silo and conveyer belt area. It was communicated that the

equipment had been drained of oil however the equipment is still

considered to be dirty and contained evidence of coal. Although

discussions regarding making this area the new waste

management area are being undertaken, decommissioned

equipment may not be permitted to be dumped in this area until

relevant mitigation measures have been implemented. It should

be noted that although the area was not measured it may

exceed 80 m3 which may result in the triggering of listed

activities in terms of the NEM:WA.

It was communicated during the site assessment that the DMR

makes regular visits to the mine to ensure it is compliant with its

various licences. The mine permits any authority who wishes to

conduct the audit provided that previous arrangements have

been made with the mine to ensure appropriate health and

safety procedures are followed.

During the site assessment it was observed that the waste

storage area is positioned on a concrete surface to prevent

potential contamination. Additionally the waste is placed within

skips to ensure all waste contained within the skips is treated as

contaminated and disposed at an appropriate licensed landfill

site. However it was observed that no roof is located over the

area where the waste is stored to prevent direct sunlight and rain

water from entering the waste container.

3.1

A copy of this approval letter and EMPR

must be kept at the property or on site office

where the mining activities will be

undertaken/are being conducted. This

approval letter and EMPr must be produced

to any authorised officials of the Department

who request to see it and must be made

available for inspection by any employee or

agent of the holder who works or undertakes

work at the mining area.


A copy of the authorisation as well as the EMPr is retained at the mine with

the appointed environmental offices Lisa Grobler. Additionally the

documents are saved on Sasol’s internal server. Should authorities or

employees wish to access the information Sasol will ensure the

documents are provided.


required.

C

3.2

The content of the EMPr and its objectives

must be made known to all contractors,

subcontractors, agent and any other people

working on the site, and any updates or

amendments to the EMPr must be submitted

to the Department for approval.


During the induction undertaken at Mooikraal contractors, subcontractors

and employees of the mine are educated on the requirements and

objectives of the EMPr and EA and environmental management measures

to be implemented. Contractors are required to abide by Sasol’s internal

policy on environmental management.


required.

C

3.3

Regular monitoring and maintenance of

storm water drainage facilities must be

conducted at all times, if damaged as

directed by the Department or any other

relevant authority.

NC

Effective stormwater management measures needs

to be implemented at both Mooikraal (soil / conveyer

belt area) as well as at 3 Shaft. Dirty water generated

from the mine should not be permitted to be

discharged as it can result in contamination. It is

however noted that stormwater management

measures are proposed to be implemented at 3 Shaft

as part of the 31 Amendment process.










authorised.

NC

3.4

A buffer zone of 100 metres between the

activity (ies) and the residential areas,

cemeteries or burial grounds, Eskom power

lines and the fuel pipe line must be clearly

demarcated and maintained.


No residential areas and archaeological and/or cultural historical sites are

located within 100 meters of the operational structures of the mine. A

statutory plan is updated on an annual basis which demonstrates this buffer

zone.


required.

C

3.5

The holder must prevent nuisance conditions

or health hazards, or the potential creation of

nuisance conditions or health hazards.

NC

Mooikraal is in the process applying for environmental

authorization for the upgrade of the stormwater

management measures at 3 Shaft. The proposed

upgrade involves the construction of silt traps and the

re-use of water back into its primary processing plant

as dust suppression. Should authorisation be

received, rehabilitation specifically where the coal has

built up beneath the culvert at 3 shaft should be

desilted to allow continuous flow of water.










authorised.

NC

5) MANAGEMENT OF MINING ACTIVITIES

Clean water is diverted around the mine and permitted to be

discharged directly to the environment. Berms are created

around the mining areas so as to assist with the diversion of

clean water away from the dirty water areas and the containment

of dirty water to prevent accidental discharge to the environment.

It was noted that the clean water berms are well maintained.

Maintenance activities are undertaken regularly and inspections

are undertaken before and after many major storms. However a

lack of effective storm water management to prevent dirty water

being discharged to the environment was observed at both

Mooikraal (soil / conveyer belt area) as well as at 3 Shaft. It was

observed that at both these locations dirty water was being

discharged to the environment.

No residential areas and archaeological and/or cultural historical

sites are located within 100 meters of the operational structures

of the mine. A statutory plan is updated on an annual basis which

demonstrates this buffer zone. This plan is submitted to the

DMR every September on an annual basis.

Mooikraal aims to ensure that its operation is well managed and

abides by the conditions in the authorisation and EMPr.

Additional best practice procedures are also considered to

prevent the possibility of a nuisance or health hazard occurring.

Continuous monitoring is being undertaken to ensure the mine is

not resulting in contamination of the environment. When

elevated levels of contaminates are identified, mitigation

measures are implemented to rectify the issue. Additionally a

complaints register is maintained to ensure that all issue raised

by I&APs are recorded and an investigation is undertaken to

address the issue prior to it becoming a potential nuisance

conditions or health hazards. However, it was observed that dirty

water generated at 3 Shaft from the coal stockpile area is being

discharged directly into the Leeuspruit. The results indicate that

over the past year and a half increased levels of sulphate are

noted which has resulted in pH values exceeding 8 which can

result in health hazards. It is however noted that the deteriorating

water quality is not only from 3 Shaft and has other contributing

factors. At a regional scale, the Vaal River, which the Leeuspruit

joins, is considered to be heavily contaminated as a result of

accidental discharges from the municipal STP which has

resulted in the significant losses of aquatic life. Although the

STP has a more significant impact on the environment and the

people utilising the river, additional contamination to the river

generated from 3 Shaft should be avoided.

A copy of the authorisation as well as the EMPr is retained at the

mine with the appointed environmental offices Lisa Grobler.

Additionally the documents are saved on Sasol’s internal server.

Should authorities or employees wish to access the information

Sasol will ensure the documents are provided.

During the induction undertaken at Mooikraal contractors,

subcontractors and employees of the mine are educated on the

requirements and objectives of the EMPr and EA and

environmental management measures to be implemented.

Contractors are required to abide by Sasol’s internal policy on

environmental management. During the site assessment sub-

contractors where located onsite which were in the process of

constructing new office buildings.

3.6

Mining activities must be managed and

operated in accordance with the

Environmental Management Systems (EMS)

that inter alia identifies and minimises risks of

pollution, including those arising from

operations, maintenance, accidents,

incidents and non-conformances and those

drawn to the attention of the holder as a

result of complaints.


Mooikraal Mine is ISO 14001 certified. The latest ISO 14001 audit was

undertaken in May 2018 by DQS . An EMS system has been set up to

ensure compliance with the ISO 14001:2015 system to ensure that all

monitoring is recorded as well as incidents are reported on.


required.

C

3.7

The holder must ensure that all non-

recyclable waste are disposed at waste

management facilities licenced to handle

such wastes and all recyclable waste are

collected by licenced waste management

facilities for recycling, reuse or treatment.

NC

Waste should not be permitted to be dump in any

other place besides the waste storage facilities. The

area where the coal waste was dumped at Sigma

Defunct Colliery should be cleaned up as the land had

been recently rehabilitated as part of the closure

process for the Sigma Defunct Colliery.

It is noted that waste generated at Mooikraal and 3 Shaft is stored in

designated waste storage areas, one at Mooikraal and one at 3 Shaft,

which is separated into various waste streams. Waste contractors have

been appointed to remove the waste and dispose of it at a licence waste

facility.

However, it was observed at the laydown area that there were redundant

cars and used tyres. Redundant cars become classfied as waste and

should be removed from site accordingly as either scrap metal or another

type of waste. The used tyres need to be handled in accordance with the

Waste Tyres Regulations under the National Environmental Management:

Waste Act No. 59 of 2008.

NC

3.8

The holder must ensure that all liquid wastes,

whose emissions to water or land could

cause pollution are diverted to sewer, after

testing water quality and receiving written

approval from the relevant local authority.

NC








The Mooikraal STP must be registered with the DWS

and have a registration certificate displayed on site

which includes the classification of the STP. In

addition, the Process Controller (PC) must be

registered and have the relevant qualifications and

training to operate the specified class of STP. This is

contained in Regulation 2834 of WA (1956) and Draft

Regulation 813 of the Water Services Act, 1997 (Act

108 of 1997).

An investigation was conducted as per the 2018 recommendation and the

Nitrate and E.coli was treated by adding fresh innoculent into the STP.

A registration of the "Mooikraal Wastewater Works" under section 26 of

the National Water Acr with the Department of Water Affairs was avaliable

and issued 13 December 2012.

The operators are approporiately qualified to operate the STP.

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3.9

Non-compliance with any condition of this

approval letter or EMPr may result in the

issuing of statutory orders or instruction as

per section 93 and 47 of the MPRDA.


External audits are undertaken to determine the level of compliance the

mine has towards its authorisation and EMPR. The audit reports aim to

document the non-conformities and propose mitigation measures to

address the issues that were identified. These reports are submitted to the

DMR by Sasol on an annual basis to notify them of the non-conformities

that may have been identified.

This audit serves as the external audit to check compliance status. Non-

compliances idnetified during thia audit will be addressed accordingly

through an action plan.

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External audits are undertaken to determine the level of

compliance the mine has towards its authorisation and EMPR.

The audit reports aim to document the non-conformities and

propose mitigation measures to address the issues that were

identified. These reports are submitted to the DMR by Sasol on

an annual basis to notify them of the non-conformities that may

have been identified. The lasted audit report was submitted in 8

December 2017. Once a non-compliance is noted Sasol

compile action lists of how to address the non-compliance and

specify a deadline to implement the measures.

In accordance with Mooikraal IWUL (Licence No.

08/C22K/CIGJFAE/6981), the STP is authorised to discharge

treated effluent to the environment. The STPs are operated in

accordance with the Site Specific Standard Operating

Procedure (SOP): The handling of sewage at Mooikraal (Ref No.

SOP 4.4.6/07). The STP treats the sewage originating from the

office blocks and change houses using a package plant

consisting of an aeration reactor and chorine tank. Chlorine is

added to the final treated effluent to ensure the quality of water

is suitable for discharge to the catchment. Monthly samples are

taken and submitted to a SANNAS accredited laboratory. The

final treated effluent from the STP at Mooikraal is discharged to

an open channel which is then released into the

Kromelmboogspruit. The results for the water that is being

discharged from the STP indicated that the volume and quality

of treated effluent exceeds the authorised volume and qualities

specified in the IWUL specifically for nitrate and E.coli.

Mooikraal Mine is ISO 14001 certified. The latest ISO 14001

audit was undertaken in May 2018 by DQS . An EMS system

has been set up to ensure compliance with the ISO 14001:2015

system to ensure that all monitoring is recorded as well as

incidents are reported on. Additionally operational procedures

have also been compiled which deal with specific actions to be

undertaken at the mine as well as procedures to address an

emergency situation such as the Emergency Preparedness and

Response Procedure (Ref No. SIG IMS 447000) and

Procedure for the Handling of Oil Spills and Oil Recycling (Ref

No. SIG (EM) IMS SOP/ 008). Additionally complaints are

recorded on an external complaints register which is managed

by Sasol Mining Rights and Properties Department. All issues

are investigated and resolved (Mooikraal Complaints Register

April 2018).

It is noted that waste generated at Mooikraal and 3 Shaft is

stored in designated waste storage areas, one at Mooikraal and

one at 3 Shaft, which is separated into various waste streams.

Waste contractors have been appointed to remove the waste

and dispose of it at a licence waste facility. However, during the

site assessment it was observed that the clean-up crew, which

cleans up coal along the conveyer belt was collecting all the coal

and dumping it on previously rehabilitated land for the local

people in the surrounding communicates to use. The area where

the coal is being dumped is not considered to be a dirty water

area as it has recently been rehabilitated and coal dumped in the

area should not be permitted. It is however noted that when the

EAP became aware of the issue immediate measure where

undertaken to stop the coal being dumped.

3.10

Only mining activities that are expressly

specified in the EMPr that forms part of this

approval letter may be conducted, and

additional or new activities not specified

herein must be applied for by the holder and

authorised in the form of an amendment to

the aforesaid EMPr before such activities

may be commenced with. This condition is

also applicable in the case of the

amendment, addition, substitution,

correction, and removal or updating of any

detail in the aforesaid EMPr.

NC

Based on the review of the EMP and correlated with

the legislative requirements of the EIA Regulations,

2014 (as amended) it is concluded that 3 Shaft which

includes the operation of the primary processing plant

is not sufficiently described, the impacts assessed

and mitigation measures provided in the EMPr to

confirm an environmental authorisation for the

activities or the area on which the activities are taking

place. The lack of detail in the EMPr with regard to 3

Shaft can be rectified by means of a Regulation 31

amendment application process. Mooikraal have

appointed Digby Wells to undertake the required

Regulation 31 amendment process to rectify the

issues identified by this audit report. This process has

however not commenced yet.










authorised.

NC

3.11

Rehabilitation of the disturbed surface

caused by mining operation at all times must

comply with the approved EMPr


As the Mooikraal Mine is an underground coal mine, limited rehabilitation is

undertaken on areas where mining or related activities have been

undertaken. It was reported that to date only minimal rehabilitation activities

had been undertaken. Once LoM is reached, all infrastructure will be

removed from site and rehabilitation will commence in line with the

rehabilitation measures proposed in the approved EMPR.

This is still the way the mine will operate. No changes to the

implementation of rehabilitation measures isnce the previous audit.

Therefore, continual management of areas should take place, however, no

immediate action is required.

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3.12

The holder must ensure that the name and

contact details of the person responsible for

environmental management is made

available to the Regional Manager within 30

days from the date of this approval

(consolidation of mining rights and approved

EMPrs).The holder must also ensure that a

person responsible for environmental

management is always available on site to

ensure that mining activities at all times

comply with the conditions of approval letter

and approved EMPr (consolidated).


Since the mine began operating in 2005, no changes to the contact details

of the holder of the authorisation have occurred therefore no notification of

the regional manager is required.

Lisa Grobler has been appointed by Sasol to ensure that all conditions are

adhered to on the mine and ensure mining activities are undertaken in

accordance with relevant legislation.

No changes since the previous audit, therefore no further action is

required.

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3.13

3.13 a

Keep and maintain a detailed incidents

register (including any spillages of fuels,

chemicals or any other material


An incident register is retained onsite and maintained by the Environmental

Practitioner at the mine. Any incidences or non-conformities that occur are

reported on and an investigation is undertaken to resolve the issue.

The . SIG IMS 10.2 Incident Register is still operational and the only

actions required are the mitigation measures for each incident logged.

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The Mooikraal operation aims to ensure that Chapter 5 of NEMA

is complied with to ensure all environmental management is

undertaken correctly and all impacts that the mine may have on

the environment is assessed and mitigated. It is however note

that the Mooikraal EMPr has failed to assess and provide

mitigation measures for all aspect specific to 3 Shaft. A non-

compliance as been identified against Section 24N with regards

to the effectiveness of the EMPr. Please refer to Section 8 of

the audit report for further details regarding the non-compliance.

It can be concluded however that in accordance with the NEMA

and EIA Regulations 2014 (as amended), the Mooikraal EMPr is

substantively lacking with regard to 3 Shaft in the following

respects:

■ 3 Shaft and its associated activities are not included in Section

1.1 or 1.2 of the EMPr, the sections which give the project

background and description respectively;

■ The Mooikraal EMPr does not adequately incorporate the

activities, aspects, impacts and associated mitigation steps at 3

Shaft into Section 4 – Environmental Impact Assessment,

Section 5.3 Environmental Management Programme, or Section

7 Environmental Monitoring.

■ Infrastructure (figure 2) and locality plans (figure 1) do not

indicate the infrastructure at 3 Shaft, nor the physical location of

3 Shaft, the mining right boundary does not correlate with the

Plan of Land Amendment of a Mining Right (dated 05/02/2016).

As the Mooikraal Mine is an underground coal mine, limited

rehabilitation is undertaken on areas where mining or related

activities have been undertaken. It was reported that to date only

minimal rehabilitation activities had been undertaken. Once LoM

is reached, all infrastructure will be removed from site and



management plan will be compiled once closure is reached

which will include all mitigation measures to prevent

unnecessary environmental impact. It was observed that all soil

stockpiles as well as the areas around the mine was vegetated

Since the mine began operating in 2005, no changes to the

contact details of the holder of the authorisation have occurred

therefore no notification of the regional manager is required. An

Environmental Practitioner, Lisa Grobler has been appointed by

Sasol to ensure that all conditions are adhered to on the mine

and ensure mining activities are undertaken in accordance with

relevant legislation.

The person responsible for environmental management must:

An incident register is retained onsite and maintained by the

Environmental Practitioner at the mine. Any incidences or non-

conformities that occur are reported on and an investigation is

undertaken to resolve the issue. Additionally internal weekly

audits are undertaken by the Environmental Practitioner to

ensure that any incidents are recorded and reported on. The

most recent incident that was reported occurred in July 2018

due to a contractor damaging a water line (Ref No. SIG IMS

10.2 Incident Register 2018). The incident was reported to be

investigated and resolved. Additionally Mooikraal is an ISO

14001 certified mine and as per part 4.5.3 an incident register is

required.

3.13 b

Keep a complaint register on site indicating

the complaint and how the issues were

addressed, what measures were taken and

what the preventative measures were

implemented to avoid re-occurrence of

complaints


A complaints register is maintained which documents all complaints raised

by I&APs, landowners as well as adjacent landowners.

It is recommended that the complaints be addressed expediantly.

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3.13 c

Keep records relating to monitoring and

auditing on site and avail them for inspection

to any relevant authorised officials.

3.13 dKeep copies of all environmental reports

submitted to the Department.

3.13 eKeep the records of all permits, licences and

authorisations required by the operation.

3.13 f

Compile a monthly monitoring report and

make it available to the Department if

requested.


Monitoring is undertaken to monitor groundwater, surface water, air quality

and aquatics / wetlands. Additionally regular reports are compiled which

consolidate these results and indicate its compliance to various

authorisations obtained by the mine. Should the DMR wish a monthly

monitoring report to be submitted this will be undertaken by the mine.

If the DMR requests monthly reports from Mooikraal, reports will be

furnished. For now, no further action is required outside the periodic

monitoring already taking place.

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3.14

The duties and responsibility of the person

responsible of environmental management

should not be seen as exempting the holder

from the legal obligations in terms of the

MPRDA and it subordinate Regulations.

C No further action requiredLisa Grobler aims to ensure the mine is compliant with is authorisations

and does not contribute to increasing environmental pollution. C

3.15

The footprint of the mining activities must be

limited on the areas authorised for the actual

construction works and operational

activities and all areas outside of the

footprint must be regarded as a "no go"

areas.


Surface activities is located within the shaft area and the underground

mining activities are being undertaken within the mining right area. No

mining activities are being undertaken outside of the authorised areas.

There are no changes to this since the previous audit.

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3.16

Erosion and soil loss must be prevented by

minimizing the construction site exposed to

surface water run-off. Where necessary

erosion stabilizing action such as gabions or

re-vegetation must be implemented to

prevent further habitat deterioration.




condition is considered to be not applicable. Therefore, no further action is

required.

NA

3.17

The holder must ensure that all personnel

who work with hazardous waste are trained to

deal with these potential hazardous situations

so as to minimise the risk involved. Records

of training and verification of competence

must be kept by the holder.


Waste is managed in accordance with the waste management procedure

for Mooikraal Colliery (Ref No. IMS(EM) 4.4.6 / SOP 001). This procedure

stipulated the appropriate measures which must be undertaken to ensure

waste is handled correctly. These procedures are then communicated to

all employees and internal training is undertaken.

External training is still not undertaken as EnviroServ has been contracted

to remove and deal with hazardous waste. It was noted that EnviroServ has

the relevant licences and training certificates for the handling of hazardous

waste.

Therefore, no further action is required.

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3.18

In order to prevent nuisance conditions, the

holder must ensure that all storage skips and

bins are not overfilled


Waste skips are emptied by EnviroServ on a weekly basis. All waste is

handled in accordance with the waste management procedure for

Mooikraal Colliery (Ref No. IMS(EM) 4.4.6 / SOP 001). During the site visit,

the oil drums were being collected and the skips not overflowing.

C

The Environmental Practitioner aims to ensure the mine is

compliant with is authorisations and does not contribute to

increasing environmental pollution.

During the site assessment and based on the maps provided it

can be confirmed that the surface activities is located within the

shaft area and the underground mining activities are being

undertaken within the mining right area. No mining activities are

being undertaken outside of the authorised areas.




Waste is managed in accordance with the waste management

procedure for Mooikraal Colliery (Ref No. IMS(EM) 4.4.6 / SOP

001). This procedure stipulated the appropriate measures which

must be undertaken to ensure waste is handled correctly. These

procedures are then communicated to all employees and

internal training is undertaken. External training is not undertaken

as EnviroServ has been contracted to remove and deal with

hazardous waste. It was noted that EnviroServ has the relevant

licences and training certificates for the handling of hazardous

waste.

It was communicated that waste skips are emptied by

EnviroServ on a weekly basis. All waste is handled in

accordance with the waste management procedure for

Mooikraal Colliery (Ref No. IMS(EM) 4.4.6 / SOP 001). During

the site assessment it was observed that none of the waste

skips were overfilled.

7) REPORTING TO THE DEPARTMENT

Monitoring is undertaken to monitor groundwater, surface water,

air quality and aquatics / wetlands. Additionally regular reports

are compiled which consolidate these results and indicate its

compliance to various authorisations obtained by the mine.

Should the DMR wish a monthly monitoring report to be

submitted this will be undertaken by the mine.

All documents regarding monitoring and auditioning is kept at

the Mooikraal Mine with the Environmental Practitioner as well as

saved on the Sasol internal server. All monitoring and auditing

reports were made available to the auditors during the site

assessment and compilation of this audit report for 2018. A list

of documents that were reviewed during this audit has been

listed in Section 2.1 of the audit report.


An external complaints register (Mooikraal Complaints Register

April 2018) is maintained which documents all complaints raised

by I&APs, landowners as well as adjacent landowners. These

complaints are directed to the Sasol Mineral Rights

Departments. All issues raised are investigated and specific

actions are implemented to ensure the issue is resolved. The

complaints register provided has captured complaints raised

between 2016 and 2018.

All documents regarding monitoring and auditioning is kept at the Mooikraal

Mine with the Environmental Practitioner as well as saved on the Sasol

internal server. All monitoring and auditing reports were made available to

the auditors during the site assessment.


required.

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4.1

The holder must submit an Environmental

Performance Assessment Report to this

Department annually as per regulation 55 of

the MPRDA Regulations. The report should

be submitted manually in a form of two (2)

copies which specify whether the conditions

of this approval letter and an approved EMPr

are adhered to. This Environmental

Performance Assessment Report must

include the information referred to in

condition 4.2 below.


This audit is in line with Regulation 55 of the Mineral and Petroleum

Resources Development Act, 2002 (Act No. 28 of 2002) (MRPDA) and

associated MPRDA Regulations (GN R527 of 23 April 2004); and

Regulation 34 of the Environmental Impact Assessment (EIA)

Regulations, 2014 (GN R326 of 7 April 2017), as amended (EIA

Regulations, 2014) promulgated under the National Environmental

Management Act, 1998 (Act No. 107 of 1998) (NEMA), respectively.

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4.2

The holder must annually assess the

environmental liabilities of the operation as

contemplated in the Financial Provisioning

Regulations, 2015 and address the shortfall

on the financial provision submitted in terms

of section 24P of NEMA.


Jones and Wagener (Ref No. JW047/15/E473 - Rev 4) updated the

calculation of the financial provision for the various Sasol operational areas

in March 2019 and this included the Mooikraal Operations and the MKR1 -

Sigma No 3 Shaft at R 11 016 424.36; MKR2 - Mooikraal at R 74 063

714.64 and MKR3 - Old Sigma coal handling at R 35 213 788.19 and all

amounting to a total of R 120 293 927.19.

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4.3

The holder must, within 24 hours of incidents

occurring, notify this department any other

relevant department of the occurrence or

detection of any incident on the site, or

incidental to the operation of the site, which

has the potential to cause, or has caused

pollution of the environment, health risks,

nuisance conditions or water pollution.


In 2013 it was, determined that the both the South and North PCDs, which

are clay lined, were unable to contain the amount of water being pumped

from the underground workings to the dams which resulted in multiple

overflows over the past few years.

These incidents were reported to the DMR and DWS. No incidents have

happened since then.

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5.1

The holder must ensure effective access

control on the site to reasonably prevent

unauthorised entry. Signs indicating the risks

involved in unauthorised entry must be

displayed at each entrance.


The mine is access controlled to ensure no unauthorised personnel are

permitted into the mine. During the site visit he auditors were required to

provide identification documentation as well as permission from the

Environmental Practitioner was required to gain access to the mine. C

5.2

Weather proof, durable and legible notices in

at least three official languages applicable in

the area must be displayed at each entrance

to the Site. These notices must prohibit

unauthorised entry and state the hours of

operation, the name, address and telephone

number of the holder and the person

responsible for the operation of the site.


Appropriate signage is placed at the entrance to Mooikraal and 3 Shaft

which is weather proof and provides the correct information regarding the

operation and the holder of the authorisation. The necessary signage were

also provided at the entrance to the STP and the PCDs.

C

The holder must maintain and implement an

emergency preparedness plan and review it

biennially when conducting environmental

monitoring and assessment or audit and after

each emergency and or major accident. The

plan must, amongst others, include:

o Site fire

o Spillage

It is recommended that the Emergency Preparedness

and Response Procedure must be updated / revised

in 2018 and continue to be updated every two years

going forward and after any emergency incident that

would have a significant impact on the receiving

environment.

Appropriate signage is placed at the entrance to Mooikraal and 3

Shaft which is weather proof and provides the correct

information regarding the operation and the holder of the

authorisation. The necessary signage were also provided at the

entrance to the STP and the PCDs

11) EMERGENCY PREPAREDNESS PLAN

6.1 C

An Emergency Preparedness and Response Procedure has

been compiled for the Mooikraal Colliery (Ref No. SIG IMS

447000). The procedure deals with various environmental

emergencies which include:

■ Fire outbreak / surface or veld fires

■ Flooding (underground)

The first overflow of the PCD was reported through formal

communication however since then continuous email

communication between the mine and the DWS is undertaken

which aims to communicate when the PCD overflows.

The overflow of the PCDs is reported to DWS on a regular

basis. It is noted that when the PCDs overflows, weekly

monitoring is undertaken at the Kromelmboogspruit to determine

the level of impact this water has on the water quality. These

results are reported to the DWS, the latest results were

submitted on 8 February 2017. Weekly monitoring will again be

undertaken with the reporting of this overflow incident.

9) SITE SECURITY AND ACCESS CONTROL

The mine is access controlled to ensure no unauthorised

personnel are permitted into the mine. During the site

assessment the auditors were required to provide identification

documentation as well as permission from the Environmental

Practitioner was required to gain access to the mine. The

access to the Mooikraal Colliery is permitted through the main

gate which is access controlled. Access to 3 Shaft is also only

permitted by one gate. To gain entry, access cards as well as a

biometric systems have been implemented. Fencing has been

constructed around the entire Mooikraal Colliery and 3 Shaft and

no entry signage has been erected. Fencing has also been

erected around the PCDs (both Mooikraal and 3 Shaft) which are

required to prevent the possibility of drowning and restrict

access. Signage has also been erected to discourage people

from entering the restricted area. Additionally entry to the

underground workings is also restricted by means of a shaft

guard which requires proof that the individual is fit to work prior

to that individual proceeding.

External audits are undertaken to determine the level of

compliance the mine has towards its authorisation and EMPr.

The audit reports aim to document the non-conformities and

propose mitigation measures to address the issues that were

identified. These reports are submitted to the DMR by Sasol on

an annual basis to notify them of the non-conformities that may

have been identified. The lasted audit report was submitted in

December 2017.

Sasol Mining calculated the financial provision for the various

Sasol mines in 2018 which was completed by Jones and

Wagener (Ref No. JW047/15/E473 - Rev 3). Financial provision

for Mooikraal for 2018 was estimated to be R 70,209,540.00.

Financial provision for Old Sigma Coal Handling for 2018 was

estimated to be R 33,314,672.00. Financial provision for 3 Shaft

for 2018 was estimated to be R 11,088,759.00

.

the Emergency Preparedness and Response Procedure is available and

due for a revision in 2021.

No emergency incident has trigger the need for an update.

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o Natural disasters such

as floodso Industrial actiono Contact details of

police, ambulances and

any emergency centre

closer to the site

6.2

The holder must ensure that an up to date

emergency register is kept during all phases

of the mining operation. This register must

be made available upon request by the

department.


An incident register is retained onsite which records any incidents that may

occur during all phases of the mining operation. All incidents that occur at

Mooikraal are dealt with in accordance with the Emergency Preparedness

and Response Procedure.

There are no chnages to the way emergencies are addressed on site.

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7.1

If, in the opinion of this department,

nuisances or health risks may be or is

occurring on the site, the holder must initiate

an investigation into the cause of the problem

or suspected problem.


The department has not raised specific issues with regards to health risks

or nuisances. It is noted however that all non-compliance identified during

the audit is reported to the department on an annual basis.

Therefore, no further action required

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7.2

If, in the opinion of this department, pollution

may be or is occurring, the holder must

initiate an investigation into the cause of the

problem or suspected problem. Such

investigation must include the monitoring of

the water quality variables, at those

monitoring points and such frequency as may

be specified by the Department of Water and

Sanitation.


The department have not raised specific issues with regards to pollution or

contamination. It is noted however that all non-compliance identified during

the audit is reported to the department on an annual basis.


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7.3

Investigations carried out in terms of

conditions 7.1 and 7.2 above must include

the monitoring of the relevant environmental

pollution, nuisance and health risk variables,

at those monitoring points and such

frequency to be determined in consultation

with the relevant Departments.


The department has not raised specific issues with regards to health risks,

nuisances, pollution or contamination. It is noted however that all non-

compliance identified during the audit is reported to the department on an

annual basis.


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7.4

Should the investigation carried out as per

conditions 7.1 and 7.2 above reveal any

unacceptable levels of pollution, the holder

must submit mitigation measures to the

satisfaction of this and any other relevant

Department.


The department has not raised specific issues with regards to pollution. It

is noted however that all non-compliance identified during the audit is

reported to the department on an annual basis.


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8.1

The holder must apply for a closure

certificate as prescribed in the MPRDA

and any other applicable legislation


The Mooikraal Colliery has been operational since 2005 and has a LoM of

34 years. A closure certificate will only be applied for once LoM is

reached.

NA

8.2

The application for closure indicated above

must be submitted together with all relevant

documents as prescribed in the MPRDA and

any other applicable legislation.




reached. The mine will submit all relevant documentation at this time.

NA

The Mooikraal Colliery has been operational since 2005 and has

a LoM of 34 years. A closure certificate will only be applied for

once LoM is reached.



once LoM is reached. The mine will submit all relevant

documentation at this time.

The department have not raised specific issues with regards to

pollution or contamination. It is noted however that all non-

compliance identified during the audit is reported to the

department on an annual basis.













It is recommended that the Emergency Preparedness

and Response Procedure must be updated / revised

in 2018 and continue to be updated every two years

going forward and after any emergency incident that

would have a significant impact on the receiving

environment.

An incident register (Ref No. Ref No. SIG IMS 10.2 Incident

Register 2018) is retained onsite which records any incidents

that may occur during all phases of the mining operation. All

incidents that occur at Mooikraal are dealt with in accordance

with the Emergency Preparedness and Response Procedure

(Ref No. SIG IMS 447000). The DWS is also notified of the

incident such as the overflow of the water from the PCD into the

Kromelmboogspruit. This register is available should the

department wish to review it.

13) INVESTIGATIONS

■ Multiple casualty accidents

■ Entrapment

■ Total mine power failure

■ Fan/ventilation failure

■ Gas explosion (surface storage areas)

■ Employees missing underground

6.1 C

■ Spillages of potentially contaminated water (mine water

■ Diesel tank ruptures (Mooikraal) / petrol pump failure 3#

The Emergency Preparedness and Response Procedure was

last revised in 2013 and should have been reviewed on a

biennial basis in 2015 and again in 2017.

15) SITE CLOSURE

the Emergency Preparedness and Response Procedure is available and

due for a revision in 2021.

No emergency incident has trigger the need for an update.

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8.3

The holder remains responsible for any

environmental liability, pollution or ecological

degradation, the pumping and treatment of

extraneous water, compliance with the

conditions of this approval letter, the

approved EMPr, management and

sustainable closure thereof until the Minister

has issued a closure certificate in terms of

section 43 of the MPRDA. Where necessary

the Minister may retain certain portion of

financial provision for residual, health or

environmental impacts that might be known in

future.




reached. Mooikraal understands that environmental liability remains with the

mine until the closure certificate is obtained.

NA

Compliant 55 88.71

Non-compliant 7 11.29

Not Applicable 14

Total 76

Total Applicable 62

76



once LoM is reached. Mooikraal understands that environmental

liability remains with the mine until the closure certificate is

obtained.

Appendix B: EMPR Checklist

Compliance Compliance (2019)

C /NC/NA C /NC/NA

■ To ensure that the resource is

mined optimally.

The comprehensive monitoring of

surface subsidence is and will be

done in accordance with the

requirements of Regulation 5.3.6 and

Regulation 12.7.1 of the GN992 of

26/06/1970.

C

The Mooikraal Colliery undertakes both bord and

pillar and high extraction mining method to extract

the coal from the coal seam. It was

communicated that no high extraction mining is

undertaken beneath watercourses in accordance

with GN 704. To date no subsidence has

occurred within the Mooikraal mining right area.

However a visual surface inspection is

undertaken on a biannual basis of the elevation of

the land where high extraction has occurred.


The Mooikraal Colliery undertakes both bord

and pillar and high extraction mining method to

extract the coal from the coal seam. It was


undertaken beneath watercourses in

accordance with GN R 704. To date no

subsidence has occurred within the Mooikraal

mining right area. However a visual surface

inspection is undertaken on a biannual basis

of the elevation of the land where high

extraction has occurred.

C

Where the probability of an

occurrence of subsidence has been

determined and it poses a danger,

the void area underground, in that

specific area will be stabilised as far

as is practicably possible in terms of

Regulation 5.3.3 of the GN992 of

26/06/1970, after consultation with

the relevant authorities and affected

parties. The fill material used to date

consists of fine ash due to its

pozzalenic properties or fine ash and

cement mixtures.

C

It was communicated to Digby Wells that to date

no evidence of subsidence has occurred within

the Mooikraal mining right area. This was

confirmed by the biannual report which is

submitted to DWS ever year. This is based on

regular surveys that are done on the area that

has been undermined. Visual surveys are

completed on a quarterly basis with Lidar

monitoring undertaken on an annual / biennial

basis. It was confirmed that the survey will be

undertaken in 2018. However, should there be

such instances of subsidence; the areas will be

rehabilitated in order to make the area free

draining as far as practicably possible, as per

procedure: Rehabilitation of Damage to the

Surface Due to Underground Mining Operations at

Sigma Colliery (SIG IM (EM) 4.4.6 021). It should

however be noted that although the EMPr gives

permission to pump ash underground to stabilise

the underground workings, a IWUL will need to be

obtained before this is commenced with. To date

no ash backfilling has taken place at Mooikraal

Colliery.


No evidence of subsidence has occurred

within the Mooikraal mining right area. This is

confirmed by the biannual subsidence

monitoring report which is submitted to DWS

ever year. The report documents the findings

of regular surveys that are done in the area

that has been undermined.

C

Surface water permeability in the

subsidence areas will be controlled

from entering the underground

working by means of :

■ Rehabilitating the surface of the

soils as discussed in paragraph

5.3.2,

■ By making the area as far as is

practically possible to be free

draining, and

■ Where the soil type does not

allow for natural drainage the area

may have to be shaped to emulate

more or less the natural contours so

as to provide for surface run-off.

Audit Comments

EMPr for the Operation of Sigma Mooikraal Operations

Action Plan - Measures to be Implemented to

Achieve Compliance


■ To monitor surface subsidence

so as to determine and plan for the

long-term land use and to timeously

prevent or control a dangerous

situation which may occur from such

a subsidence.

Activity Aspect Objective Proposed Mitigation Measure Comments 2018

1 Geology

C



the Mooikraal mining right area. However, should

there be such instances of subsidence; the areas

will be rehabilitated in order to make the area free


procedure: Procedure for Rehabilitation of

Damage to the Surface Due to Underground

Mining Operations at Sigma Colliery (SIG IM (EM)

4.4.6 021). Additionally should subsidence occur

the area will be rehabilitated, thereafter the area

will be monitored for soil erosion every month for

a year, then biannually for a year and then

annually for three years until erosion is no longer

detected.


within the Mooikraal mining right area. This is

confirmed by the biannual subsidence

monitoring report which is submitted to DWS

ever year. The report documents the findings

of regular surveys that are done in the area

that has been undermined.

C

■ To ensure that no soils in new

areas are disturbed.

Soils in areas not allocated to the

building of infrastructures will not be

disturbed unnecessarily.

C

During the construction of the mine soils would

have been disturbed for the establishment of the

surface infrastructure as well as the incline shaft.

Since then the Kleinvlei Ventilation Shaft was

established in 2010 which resulted in further

disturbance of the soil in that specific area.

During the site assessment no unnecessary soil

disturbance was observed however the area

where the conveyor belt is located, a borrow pit

was constructed and the soil was disturbed.

Rehabilitation efforts have been undertaken

however it is noted that further rehabilitation is

still required. It was also determined that the soil

stockpiles were well vegetated and the waste

rock dump although erosion that was observed

did not require further intervention as the discard

dump was located within a contained area and no

soil lost to soil erosion was exiting the

containment area.

Although full rehabilitation will not be undertaken

until LoM is reached it is recommended that

rehabilitation of the borrow pits should be

undertaken to prevent ponding of water and the

spread of alien invasive species. The area should

be ploughed to make the surface level. Additionally

alien invasive management measures must be

implemented.


have been disturbed for the establishment of

the surface infrastructure as well as the incline

shaft.

No unnecessary soil disturbance was

observed however the area where the

conveyor belt is located, a borrow pit was

constructed and the soil was disturbed. Some

soils were also used to renovate the PCD spill

way.

Therefore, no soils were disturbed and being

used for buidling infrastructures at the time of

the audit.

It is still recommended that alien invasive

species management and eradication be

undertaken. The borrow pit has been made

free draining and will be rehabiliated at the

mine's end of LoM.

C

■ To prevent soil erosion.

■ To ensure that topsoil stockpiles

are managed in such a way that they

can be used for rehabilitation of the

disturbed areas.

Soil amelioration will be undertaken

to enhance the arable capability of

the soils and to sustain the ability of

the soil to retain oxygen and thus

sustain vegetative material during the

storage period.

C

During the site assessment it was observed that

soil has been stockpiled around the incline shaft,

PCD and utilised to construct stormwater berms.

These soil stockpiles are vegetated and are

regular inspected and maintained.


Soil has been stockpiled around the incline

shaft, PCD and utilised to construct

stormwater berms. These soil stockpiles are

vegetated and are regular inspected and

maintained.

C

The area undergoing rehabilitation

will be fenced and all animals

prevented from entering the area until

vegetation is sustainable.

NA

As the Mooikraal Mine is an underground coal

mine, limited rehabilitation is undertaken on areas

where mining or related activities have been

undertaken. It was reported that to date only

minimal rehabilitation activities had been

undertaken. Once LoM is reached, all

infrastructure will be removed from site and

rehabilitation will commence in line with the

rehabilitation measures proposed in the approved

EMPr, a rehabilitation management plan will be

compiled once closure is reached which will

include all mitigation measures to prevent

unnecessary environmental impact.

No further action requiredRehabilitation will be undertaken at the end of

LoM for Mooikraal. NA



PCD and utilised to construct stormwater

management berms. These soil stockpiles are

vegetated and are regular inspected and

maintained. No evidence of erosion was

observed on these soil stockpile areas.

A maintenance road (dirty road) has been

constructed along the conveyer belt for security

reasons and should maintenance activities need

to be undertaken. It was observed that erosion

was found along the road which needed to be

addressed.

It is recommended that good practice housekeeping

is implemented along the conveyer belt to ensure

that coal is cleaned up more regularly and the road

is maintained to address the issues of erosion

which was observed during the site visit.

2 Soils

Topsoil stockpiles will be vegetated

and the vegetation maintained to

prevent erosion throughout the life of

the mine.

C

Topsoil is used for the construction of berms

around the mine site. The berms are well

vegetated and well maintained.

C

Newly seeded/planted areas will be

protected against compaction and

erosion.

C













unnecessary environmental impact. It was

observed that all soil stockpiles as well as the

areas around the mine was vegetated



mine, limited rehabilitation is undertaken on

areas where mining or related activities have

been undertaken.

No newly seeded areas were observed during

the site visit.

NA

Traffic shall be limited where possible

while the vegetation is establishing

itself.

NA
















mine, Limited vehichles move the surface.

However, there are designated roads on the

mine and traffic signs indicating speed limits.

C

A monitoring programme will be

initiated to monitor the rehabilitation

of disturbed areas.

NA




undertaken. It was reported during the reporting

period that no rehabilitation had been undertaken

(Financial Provision J&W 2018).

It is recommended that once the borrow pits are

rehabilitated this monitoring plan must be

implemented to ensure no erosion or alien invasive

species occurs within the newly rehabilitated area.

A disturbed area that has been partially

rehabiliated by making it free draining and

naturally vegetating is the borrow pit.

The mine is maintained and monitored. Where

the free draining borrow pit begins to fail to

free drain, measures will be put in place to

address the issue until such a time that

rehabilitation of the mine commences.

C

3 Topography

■ To remove all “scars” and

emulate within ±2 m the “pre-mining“

topography so as to, as far as is

practicably possible restore the land

forms and surface drainage paths.

To reconcile the expected and actual

material swells of the overburden

removal and placement and do the

necessary adjustment to the long

term plan in order to meet the overall

objective.

NA

This condition is considered to be not applicable

at this stage. The bulk factor will be taken into

consideration once the boxcut is rehabilitated and

backfilled.



have been disturbed for the establishment of

the surface infrastructure as well as the incline

shaft.

The borrow pit was used for the construction

of conveyor belt. Besides this topography

change, no other excavations were observed.

The levellihng of the topography will only take

place when rehabilitation commences at the

mine's end of LoM. Therefore, for now this

action is not applicable.

NA

The main objective of the

reclamation of the surface of the land

to be impacted upon by the

operations of Sigma: Mooikraal

Operation is to restore the area to its

original potential for rain fed arable

production i.e. a COM Class II, land

capability and to establish a natural

grassland to:

The procedure for rehabilitation of

subsided areas is as follows:

4 Rehabilitation


2 Soils




there be such instances of subsidence, the areas

will be rehabilitated to make the area free draining

as far as practicably possible, as per procedure:

Rehabilitation of Damage to the Surface Due to

Underground Mining Operations at Sigma Colliery

(SIG IM (EM) 4.4.6 021). Additionally should

subsidence occur, the area will be rehabilitated,

thereafter the area will be monitored for soil

erosion every month for a year, then biannually

for a year and then annually for three years.


within the Mooikraal mining right area.

However, should there be such instances of

subsidence, the areas will be rehabilitated to

make the area free draining as far as

practicably possible, as per procedure:

Rehabilitation of Damage to the Surface Due

to Underground Mining Operations at Sigma

Colliery (SIG IM (EM) 4.4.6 021).

NA

■ Provide a satisfactory cover that

will stabilise the area, reduce the

potential for wind and water erosion

and thus reduce the potential for

contamination of the surrounding

■ The area is to be fenced off in

terms of Regulation 5.2 of the GN992

of 26/06/1970, if necessary,

■ environment,

■ Coarse and fine ash due to there

pozzalenic properties is then worked

into the cracks up to a level of ± 1m

from surface (Harmse, 1991-1993)

and where necessary this is sealed

by means of ±1m of clay,

■ Reduce the visual impact of the

mining area and restore or improve

on the pre-mining appearance of the

area,

■ A topsoil layer of at least 0.5m is

placed over the ash-filling or clay-

layer,

■ Create a more continuous plant

community across the area, and

■ The affected area is fertilised and

revegetated during the first rainfall

period after “repair work” has been

done,

■ Remove undesirable stands of

weedy species (exotics) and replace

them with a more productive and

acceptable grassland community.

■ The fencing will be removed once

the area has been rehabilitated and

the vegetation has established to a

minimum of 15% basal cover

(Chamber of Mines South Africa,

1979), and

■ The subsided areas are

inspected on a regular basis to

determine whether further

subsidence has occurred and if

necessary the process is repeated

until the area has stabilised.

The topsoil and sub-soil horizons are

stripped separately since the

physical, biological and chemical

characteristics of topsoil are

generally more suitable for the

germination, survival and growth of

the vegetation.

C

The topsoil stockpiles are located around the

incline shaft, PCD and utilised for stormwater

berms. No sub-soil is located onsite. These soil

stockpiles are well managed as they are

vegetated, no significant compaction was found

and no erosion was identified.


The topsoil stockpiles are located around the

incline shaft, PCD and utilised for stormwater

berms. No sub-soil is located onsite. These

soil stockpiles are well managed as they are

vegetated, no significant compaction was

found and no erosion was identified.

C

Soil stockpiles are avoided as far as

is practicably possible since soil

stripped at the workings is utilised

directly for rehabilitation. Vegetation

cover is mulched into the topsoil

during removal providing additional

organic nutrients to the soil.

C

Soil stockpiles are utilised as bunds and have

been vegetated. Vegetation cover will only be

mulched into the topsoil during removal providing

additional organic nutrients to the soil during

rehabilitation. Therefore this condition is

considered to be not applicable.


Soil stockpiles are utilised as bunds and have

been vegetated. Vegetation cover will only be

mulched into the topsoil during removal

providing additional organic nutrients to the

soil during rehabilitation. Therefore this


C

Vegetation cover is mulched into the

topsoil during removal providing

additional organic nutrients to the

soil.

NA




undertaken. No rehabilitation was undertaken

within the reporting year as indicated in J&W

Financial provision Report, 2018. No mulching

was undertaken as no soil removal was

completed.





been undertaken. No rehabilitation was

undertaken within the reporting year as

indicated in J&W Financial provision Report,

2018. No mulching was undertaken as no soil

removal was completed

NA

4 Rehabilitation


Soils removal placement and land preparation:





will be rehabilitated to make the area free draining

as far as practicably possible, as per procedure:

Rehabilitation of Damage to the Surface Due to

Underground Mining Operations at Sigma Colliery

(SIG IM (EM) 4.4.6 021). Additionally should

subsidence occur, the area will be rehabilitated,

thereafter the area will be monitored for soil

erosion every month for a year, then biannually

for a year and then annually for three years.


within the Mooikraal mining right area.

However, should there be such instances of

subsidence, the areas will be rehabilitated to

make the area free draining as far as

practicably possible, as per procedure:

Rehabilitation of Damage to the Surface Due

to Underground Mining Operations at Sigma

Colliery (SIG IM (EM) 4.4.6 021).

NA

A veld-burning programme will be

followed to remove

moribund/unacceptable grass

material, to contain/prevent

encroachment of undesirable plants.

C

No veld burning programme has been

implemented however, measures have been

undertaken to ensure fire breaks are still

established such as the continued maintains of

the areas and ensuring that the grass is cut to a

height of 50 mm through a maintenance

subcontractor specifically during the summer and

winter seasons within the Mooikraal Colliery.

Communication between farmers and the mine is

also undertaken to ensure firebreaks are

constructed on adjacent farms.





established such as the continued maintains

of the areas and ensuring that the grass is cut

to a height of 50 mm through a maintenance

subcontractor specifically during the summer

and winter seasons within the Mooikraal

Colliery. Communication between farmers and

the mine is also undertaken to ensure

firebreaks are constructed on adjacent farms.

Although a formal plan is not in place, the

purpose of a veld-burning programme is being

achieved by the measures put in place with

the fire breaks.

C

In order to limit erosion of soils, prior

to the establishment of vegetation,

erosion control contours are placed

at intervals over the rehabilitated

land. This limits the effect of

uncontrolled run-off and excessive

erosion.

C






undertaken. Rehabilitation has been undertaken

at the borrow pit areas. Vegetation has been

established however further rehabilitation is

required to prevent ponding of water. Soil

stockpiles have also been vegetated and will be

utilised once the mine ceases operation.

Although full rehabilitation will not be undertaken

until LoM is reached it is recommended that

rehabilitation of the borrow pits should be

undertaken to prevent ponding of water and the

spread of alien invasive species. The area should

be ploughed to make the surface level. Additionally

alien invasive management measures must be

implemented.

Rehabilitation will be undertaken at the end of

LoM for Mooikraal.

The site is well vegetated, the topsoil is used

as berms around the area and well

maintained.

Rehabilitation has not become applicable yet

as the mine is in the operational phase.

NA

Vegetation establishment:

Grasses - Revegetation (seeding) is

programmed for the season and time

of year, which will yield the optimum

germination and growth (late

spring/early summer). Successful

germination should be achieved

within six weeks.

Maintenance of all planted

revegetated areas - The following

maintenance is required:

■ Newly seeded/planted areas must

be protected against all undue traffic

and/or other disturbances throughout

the establishment period,

■ Plants should be watered and

weeded regularly,

■ A check for pests and diseases

at least once every two weeks and

treatment, (if necessary), for six

months,

■ Replace unhealthy or moribund

specimens,


4 Rehabilitation

No further action requiredNA






undertaken. Within the reporting period no

rehabilitation activities had been undertaken

(Financial Provision J&W 2018). It was observed

that vegetation has been established on soil

stockpiles and around the mining infrastructure

area.

NA








(Financial Provision J&W 2018). Once LoM is

reached, all infrastructure will be removed from

site and rehabilitation will commence in line with

the rehabilitation measures proposed in the

approved EMPr, a rehabilitation management plan

will be compiled once closure is reached which

will include all mitigation measures to prevent

unnecessary environmental impact. All steps

listed must be implemented by the mine should

rehabilitation be undertaken during the operational

phase.




been undertaken. It was reported that to date

only minimal rehabilitation activities had been




reached, all infrastructure will be removed

from site and rehabilitation will commence in

line with the rehabilitation measures proposed

in the approved EMPr, a rehabilitation

management plan will be compiled once

closure is reached which will include all

mitigation measures to prevent unnecessary

environmental impact. All steps listed must be

implemented by the mine should rehabilitation

be undertaken during the operational phase.

NA

Rehabilitation will be undertaken at the end of

LoM for Mooikraal. NA

■ Fertilize the grassed areas with

150 kg/ha LAN (28), 4-6 weeks after

germination under

■ Favorable growing conditions,

■ Control alien invasive plants, and

■ Continually repair any damage

caused by erosion.

Irrigation - In the establishment of

vegetation during the rehabilitation

procedure irrigation will be necessary

where rainfall is insufficient.

NA








(Financial Provision J&W 2018). No vegetation

was planted and therefore no irrigation was

undertaken









(Financial Provision J&W 2018). No

vegetation was planted and therefore no

irrigation was undertaken

NA

The rehabilitated areas must be well

managed when post-mining utilisation

commences to prevent deterioration

of the grazing and degradation of the

environment.

NA
























(Financial Provision J&W 2018). No

vegetation was planted and therefore no

irrigation was undertaken

NA

It is noted that environmental awareness training

is undertaken on a monthly basis through the use

of meetings/ posters/ annual induction/

Environmental monthly topics and events such as

Arbour day tree planting which occurs every

August. Environmental training is undertaken

during the 2nd level SHE meetings. Monthly

environmental awareness poster are placed

around the mine. Annual induction is attended by

all employees and service providers which

includes aspects of environmental awareness.

Additional induction training includes the following:

■ Waste handling (hazardous, general and

recycled)

■ Water conservation

■ Soil contamination with oil spills/ diesel spills

■ Basics of ISO 14001


No further action requiredC

4 Rehabilitation

Environmental awareness training

should form part of the annual

induction training.

NA















unnecessary environmental impact. All steps

listed must be implemented by the mine should

rehabilitation be undertaken during the operational

phase.









reached, all infrastructure will be removed

from site and rehabilitation will commence in

line with the rehabilitation measures proposed

in the approved EMPr, a rehabilitation

management plan will be compiled once

closure is reached which will include all

mitigation measures to prevent unnecessary

environmental impact. All steps listed must be

implemented by the mine should rehabilitation

be undertaken during the operational phase.

NA

It was noted that environmental awareness

training is undertaken on a monthly basis

through the use of meetings/ posters/ annual

induction/ Environmental monthly topics and

events. Awareness presentations were

provided, with topics such as Greenhouse

Gases, Waste Minimisation and Firebreaks.

C

In order to mitigate the impact on the

loss of habitats, and the change in

habitat composition, the following

measures will be implemented:

Any areas that are rehabilitated

during operation, as well as sensitive

areas shall be monitored for alien

species invasion. This will be

performed at least once per season

and more frequently during very wet

seasons. All alien species found will

be removed according to the alien

plant control programme (Appendix

3).

NC

An alien plant/weed eradication programme is not

implemented on an annual basis. The Mooikraal

Colliery is in the process of developing an

operational procedure for the management of

alien invasive species onsite. It was noted that

regular inspections are undertaken by the

Environmental Practitioner at Mooikraal to ensure

the invasive species are removed to prevent the

spread of species. Mooikraal currently spray

herbicides around the conveyer belt and other

problem areas previously identified. During the

site assessment it was observed that invasive

species were present such as Scottish Thistle,

Cockleburs and Pink Tamarisk. It was

communicated that most invasive species have

been established on areas that have been

disturbed and no significant spread of invasive

species have been observed.

It is recommended that the alien plant control

programme attached as Appendix 3 to the EIA

Report is implemented to manage and control the

alien invasive species which are present onsite.

The eradication of invasive species is required by

National Environmental Management Biodiversity

Act (NEMBA) (Act 10 of 2004) – Alien and Invasive

Species (AIS) regulations, 2014 and any plan

drafted in compliance with the legal requirements

must be implemented. Invasive species must be

removed to prevent spreading to other areas

around the site. Mechanical methods should be

used to remove the invasive species specifically at

the time of the year when the plants are not

producing seeds which can result in the spread of

these species to other areas. The disposal of these

species must be removed in a controlled manner to

prevent further spreading. Proof of training specific

to the invasive species identified on site must be

provided either to the appointed contractor or the

person made responsible for the removal of alien

invasive species.

Alien species identification has been

undertaken. The development of an


alien invasive species onsite is needed to

give effect to the alien plant control

programme already set in place by the mine.

It has been communicated that the plan for

2020 will be to implement an alien eradication

programme on site.

NC

Areas, which have been disturbed by

the mining operations and are no

longer used will to be revegetated

with vegetation indigenous to the

area (refer to paragraph 5.3.4).

NA








(Financial Provision J&W 2018). Areas that had

been vegetated after construction included the

soil stockpiles, berms and borrow pit areas





been undertaken.

The borrow pit was used for the construction

of conveyor belt. It has been made free

draining and it is vegetated and full

rehabilitation will take place.

C

Vegetation used for rehabilitation will

be selected for its self-sustaining

properties. If natural re-vegetation

does not occur, the vegetation will be

replaced.

NA













unnecessary environmental impact. Additionally a

re-vegetation programme will be implemented to

ensure indigenous vegetation is utilised during

rehabilitation. Additionally alien invasive species

monitoring will be undertaken on the newly

rehabilitated areas so as to prevent the spread of

invasive species.


Rehabilitation will only take place at

Mooikraal's end of LoM.

A rehabilitation management plan will be




NA

5 Flora

To maintain the status quo after

construction is completed and to

conserve and protect the structure of

the vegetation community and

prevent further loss of species

diversity.

Off-road driving by mine vehicles

through the surrounding veld will be

prohibited.

C

Maintenance vehicles are used on a daily basis

around the mine to inspect the conveyor belt and

visit the Kleinvlei Vent shaft. The vehicles are

required to utilise established road networks

which may include main roads, farm roads and

maintenance roads. It was communicated that

should a vehicle need to access an area away

from the road network caution is taken to ensure

no damage or impact to the environment occurs.


Main roads, farm roads and maintenance

roads are used when moving about the site.

Caution is taken when accessing areas that is

far from a road network.

C

C

■ Minimal rehabilitation has been undertaken for

the mine, however where rehabilitation is

undertaken this is done in accordance with the

rehabilitation mitigation measures included in the

EMPr.

■ It was noted that alien invasive species have

been identified on site and therefore measures

need to be implemented to prevent the spread of

these species.

■ No veld burning programme has been



established such as the continued maintain of the

areas and ensuring that the grass is cut to a

height of 50 mm through a maintenance

subcontractor specifically during the summer and

winter seasons.





established such as the continued maintains

of the areas and ensuring that the grass is cut

to a height of 50 mm through a maintenance

subcontractor specifically during the summer

and winter seasons within the Mooikraal

Colliery. Communication between farmers and

the mine is also undertaken to ensure

firebreaks are constructed on adjacent farms.

Although a formal plan is not in place, the

purpose of a veld-burning programme is being

achieved by the measures put in place with

the fire breaks.

C


training is undertaken on a monthly basis through

the use of meetings/ posters/ annual induction/

Environmental monthly topics and events such as

Arbour day tree occur on a yearly basis. The

most recent training was undertaken via posters

which aimed to encourage better water

management.

Limited trees are located within the mining area

however it is noted that the collection of firewood

is prohibited and this is communicated through

induction training. Additionally it is noted that the

wood waste that is taken to Sasol’s reclamation

yard. The wood waste is then sold to Arc

Charcoal, who utilise the wood as fuel for the

making of charcoal



training is undertaken on a monthly basis

through the use of meetings/ posters/ annual

induction/ Environmental monthly topics and

events such as Arbour day tree occur on a

yearly basis. Awareness presentations were

provided, with topics such as Greenhouse

Gases, Waste Minimisation and Firebreaks.

C

Any form of hunting, poaching,

snaring or trapping will be prohibited

within the mining area.

Birds

In order to further improve bird

habitat the following measures will be

taken:

■ The active planting of the tree

screens and the revegetation of the

badly disturbed areas will definitely

improve the bird habitats.

Mammals

In order to minimise the impacts on

mammals the following actions will be

taken:

■ Relocate specimens.

Reptiles and amphibians

In order to minimise the impacts on

reptiles and amphibians the following

actions will be undertaken:

■ Relocate specimens which may

be trapped in trenches, adits and

other mine related structures, and


No form of hunting is permitted at the Mooikraal

Colliery or Sigma 3 Shaft. This is communicated

through the induction that must be undertaken by

each individual working onsite. Security guards

regularly patrol the mine to ensure no

unauthorised entry to the mine and ensure no

hunting is taking place. It was noted that should

an animal be identified onsite the individual is

required to alert the Environmental Practitioner.

Depending of the species that is identified efforts

will be undertaken to relocate the species away

from the mine. It is noted that no killing of any

animal is permitted.

5 Flora

To maintain the status quo after

construction is completed and to

conserve and protect the structure of

the vegetation community and

prevent further loss of species

diversity.

In order to limit habitat disturbance

and fragmentation, the following

programmes shall be established

■ A rehabilitation programme for

the areas disturbed during the

construction phase

■ Alien plant control programme

(Appendix 3)

■ A fire management programme

■ Education/awareness

programme for all staff regarding the

management and protection of

biodiversity

■ Collection of firewood will be

prohibited.

6

Fauna

To minimise the impact of the mine

on animal life and re-establish and

enhance animal populations that

existed pre-mining.

C

No form of hunting is permitted at the

Mooikraal Colliery or Sigma 3 Shaft. This is

communicated through the induction that must

be undertaken by each individual working

onsite. Security guards regularly patrol the

mine to ensure no unauthorised entry to the

mine and ensure no hunting is taking place. It

was noted that should an animal be identified

onsite the individual is required to alert the

Environmental Practitioner. Depending of the

species that is identified efforts will be

undertaken to relocate the species away from

the mine. It is noted that no killing of any


C

■ Where practical, slope the walls

of permanent trenches to enable

trapped animals to escape.

■ Killing of snakes prohibited - they

will be relocated

The objectives of surface water

management will be:

■ To manage the operation in such

a way as to prevent surface water

contamination that will impact on the

aquatic environment,

■ To operate within the law as

stated in the MPRDA, 2002 (Act 28

of 2002) and the National Water Act,

1998 (Act 36 of 1998) and to ensure

that all the applicable requirements of

the National Water Act, are complied

with, in particular Government Notice

704,

■ To affect catchment yield as little

as is practically possible,

■ To keep 1:50 and regional

maximum floods out of the mine,

Surface water monitoring is undertaken to

determine whether the water qualities are in

accordance with the IWUL and Resource Quality

Objectives. The report indicates that samples are

taken on a quarterly basis and reported on

biannually. The most recent biannual water

monitoring report for Mooikraal is dated February

2018 (Ref No. 2018/04/PJHL) and compiled by

IGS. The report indicated that variations in water

quality of Kromelmboogspruit North and South

have been detected and can be attributed to the

uncontrolled mine water discharge into the

Kromelmboogspruit which has been prevalent

since 2010. However the report indicated that

over the monitoring period the surface water

qualities were within the IWUL limits.

It was observed that dirty water runoff generated

at Sigma 3 Shaft from the coal stockpile area

enters the Leeuspruit. The monthly water quality

results indicated an increase of sulphate levels

over the past eighteen months. It is however

noted that the deteriorating water quality is not

only from 3 Shaft and has other contributing

factors. The most recent biannual water

monitoring report for Sigma (which includes 3

Shaft) is dated January 2018 (Ref No.

2018/03/PJHL) and compiled by IGS.

The upgrade of stormwater management

mechanisms at Sigma Colliery: 3 Shaft will

only be effected once the Regulation 31

Amendment and WUL is granted.

Water monitoring, both surface water and

groundwater, is undertaken on a quarterly

basis. The October 2019 report indicated that

calcium-bicarbonate signature for the

upstream monitoring point and sodium-

bicarbonate signature for the downstream

monitoring point of Kromelmboogspruit North

and South whcih can be attributed to the

release of mine water discharge into the

Kromelmboogspruit t since 2010.

Based on the STP results from May to

November 2019 shows that from July, the

Nitrate dropped from 16.20 in June to 1.10 in

July. This can be attributed to the fresh

innoculent that the clinet injected into the STP.

E Coli is at a 0.00 readingfrom May to

November and was thus dealt with as per the

instructions of the 2018 recommendations.

C

■ To restrict the impacts of

polluted water to the mining area

■ To operate within the standards

and operational procedures,

■ To as far as is practicably

possible have a free draining

topography over rehabilitated areas,

The STP is authorized under the Water Use

Licence (WUL) (Licence No

08/C22K/CIGJFAE/6981) approved on 16

January 2018. The sewage is treated to an

acceptable standard in accordance with the WUL

and discharged to the Kromelmboogspruit. The

water qualities reported on from the STP are

however not complying with the water quality

standards in the IWUL. High levels of Nitrates and

E-coli were detected in the monitoring data (STP

Water Quality, 2018). It was however observed

during the site assessment that maintenance of

the STP was being undertaken in an attempt to

clean out the system and ensure the STP

operates optimally.

The STP is authorized under the Water Use

Licence (WUL) (Licence No

08/C22K/CIGJFAE/6981) approved on 16

January 2018. The sewage is treated to an

acceptable standard in accordance with the

WUL and discharged to the

Kromelmboogspruit.

Fresh innoculent was injected into the STP

and the Nitrates and E.Coli have stabilised to

licenced levels. Based on the STP results

from May to November 2019 shows that from

July, the Nitrate dropped from 16.20 in June to

1.10 in July. This can be attributed to the fresh

innoculent that the clinet injected into the STP.

E Coli is at a 0.00 readingfrom May to

November and was thus dealt with as per the

instructions of the 2018 recommendations.

C


No form of hunting is permitted at the Mooikraal

Colliery or Sigma 3 Shaft. This is communicated

through the induction that must be undertaken by

each individual working onsite. Security guards

regularly patrol the mine to ensure no

unauthorised entry to the mine and ensure no

hunting is taking place. It was noted that should

an animal be identified onsite the individual is

required to alert the Environmental Practitioner.

Depending of the species that is identified efforts

will be undertaken to relocate the species away

from the mine. It is noted that no killing of any


It is noted that once the pipeline between Mooikraal

at 3 Shaft has been constructed water will no longer

be accidently discharged to the environment this will

assist in reducing the elevated surface water quality

levels within the Kromelmboogspruit.

It is noted that monitoring of surface water is not

being undertaken monthly as required in terms of

the EMPr and IWUL, except when the PCDs at

Mooikraal Colliery overflows, which occurs

occasionally which is then undertaken on a weekly

basis. Surface water quality samples should be

undertaken in accordance with the monitoring

methodology approved in the EMPr and IWUL.








Mooikraal has proposed that an upgrade to the

stormwater management at Sigma 3 Shaft is

required to ensure all dirty water is contained within

the operation and not discharged to the Leeuspruit.

The proposed upgrade involves the separation of

clean and dirty water. The containment of dirty

water and sending it to the SO. The existing crusher

area will also be relocated and rehabilitated. A

basic assessment and 31 amendment process is

currently being undertaken to assess the impacts

associated with the proposed project and obtain the

required authorisation. Mitigation measures

proposed as part of this process must be

implemented to make this condition compliant.

Should authorisation be received, rehabilitation of

the built up of coal will be removed from the area

the coal which has been built up beneath the

culvert. Investigation needs been be undertaken

should a IWUL be required to undertake the

rehabilitation beneath the culvert.

Surface water

(Aquatic

Systems)

Surface water will be monitored

monthly to check for deterioration of

water quality and to identify potential

seepage pathways.

NC

6

Fauna

To minimise the impact of the mine

on animal life and re-establish and

enhance animal populations that

existed pre-mining.

C

No form of hunting is permitted at the

Mooikraal Colliery or Sigma 3 Shaft. This is

communicated through the induction that must

be undertaken by each individual working

onsite. Security guards regularly patrol the

mine to ensure no unauthorised entry to the

mine and ensure no hunting is taking place. It

was noted that should an animal be identified

onsite the individual is required to alert the

Environmental Practitioner. Depending of the

species that is identified efforts will be

undertaken to relocate the species away from

the mine. It is noted that no killing of any


C

The necessary control measures will

be maintained to ensure containment

of spillages at the plant and shaft

areas, e.g. pollution control dams, the

clearing of channels, etc.

NC


water was overflowing uncontrolled from the PCD

into the Kromelmboogspruit. It was observed that

the water was overflowing beneath the spill way

which may indicate issues relating to structural

integrity of the dam wall of the PCD. The

overflow of water from the PCDs to the

environment is not authorised in terms of the

NWA and under the IWUL. Measures have been

put in place to manage the excess water. This

includes the construction of a 7 ML and 10 ML

pipeline which will direct the water from the PCDs

to the Sasolburg Operations and prevent the

unauthorised discharge. The construction of the

pipeline received environmental authorisation in

2015 with the IWUL being authorised in January

2018. The pipeline has been constructed except

in the areas where the pipeline will cross

watercourses. It is proposed that the pipeline will

be fully constructed by the end of 2018. It was

observed that the PCD at 3 Shaft was also quiet

full and above the 0.8 m recommended levela

Once the 7ML and 10ML pipeline is constructed

water will be transferred between Mooikraal PCDs

to SO PCDs which will prevent further discharge of

dirty water to the environment at Mooikraal. A Dam

Safety Inspection by a professional Registered

Engineer on the PCDs at Mooikraal must be

undertaken to ensure the PCDs are able to contain

the required amount of water without the potential of

dam failure. Additionally the incident is required to

be reported to water affairs if the reason for the

overflow was due to the integrity of the PCDs.


PCD at 3 Shaft was at full capacity and above the

0.8 m recommended freeboard level. The water

level within the PCD at 3 Shaft must be reduced to

be within the recommended level.

The PCDs were not overflowing. Water is

being transported via the constructed

pipelines to other Sasol Operations.

C

Prevent areas of high infiltration from

developing on mined areas and

ensure free drainage

C





will be rehabilitated in order to make the area free




Mining Operations at Sigma Colliery (SIG IM (EM)

4.4.6 021). Additionally should subsidence occur

the area will be rehabilitated and will be made free

draining.


There was no evidence of subsidence having

occurred within the Mooikraal mining right

area. However, should there be such

instances of subsidence, the areas will be

rehabilitated in order to make the area free




Mining Operations at Sigma Colliery (SIG IM

(EM) 4.4.6 021). Additionally should

subsidence occur the area will be rehabilitated

and will be made free draining.

NA

Limit containment of uncontaminated

stormwater limit interference with

natural surface water drainage

system

NC

An IWWMP has been completed (Digby Wells,

2015 (Ref No. SAS1388) which aims to identify

potential ground and surface water contamination

and implement management measures to ensure

dirty water is contained within the operation and

clean water is permitted to be discharged. It is

noted that the IWWMP is proposed to be updated

in 2018. During the site visit two incidents where

dirty water was being discharged to the natural

surface water drainage systems was observed.

At Mooikraal Colliery it was found that the water

generated around the Silo and Conveyer belt area

is not contained to the dirty water system and the

water is currently discharging to the clean water

environment. This water may contain coal and

therefore is considered to be dirty water.

Additionally stormwater from the processing plant

at 3 Shaft will enter the Leeuspruit directly during

rainstorm events which eventually ends up in the

Vaal River.

Effective stormwater management measures must

be implemented at both Mooikraal (soil / conveyer

belt area) as well as at 3 Shaft. Dirty water

generated from the mine should be contained as it

can result in the contamination of soil and surface

water. It is however noted that stormwater

management measures are proposed to be

implemented at 3 Shaft as part of the conveyor

relocation project which will be authorised as part of

the BAR / 31 Amendment process.

A Standard Operating Procedure (SOP) for

stormwater management and the maintenance

of Sigma Colliery: 3 Shaft has been put

together and due for review in 2021. It is


measures are proposed to be implemented at

3 Shaft as part of the conveyor relocation

project which will be authorised as part of the

Regulation 31 Amendment process.

Therefore, this commitment remains a non-

compliance as the measures necessary for a

compliance are still to be authorised by the

competent authority.

NC

Surface water

(Aquatic

Systems)

6

Surface water

(Hydrology)

To ensure that the impact from the

mining infrastructure will not increase

from that of the construction phase.

Stormwater control measures will be

maintained around the shaft and plant

area (at 3 Shaft) to ensure the

maximum return of clean water to the

natural drainage systems.

NC

Clean water canals are in place around the

Mooikraal Shaft which ensures that all clean

water from the adjacent farm lands will be diverted

away and around the shaft.

During the site visit two incidents where dirty

water was not contained to the dirty water system

and being discharged to the clean environment.

At Mooikraal Colliery it was found that the water

generated around the Silo and Conveyer belt area

was ponding and not contained to a dirty water

system. This water contains fine coal and

therefore is considered to be dirty water.

Additionally stormwater from the processing plant

at 3 Shaft is not contained to the immediate area

but left to enter into the Leeuspruit which

eventually ends up in the Vaal River.


to be implemented at both Mooikraal (soil /

conveyer belt area) as well as at 3 Shaft. Dirty

water generated from the mine should not be

permitted to be discharged as it can result in

contamination. It is however noted that stormwater


implemented at 3 Shaft as part of the 31

Amendment process.




together and due for review in 2021. It is


measures are proposed to be implemented at

3 Shaft as part of the conveyor relocation

project which will be authorised as part of the

Regulation 31 Amendment process.





NC

■ To prevent the deterioration of

the surface water quality during the

operational phase as a result of

sedimentation, seepage from the

stockpiles, overburden dump and

spillages.

Soil erosion measures will be

maintained at the topsoil stockpiles,

overburden dumps and shaft area,

including the vegetation of these

deposits and construction of

paddocks where applicable.

C



PCD and utilised to construct stormwater berms.

These soil stockpiles are vegetated and are

regularly inspected and maintained. No evidence

of erosion was observed on these soil stockpile

areas.

Erosion was noticed at the borrow pit next to the

Waste Rock Dump. This area has not been

rehabilitated. This area will only be rehabilitated

hen equipment will be available to make the area

free draining and remove the larger waste rock

boulders.


Th overburden stockpile will be used for

rehabilitation purposes when Mooikraal

reaches its end LoM. It is located in a clean

water area and has a berm constructed

around it. The vegetation of the overburden

stockpile was not successful, and erosion can

be observed, and this is due to the gradient of

the slope being too steep (Digby Wells

Environmental Mooikraal Audit, 2018).

No other stockpiles were observed on site.

C

7

Surface water

(Water Quality)

■ To maintain all the water pollution

control measures so that they will be

able to handle a 1:50 year flood

event.

Contaminated runoff water from the

dirty areas (shaft and plant at 3

Shaft) will be contained in water

pollution control dams (North and

South dams) that will be able to retain

a 1:50 year flood event. From these

dams it will be recycled back into the

process for reuse in the mine or

pumped to SII.

NC

As per the NWA, dirty water is not permitted to be

discharged to the environment without an IWUL

and the water quality is acceptable for discharge.

It is noted that an IWWMP has been compiled for

Mooikraal and is in the process of being updated.

Water at the Mooikraal Colliery specifically

around the shaft is contained in the North and

South PCDs and transferred to the SO.


dirty water at the Silo and Conveyer belt area at

Mooikraal is not contained to a dirty water system

but left to pond in the immediate area. This may

result in groundwater contamination or potential

discharge to the clean water environment. No

dirty water system is currently in place to contain

the water.

At 3 Shaft it was observed that the dirty water

was not contained to the immediate area but left

to flow directly into the Leeuspruit. It should also

be noted that water from 3 Shaft can not be

pumped back to North and South PCD and

therefore this condition for 3 Shaft is considered

to be impractical.

It is recommended that regular housekeeping is

undertaken at the Silo and conveyer belt area at

Mooikraal Colliery to ensure the area is kept clear

of coal. Ponding of water should also not be

permitted as it can result in contamination of the

groundwater and should it leave the area it can

result in the contamination of surface water.

Effective stormwater management measures must





contamination of the receiving water environment. It

is however noted that the stormwater management

measures will be upgraded at 3 Shaft as part of the

BAR /31 Amendment process.

The situation has not changed since the

previous audit in 2018. Effective stormwater

management measures for Mooikraal will be

put into effect upon the authorsation of the

Regulation 31 Amendment.

The mine should in the meantime implement

best practice measures to ensure that dirty



contamination of the receiving water

environment.

NC

It is recommended that regular housekeeping must

be undertaken at the Silo and conveyer belt area to

ensure the area is kept clear of coal and silt.

Ponding of water should also not be permitted as it

can result in environmental contamination.








implemented at 3 Shaft as part of the BAR/ 31

Amendment process.



at the fuel and hydraulic oil storage area to ensure

the sump operates at optimal capacity.

7

Surface water

(Water Quality)

NC

Measures implemented to separate

clean and dirty stormwater at the

shaft (Figure 8) and plant (at 3 Shaft)

(Figure 9) will be maintained and

upgraded where necessary to

prevent spillages to the natural

environment .

Water at the Mooikraal Colliery specifically

around the shaft is contained in the North and

South PCDs and transferred to the SO.


dirty water at the Silo and Conveyer belt area at

Mooikraal is not contained to a dirty water system

but left to pond in the immediate area. This may

result in groundwater contamination or potential

discharge to the clean water environment. No

dirty water system is currently in place to contain

the water.

At 3 Shaft it was observed that the dirty water

was not contained to the immediate area but left

to flow directly into the Leeuspruit.

It was observed that regular maintenance of the

clean and dirty water canals is undertaken. The

sumps are inspected visually weekly by surface

services for volume. Stormwater management

infrastructure are inspected in summer months on

a monthly basis and in winter months every 2

months.

A sump and oil trap has been constructed to

collect all the water being discharged from the fuel

and oil storage area. However currently there is

not oil skimmer and water is being pumped out

manually.











environment.





NC

The mine will implement measures to

minimise its dirty water make that

need to be handled in the water

balance e.g. dirty areas at the plant

will be kept to the minimum.

NC

Mooikraal regularly monitors their water flow

which is recorded on a flow spreadsheet and

submitted to DWS. The water is currently pumped

from underground, to the PCDs and then to SO.

It is however noted that at present Mooikraal

Colliery is generated excess water which cannot

be contained within the North and South PCD

which is resulting in overflows. A 10 ML and 7 ML

are proposed to be constructed to transfer the

water to SO for further use. It is also noted that

the Water Balance contained in the IWWMP,

2015 does not include the flow of water at 3

Shaft. The IWWMP for Mooikraal was compiled

in 2015 and is proposed to be updated in 2018 to

ensure relevance to the current operation at

Mooikraal and 3 Shaft. It was observed that water

is currently discharging from 3 Shaft into the

Leeuspruit and that stormwater mitigation

measures currently located in the area is not

considered to be effective. It is considered that

the dirty water areas are not being kept to a

minimum.



to SO which will prevent further discharge of dirty

water to the environment at Mooikraal.

The IWWMP is required to be updated on an annual

basis and submitted to the DWS. However, the

IWWMP has not been updated since 2015. Digby

Wells have been appointed to update the IWWMP.

During this update process it is recommended that

the Water Balance should also be updated to reflect

accurate water quantities as well as include 3 shaft

water usages which have been omitted in the 2015

IWWMP


to be implemented at 3 Shaft. Dirty water generated




measures are proposed to be implemented at 3

Shaft as part of the 31 Amendment process











environment.





NC

Contaminated water will be pumped

to the dirty water system for reuse in

the plant and service water

underground.

NC

Mooikraal Colliery

Groundwater flows into the underground workings

at Mooikraal Colliery. These workings must be

kept dry for health and safety as well as

continued production reasons. The water is then

pumped to the various underground dams and

then to the PCDs. The water contained in the

PCDs is then pumped away to the SO through a

5ML pipeline.

3 Shaft

Water at 3 Shaft is received from Mooikraal and

utilised for dust suppression. It is however noted

that there is currently no water containment at 3

Shaft which is resulting in contamination of soil

and surface runoff to the Leeuspruit.












The water pipelines from Mooikraal to 3Shaft

and other Sasol operations is operational. The

PCDs are not overflowing into the river

system.

The stormwater management measures

proposed and the upgrades needed at 3Shaft

need the Regulation 31 Amendment to be

approved and issued so as to authorise those

changes to be able to deal effectively with the

irty water management at 3Shaft.

Therefore, the fulfilment of this condition lies in

the Regulation 31 Amendment being granted

to authorise the stormwater measures being

proposed to handle the dirty water

management.

NC

Machinery to be brought up from

underground for repairs or

maintenance will first be washed in a

demarcated area underground. This

equipment will then be cleaned,

serviced and repaired in a dedicated

workshop with the necessary

pollution control measures in place

such as dedicated wash bays with oil

separators and a facility to contain

the recycled oil.

C

Machinery is continuously being repaired as part

of preventative maintenance. It was noted that

machinery is washed in a demarcated washbay

prior to it being transferred to the workshop area

for maintenance. The workshop underground and

washbay underground has not been established

yet. A sump is being constructed around the

workshop to capture any oil and dirty water that

may be generated at the washbay and parking

area. This water is then pumped to the PCDs. It

is noted that this area around the workshop is

concreted. A sump is located near the wash bay

which captures the water. A skimmer is also

located at the sump to skim the hydrocarbon oil

off the water. The hydrocarbon is stored in used

oil tanks located on a concrete area. This oil is

then removed by EWOR for recycling.


Machinery is continuously being repaired as

part of preventative maintenance. It was noted

that machinery is washed in a demarcated

washbay prior to it being transferred to the

workshop area for maintenance.

However, it is recommended that redundant

underground cars need to be removed.

C

7

Surface water

(Water Quality)

Clean stormwater and run-off will be

diverted around the shaft, overburden

stockpile, plant and waste storage

areas. Contaminated water will be

contained and put back into the

process water system, for reuse.

NC

It was noted that clean stormwater channels

have been constructed around Mooikraal Colliery

to divert clean water .around the shaft. Berms are

constructed around the WRD to contain any

runoff containing silt and prevent the

contamination of the surface water.

No clean and dirty stormwater management

measures are in place at the Sigma 3 Shaft area.








implemented at 3 Shaft as part of the 31

Amendment process.











environment.





NC

A spill response plan will be

implemented and employees trained

accordingly to react efficiently to

address any spillage. Large spillages

of hazardous substances such as oil

will initially be controlled by on-site

emergency response personnel, who

will be aided by professional

contractors.

C

Any oil spills that occur on site are contained and

dealt with on a weekly basis in accordance with

the Procedure for the Handling of Oil Spills and Oil

Recycling (Ref No. SIG (EM) IMS SOP/ 008). It

was noted that all oil spillage that occur are

recorded in an incident register (Ref No. Ref No.

SIGIMS/NCREG/1) which is retained at the mine.

Training is provided on effective management and

measures to be implemented in the event of a

spillage. To date no large spillages have occurred

however an Emergency Preparedness and

Response Procedure (Ref No. SIG IMS 447000)

is available should such a spillage occur. It was

noted that miner spillages are immediately

cleaned up when required. No spillages were

noted on the incident register. Training is provided

on environmental aspects during induction.


Any oil spills that occur on site are contained

and dealt with on a weekly basis in

accordance with the Procedure for the

Handling of Oil Spills and Oil Recycling (Ref

No. SIG (EM) IMS SOP/ 008). It was noted

that all oil spillage that occur are recorded in

an incident register (Ref No. Ref No.

SIGIMS/NCREG/1) which is retained at the

mine.

A memorandum in April and May 2019 was

written to address spills on site. An incident

register was also made available that notes

incidents, actions taken and whether

investigations were needed.

C

7

Surface water

(Water Quality)

Hazardous waste will be disposed by

an approved waste contractor to

ensure the safe disposal of the

waste. The associated safe disposal

certificates will be kept in a secure

C


waste generated at Mooikraal and 3 Shaft is

stored in the ISO yards which has designated

waste storage areas, one at Mooikraal and one

at 3 Shaft, which is separated into various waste

streams namely wood waste, scrap metal and

hazardous waste. The hazardous waste is stored

in waste skips and signage indicating the waste

stream is placed above the waste skip. Mooikraal

considers general waste to be hazardous as

general waste is obtained from the underground

workings and anticipated to be contaminated with

hydrocarbons. It was communicated that

hazardous waste is removed by EnviroServ and

disposed at Holfontein. Safe disposal certificates

are provided for the safe disposal of this waste.

During the audit a safe disposal certificate for the

disposal of hazardous waste was provided (Ref

No.GP-SP240100). Good housekeeping

measures are in place. All waste is stored and

handled in accordance with the National

Environmental Management: Waste Act, 2008

(Act 59 of 200rage area. However currently there

is not oil skimmer and water is being pumped out

manually. harged to the Leeuspruit. The proposed

upgrade involves the separation of clean


Mooikraal considers general waste to be

hazardous as all general waste is obtained

from the underground workings and anticipated

to be contaminated with hydrocarbons. It was

communicated that hazardous waste is

removed by EnviroServ and disposed at

Holfontein.

Safe disposal certificates, purchase orders

and invoices were provided.

C

General waste will be separated in

dedicated areas to facilitate the

separation of waste from where it will

be collected for disposal to a

permitted landfill site or recycling.

C



stored at the ISO Yard in designated waste

storage areas, one at Mooikraal and one at 3

Shaft, which is separated into various waste


hazardous waste. The hazardous waste is stored

in waste skips and signage indicating the waste

stream is placed above the waste skip. Mooikraal

considers general waste to be hazardous as all

general waste is obtain from the underground

workings and anticipated to be contaminated with

hydrocarbons and is therefore handled

accordingly. The EAP at Mooikraal ensures that

all waste generated and recycled at the mine is

recorded on a spreadsheet. The spread sheet

was provided to the auditors which showed all

waste generated and recycled between 2016 and

2018. This information is also recorded and

reported on a quarterly basis in the Sasol

Sustainability Report


Mooikraal considers general waste to be

hazardous as all general waste is obtained

from the underground workings and anticipated

to be contaminated with hydrocarbons. It was

communicated that hazardous waste is

removed by EnviroServ and disposed at

Holfontein.

Safe disposal certificates, purchase orders

and invoices were provided.

C

Waste will be separated into the

following categories which allow

recycling: glass, steel, paper,

batteries and woodchips as per

waste procedure (SIGIMS 446002).

C



stored at the ISO yard in designated waste

storage areas, one at Mooikraal and one at 3

Shaft, which is separated into various waste


hazardous waste. The wood waste and scrap

metal is removed from site and taken to Sasol’s

reclamation yard. The wood waste is then sold to

Archorcol who burn the wood to make charcoal

while the steel is sold or auctioned off. Oil waste

is removed off site by EWOR where it is recycled

and reused. The drums that are used to store the

oil is sold to Senno Drums for recycling.


Waste is sorted and separated into various

waste streams namely wood waste, scrap

metal and hazardous waste.

There were no designated areas for glass,

paper and batteries. However, best practice

measures have been put into place regarding

waste separation. Therefore, the intent of

commitment is acheived.

C

7

Surface water

(Water Quality)

The waste areas will contain the

necessary water pollution control

features e.g. bunded, impermeable

surfaces and sump, and separate

demarcated areas for the different

wastes.

C

The waste is stored in the ISO yard in a

designated waste storage areas. These areas

have a concrete surface and dividers have been

established between each waste stream to

ensure separation of waste. At Mooikraal all

waste is disposed in skips depending on the

waste stream. The waste storage area is sloped

to allow water to drain towards a sump area

which collects the water from both the waste

storage area and wash bay. An oil skimmer is

also used to recover the oil from the sump prior to

the water being discharged to the PCDs. It was

observed that the water management around the

waste area is considered to be effective. Clean

runoff water is diverted around the waste storage

area and dirty runoff water will be contained in the

sump.


The waste storage area is bunded and

concreted. Each waste stream is separated

by concrete wall on either side.

C

All bulk storage of substances such

as fuel and oil must be bunded to

contain 110% of the substance

stored. These facilities must include

a sump, an oil trap and an

impermeable floor and walls.

C

Mooikraal Colliery

All fuel and oil is stored in tanks in a designated

fuel and oil storage area. The tanks are bunded to

ensure that should a failure occur it will be able to

contain 150 % of the fuel and oil stored. The

tanks and area where the vehicles are refueled

are located on a concrete floor and within

impermeable walls. Additionally the tanks are

located within a lockable and access control area

with established fencing around it. A sump and oil

trap has been constructed to collect all the water

being discharged from the fuel and oil storage

area. However currently there is not oil skimmer

and water is being pumped out manually.

3 Shaft

A diesel storage facility is located at 3 Shaft

however it is currently not in used as it is will be

decommissioned in the near future





It is recommended that as the diesel storage facility

is not required it should be decommissioned to

concrete level. The oil that may be stored inside the

tank should be drained and the oil contained within

the bunded removed and disposed of as hazardous

waste.

Fuel and hydraulic oil are stored on site in bulk

storage tanks. These tanks are stored within a

bunded area and on a concrete standing. The

oil storage area contains a total of 73 000

litres and has a bund wall capacity to store

150% of the total capacity of the bundwall

which amounts to 113 500 litres.

C

All hazardous substances (such as

paint, flammable substances) will be

stored in a lockable cupboard at all

times.

C

Mooikraal Colliery

All fuel and oil is stored in tanks in a designated

fuel and oil storage area. The tanks are bunded to

ensure that should a failure occur it will be able to

contain 150 % of the fuel and oil stored. The

tanks and area where the vehicles are refueled

are located on a concrete floor and within

impermeable walls. Additionally the tanks are

located within a lockable and access control area

with established fencing around it. A sump and oil

trap has been constructed to collect all the water

being discharged from the fuel and oil storage

area. However currently there is not oil skimmer

and water is being pumped out manually.

3 Shaft

A diesel storage facility is located at 3 Shaft

however it is currently not in used as it is required

to be decommissioned.





It is recommended that as the diesel storage facility

at 3 Shaft is not required it should be

decommissioned with the tank and bund removed.

The oil that may be stored inside the tank and

bunded area should be removed and recycled by

an approved service provider. All the contaminated

concrete or material must be removed as hazardous

waste and appropriately disposed of.

There are lockable storage areas for

hazardous flammable substances such as

Acetylene, Oxygen and LPG Gas.

C

7

Surface water

(Water Quality)

A register with all the Material Safety

Data Sheets (MSDs) of all the

hazardous substances will be

maintained on the mine at the point of

use.

C

MSDs are retained onsite for all hazardous

substances used on the mine. An example of a

Safety Date Sheet was provided for Sasol Diesel

500 which provides measures to be implemented

in the event of an incident. It was also noted that

a chemical registry has been compiled for the

mine with all the MSDS linked to each chemical


Material Safety Data Sheets (MSDS) were

provided for the Oxygen, Acetylene and LPG

Gas.

C

No activities will be allowed within

100m of watercourses.C

Mooikraal received a GN 704 4 (b) exemption

which permits Mooikraal to undermine the

Kromelmboogspruit and feeder streams using

bord and pillar methods. It is required that a

safety factor of 2 is maintained as well as a width

to height ratio of greater than 4. However, it was


permitted within 100 m of a watercourse or

wetlands. The wetlands around Mooikraal have

been delineated in 2014 and a 100 m buffer has

been placed around both wetlands and river on

the mine plans.

It is also noted that 3 Shaft is considered to be

located within 100 m of a water course however

the plant was constructed in 1950 before NWA

was promulgated. It is also noted that it is

proposed that the processing plant at 3 Shaft will

be relocated away from the water course to

reduce 3 Shaft impact on the river.


Mooikraal received a GN R704 4 (b)

exemption which permits Mooikraal to

undermine the Kromelmboogspruit and feeder

streams using bord and pillar methods. It is

required that a safety factor of 2 is maintained

as well as a width to height ratio of greater

than 4. However, it was communicated that no

high extraction mining is permitted within 100

m of a watercourse or wetlands. The wetlands

around Mooikraal have been delineated in

2014 and a 100 m buffer has been placed

around both wetlands and river on the mine

plans.

It is also noted that 3 Shaft is considered to

be located within 100 m of a water course

however the plant was constructed in 1950

before NWA was promulgated. It is also noted

that it is proposed that the processing plant at

3 Shaft will be relocated away from the water

course to reduce 3 Shaft impact on the river.

C

An annual weed eradication

programme will be undertaken

utilising a registered chemical

herbicide contractor.

NC

An alien plant/weed eradication programme is not

implemented on an annual basis. The Mooikraal

Colliery is in the process of developing an


alien invasive species onsite. It was noted that

regular inspections are undertaken by the

Environmental Practitioner at Mooikraal to ensure

the invasive species are removed to prevent the

spread of species. Mooikraal currently spray

herbicides around the conveyer belt and other

problem areas previously identified. During the

site assessment it was observed that invasive

species were present such as Scottish Thistle,

Cockleburs and Pink Tamarisk. It was

communicated that most invasive species have

been established on areas that have been

disturbed and no significant spread of invasive

species have been observed.

It is recommended that the alien plant control

programme attached as Appendix 3 to the EIA

Report is implemented to manage and control the

alien invasive species which are present onsite.

The eradication of invasive species is required by

National Environmental Management Biodiversity

Act (NEMBA) (Act 10 of 2004) – Alien and Invasive

Species (AIS) regulations, 2014 and any plan

drafted in compliance with the legal requirements

must be implemented.

Invasive species must be removed to prevent

spreading to other areas around the site.

Mechanical methods should be used to remove the

invasive species specifically at the time of the year

when the plants are not producing seeds which can

result in the spread of these species to other areas.

The disposal of these species must be removed in

a controlled manner to prevent further spreading.

Proof of training specific to the invasive species

identified on site must be provided either to the

appointed contractor or the person made

responsible for the removal of alien invasive

species.

It has been communicated that the plan for

2020 will be to implement an alien eradication

programme on site. NC

7

Surface water

(Water Quality)

Surface water monitoring will be

implemented to ensure that the water

management systems perform

adequately as discussed in this EMP.

NC

It is noted that biannual ground and surface water

quality monitoring is undertaken to determine

whether the water qualities are in accordance

with the WUL and catchment standards. The most

recent biannual water monitoring report for

Mooikraal dated February 2018 (Ref No.

2018/04/PJHL) was compiled by IGS. This report

is submitted to the DWS on a biannual basis. 3

Shaft is monitored under the Sasol Sigma Colliery

as per their rehabilitation requirements. The most

recent report is dated January 2018 (Ref No.

2018/03/PJHL). The monthly water quality results

for 3 shaft indicated an increase of sulphate

levels over the past eighteen months. It is

however noted that the deteriorating water quality

is not only from 3 Shaft and has other contributing

factors. Additionally it is noted that the water

management system which is described in the

EMP is not a true reflection of what is occurring

onsite and therefore the EMP is required to be

updated.

Since Sasol Sigma is no longer required by law to

monitor its surface, it is anticipated that monitoring

will be reduced around 3 Shaft within the next 3

years. It is recommended that in order to continue

assessing the impact of 3 Shaft on the surface

resources that Mooikraal Colliery expand their

monitoring programme to include 3 Shaft. The

biannual water monitoring report currently being

compiled by IGS must monitor both Mooikraal

Colliery and 3 Shaft.

It was communicated that a BAR / 31 amendment

process is being undertaken to amend the

information currently contained within the EMP and

ensure its relevance to both the Mooikraal and 3

Shaft operation. The update will also include the

implementation of mitigation measure to prevent

continuous flow to the Leeuspruit from 3 Shaft and

ensure the containment of this dirty water.




together and due for review in 2021.

Water monitoring, both surface water and

groundwater, is undertaken on a quarterly

basis. The October 2019 report indicated that

calcium-bicarbonate signature for the

upstream monitoring point and sodium-

bicarbonate signature for the downstream

monitoring point of Kromelmboogspruit North

and South whcih can be attributed to the

release of mine water discharge into the

Kromelmboogspruit t since 2010.

It is however noted that stormwater


implemented at 3 Shaft as part of the

conveyor relocation project which will be

authorised as part of the Regulation 31

Amendment process.

NC

The water balance at Sigma:

Mooikraal operation will be managed

by pumping to SII , from where it is

discharged to the Vaal River as part

of SII's final effluent.

NC

Mooikraal regularly monitors their water flow

which is recorded on a flow spreadsheet and

submitted to DWS. The water is currently pumped

from underground, to the PCDs and then to SO.

It is however noted that at present Mooikraal

Colliery is generated excess water which cannot

be contained within the North and South PCD

which is resulting in overflows. A 10 ML and 7 ML

are proposed to be constructed to transfer the

water to SO for further use. It is also noted that

the Water Balance contained in the IWWMP,

2015 does not include the flow of water at 3

Shaft. The IWWMP for Mooikraal was compiled

in 2015 and is proposed to be updated in 2018 to

ensure relevance to the current operation at

Mooikraal and 3 Shaft. It was observed that water

is currently discharging from 3 Shaft into the

Leeuspruit and that stormwater mitigation

measures currently located in the area is not

considered to be effective. It is considered that

the dirty water areas are not being kept to a

minimum.





The IWWMP is required to be updated on an annual

basis and submitted to the DWS. However, the

IWWMP has not been updated since 2015. Digby

Wells have been appointed to update the IWWMP.

During this update process it is recommended that

the Water Balance should also be updated to reflect

accurate water quantities as well as include 3 shaft

water usages which have been omitted in the 2015

IWWMP .








The pipelines have been constructed and are

operational. The water is being transferred

from Mooikraal to Sasol Operations.

The upgrade of stromwater management

mechanisms at 3Shaft will only be effected

once the Regulation 31 Amendment is

granted.

C

No river diversions are planned for

the operations. Undermining of the

Kromelmboogspruit will be done in

accordance with GN 704

C

No river or streams have been diverted during

any phase of the Mooikraal operations. Mooikraal

received the IWUL, issued 2018 which permits

Mooikraal to undermine the Kromelmboogspruit

and feeder streams using bord and pillar methods.

It is required that a safety factor of 2 is

maintained as well as a width to height ratio of

greater than 4. However, it was communicated

that no high extraction mining is permitted within

100 m of a watercourse or wetlands. The

wetlands around Mooikraal have been delineated

in 2014 and a 100 m buffer has been placed

around both wetlands and river on the mine plans.


No river or streams have been diverted during

any phase of the Mooikraal operations




streams using bord and pillar methods.

C

7

Surface water

(Water Quality)

Mitigate against any impact on

surface water users. Undermining of

watercourses will however be

conducted in accordance with GN

704 and the National Water Act,

1998 (Act 36 of 1998).

C

Mooikraal received a IWUL (c and i) which

permits Mooikraal to undermine the

Kromelmboogspruit and feeder streams using

bord and pillar methods. The was granted in 2018.

It is required that a safety factor of 2 is

maintained as well as a width to height ratio of

greater than 4. However, it was communicated

that no high extraction mining is permitted within

100 m of a watercourse or wetlands. The

wetlands around Mooikraal have been delineated

in 2014 and a 100 m buffer has been placed

around both wetlands and river on the mine plans.





streams using bord and pillar methods.

The wetlands around Mooikraal have been

delineated in 2014 and a 100 m buffer has

been placed around both wetlands and river

on the mine plans.

C

Users of private boreholes affected

by mining operations will be provided

with an alternative supply of potable

water the same or better quality after

an investigation has been done by

Sasol Mining.

C

A complaints registered was provided which

records all complaints that have been made with

the Mooikraal Mine. The register is maintained by

The Sasol Mining Rights Department (SMRD)

(Mooikraal Complaints Register Dated April

2018). It was observed that complaints have

been received however no complaints relating to

any distribution of borehole water utilised by

farmers have been recorded. Should an instance

arise where borehole water has been disrupted or

impacted (quality or quantity), the incident would

be recorded and an investigation undertaken to

determine whether the mine was responsible for

the impact. If it is found that mining activities had

affected the surrounding landowner’s boreholes,

water of a similar quality and volume shall be

supplied to them by Mooikraal, this in accordance

with SMRD PROC 004. Mooikraal currently does

not provide farmers with water.


On the day of the site visit, the Environmental

Manager was attending to a borehole issue

with an I&AP.

A complaints register is available at Mooikraal.

When a complaint is issued, the complaint

would be placed under investigation. The

complaint is assigned a person competen to

deal with the issue. The remedial measures to

be implemented are noted and progress is

given on the matter.

C

Excess mine water is pumped to

surface and either recycled, re-used

for dust suppression, etc. or

abstracted for treatment

C

Groundwater flows into the underground workings

at Mooikraal Colliery. These workings must be

kept dry for health and safety as well as

production reasons. The water is then pumped to

the South PCD which overflows to the North

PCDs. The water contained in the PCDs is then

pumped away from the dam through a 5ML

pipeline to SO for disposal. The water that is

contained in the PCD at 3 Shaft is also

authorised to be utilised for dust suppression

along the conveyor belt and at the processing

plant. Water is not pumped back underground.

Water stored in the dams underground is used for

dust suppression. It was also communicated that

Dust–A-Side is utilised along roads underground

to prevent the generation of dust.


Water from underground is pumped into the

South PCD which then flows into the North

PCD. The water is then transferred to the

Sasol Operations and to 3Shaft for dust

suppression measures.

C

7

Surface water

(Water Quality)

8 Groundwater

The objective of groundwater

management will be to restrict the

impact of polluted groundwater to the

mining area and the adverse impacts

on groundwater will be further

reduced by implementing the

mitigatory measures and

management programme of the

below listed.

The groundwater boreholes should be

monitored to ensure that seepage is

detected before it becomes an issue.

NC

IGS is responsible for biannual ground and

surface water monitoring to determine whether

the water qualities and quantities are in

accordance with the WUL and catchment

standards. The most recent biannual water

monitoring report dated February 2018 (Ref No.

2018/04/PJHL) compiled by IGS. This report is

submitted to the DWS on a biannual basis. The

report indicated that Nitrate exceeded the limit for

the prescribed water quality objectives in

borehole MK004 at Mooikraal. All the other

constituents are well within the prescribed limits.

No groundwater monitoring of 3 Shaft is currently

being undertaken. The coal handling plant as well

as coal stockpiling can result in groundwater

contamination and therefore this needs to be

monitored

No groundwater monitoring of 3 Shaft is currently

being undertaken. Monitoring boreholes are

proposed to be drilled around 3 Shaft and

incorporated into the groundwater monitoring

programme for Mooikraal. Once the boreholes are

drilled Mooikraal must ensure that quarterly

monitoring is undertaken for each borehole.

Water monitoring by IGS is being conducted.

The August 2019 report indicated monitoring

of various boreholes and exceedances were

identified and the quality of the groundwater

was discussed to be affected by either the

geology of the area, tailings at the Waste Ash

Site at Sasol 1, 3 Shaft coal stockpile,

fertiliser on cultivated land and the borehole

assessed being near it and the proximity of a

borehole to explosives used for blasting

underground.

Therefore, boreholes have been drilled and

are being monitored quarterly as

recommended in the 2018 audit.

C

Applications of a chemical binder

(ligno-sulphonate,

calcium/magnesium chloride or

bituminous products) to roads to

develop a crust, coupled to watering

and sweeping to eliminate dust

mobilisation from this source.

C

The roads utilised underground are sprayed with

Dust–A-Side which is a chemical binder. The

Dust–A-Side assists with preventing the

generation of dust. The Dust–A-Side is spray on

the surface with a watering truck. Dust monitoring

on a monthly basis.


Dust-A-Side is used for the roads underground

and at 3Shaft, there is Dust-A-Side used along

the access road near the water guns.

C

Constant watering (with water trucks)

in areas where material removal,

placement or manipulation is

occurring

NC

Dust suppression mechanisms are being

undertaken at the mine and include the spraying

of coal at the transfer stations of the conveyor

belt. Dust suppression is also undertaken at the

crushing and screening plant. This assists with

preventing spontaneous combustion as well as to

prevent the generation of coal dust. Dust-A-Side

is also utilised underground to reduce the

generation of dust.

A dust monitoring programme has been

implemented at Mooikraal and 3 shaft where dust

buckets have been positioned in all major and

secondary wind directions. These dust buckets

are monitored on a monthly basis by Gondwana.

Dust results were provided for the months of

August 2012 to May 2018. The results indicated

that the levels of dust did exceed the specified

limits associated with residential levels and in

some months industrial levels as per the National

Dust Fallout Regulations. Dust is considered to

be an issue at 3 Shaft due to the handling of coal.

A number of complaints have also been raised

regarding the generation of dust around the

conveyer belt and 3 Shaft (Refer to Complaints

register, 2018).

As the dust mitigation measures implemented at the

mine were found to be inadequate. An air quality


assess the impact of dust fall-out on the

surrounding community and to recommend

measures to reduce the impacts around 3 Shaft and

the Mooikraal Colliery. The mitigation measures

proposed from this specialist study must be

implemented to ensure dust levels are reduced and

are brought in compliance with air quality legislation.

Dust suppression measures have been put

into place at Sigma Colliery: 3 Shaft in the

form of fogger cannons. This was put in place

to address dust fall-out impacts to the

surrounding community.

The dust monitoring report compiled by

Godnwana Environmental Solutions in October

2019 states that during the period of

monitoring, 2019-09-30/2019-10-31 there

were no exceedances for non-residential

standards.

The Mooikraal Opertaions are classified as

non-residential. Therefore, based on the

lastes report provided to Digby Wells, this

condition is met.

C

Rehabilitating areas as soon as

practically possible,NA

The coal handling area at 3 Shaft is still being

utilised. This area will only be decommissioned

once MK is decommissioned and or closed.No further action required







NA

9 Air Quality

To ensure that the dust impacts do

not exceed guideline levels as a

result of the mining activities.

8 Groundwater

The objective of groundwater

management will be to restrict the

impact of polluted groundwater to the

mining area and the adverse impacts

on groundwater will be further

reduced by implementing the

mitigatory measures and

management programme of the

below listed.

Applying dust control measures to

roads to achieve maximum dust

control efficiency

C

Dust along roads underground that are not paved

is controlled through the spraying of Dust–A-Side

with watering trucks . Dust suppression on the

surface is undertaken at the coal transfer stations

on the conveyor belt. No significant generation of

dust from the use of roads has been noted.





C

Ensuring that dust control measures

at transfer points are in place and

operate efficiently

C

Dust suppression mechanisms are being

undertaken at the mine and include the spraying

of coal at the transfer stations of the conveyor

belt.

Dust suppression is also undertaken at the

crushing and screening plant. This assists with

preventing spontaneous combustion as well as to

prevent the generation of coal dust.

Dust-A-Side is also utilised underground to reduce

the generation of dust.





The pressure of the water guns at 3Shaft need

to be checked.

C

Where practically possible to

construct berms, plant tree

screens/windbreaks

C

Berms have been constructed around the incline

shaft and PCD this assist in both screening and

water management. Trees are planted on an

annual basis in August during Arbour day. Only

indigenous vegetation is planted.


Berms have been constructed around the

incline shaft and PCD this assist in both

screening and water management. Trees are

planted on an annual basis in August during

Arbour day. Only indigenous vegetation is

planted.

C

Implement specific noise prevention

measures such as disabling audible

reverse warning devices and

replacing these with visual warning

devices on all and new equipment,

the proper silencing of all diesel

equipment, the regular and

systematic maintenance of

equipment and the continuous

training of personnel in order to

promote operational procedures

NC

It was noted that the Mooikraal Colliery is not

considered to be noisy as only underground

mining is being undertaken. Additionally the

nearest receptor is considered to be far away

from the mining operation and would not be

considered to be impacted upon by noise. All

equipment is also put onto planned maintenance

to ensure that it is operated optimally.

Although the ventilation shaft is quiet noisy there

are no close receptors to the ventilation shaft. It

is noted however that should any noisy activity be

planned to be undertaken at the mine, adjacent

land owners will be notified. No noise complaints

for Mooikraal have been received for 2017 and

2018 (Sasol Mining External Complaints Register

April 2018).

It was however noted that issues regarding noise

generated at 3 Shaft by the crushing and

screening plant has been received from the

community and reported to the mine however this

has not been captured on the complaints register.

A noise specialist study is currently being

undertaken to address the issue of noise and

implement measures to reduce these impacts to

the surrounding community

It is recommended that once the ambient noise

specialist study has been completed and mitigation

measures have been proposed, these measures

must be implemented to reduce the generation of

noise at the shaft. Additionally, noise monitoring

may need to be implemented to ensure the noise

currently being generated at 3 Shaft is reduced.

As per the Complaints register, the Sigma

Complex only has complaints for subsidence,

leaks and rehabilitation.

No noise complaints were placed on record

about the machinery at the Sigma Coliery: 3

Shaft and Sigma Colliery: Mooikrall since is an

undergound mine, it is not considered noisy.

C

10 Noise

To ensure that measures are

implemented to reduce the disturbing

noise.

9 Air Quality

To ensure that the dust impacts do

not exceed guideline levels as a

result of the mining activities.

Conduct noise measurements on all

new equipment to establish a

reference data-base and follow up

with regular noise audits to ensure

the early detection of deviations

which could lead to complaints

C

Continuous maintenance on vehicles is

undertaken to ensure the machines function

optimally and do not produce excessive noise.

Additionally when vehicles are brought onto site,

the vehicles are monitored in terms of

occupational health and safety to ensure the

noise levels do no exceed noise standards. It

was communicated that no additionally silencers

are added to the vehicles to reduce noise as

these are generally standard on these types of

machines. It was also communicated that when

new infrastructure begins operating such as the

operation of a new ventilation shaft, ambient

noise monitoring is undertaken to ensure the

infrastructure does not generate excessive noise.


No noise monitoring and audits are conducted

ar Mooikraal.

Noise monitoring and audits need to be

undertaken at Mooikraal.

NC

Conduct ambient noise monitoring at

regular intervals in order to detect

possible deviations from predicted

and accepted noise impact levels.

Analyse and take corrective action

NC

It was noted that the Mooikraal Colliery is not

considered to be noisy as only underground

mining is being undertaken. Additionally the

nearest receptor is considered to be far away

from the mining operation and would not be

considered to be impacted upon by noise.

Additionally although the ventilation shaft is quiet

noisy there are no close receptors to the

ventilation shaft. It is noted however that should a

noisy activities be planned to be undertaken at

the mine, adjacent land owners will be notified. No

noise complaints for Mooikraal have been

received for 2017 and 2018 (Sasol Mining

External Complaints Register April 2018). It was

however noted that issues regarding noise

generated by the crushing and screening plant

has been received but not documented. No

baseline noise assessment has been completed

for the Mooikraal operation and 3 Shaft in order to

provide substantial evidence that the noise levels

are below legal noise standards. A noise


address the of noise and implement measures to

reduce these impacts to the surrounding

community not di

It is recommended that once the ambient noise

specialist study has been completed and mitigation

measures have been proposed, these measures

must be implemented to reduce the generation of

noise at the shaft. Additionally, noise monitoring

may need to be implemented to ensure the noise

currently being generated at 3 Shaft is reduced.

It was advised by the Environmental Officer

that no noise report were available, besides

the baseline that was conducted for the

Regulaton 31 Amendment and WUL

application.

Noise complaints were not identified in the

complaints register. However, as a

commitment of the EMPR, there needs to be

monitoring conducted. Theefore, because

these are not taking place, the condition is

found non-compliant.

NC

No “high noise” operations should

take place on or above ground level

at night

C

The mine operates as a 24 hour mine however it

was noted that excessive noisy activities which is

undertaken occasionally is limited to day light

hours such as blasting. No noise complaints for

Mooikraal have been received for 2017 and 2018

(Sasol Mining External Complaints Register April

2018). It was however noted that issues

regarding noise generated by the crushing and

screening plant has been received but not

documented.


The mine operates as a 24 hour mine

however it was noted that excessive noisy

activities which is undertaken occasionally is

limited to day light hours such as blasting.

C

10 Noise



noise.

If all management actions fail to

address the impact, BATNEEC-

engineering practices will have to put

in place e.g. the construction of a

noise barrier, etc.

NA

On completion of the noise specialist study,

mitigation measures will be proposed to reduce

the noise being generated from the operation.

These mitigation measures may invoice the

construction of berms where applicable.


It was advised by the Environmental Officer

that no noise report were available, besides

the baseline that was conducted for the

Regulaton 31 Amendment and WUL

application.

Upon approval of the Regulation 31

Amendment, the noise baseline can be used

as a starting point.

C

The shaft, conveyor, overburden

dump and plant (at 3 Shaft) will be

vegetated and rehabilitated

C


the areas around the Mooikraal shaft, Kleinvlei

Ventilation Shaft, 3 Shaft, borrow pit and

overburden dump were vegetated. The

vegetation was allowed to be established

naturally and it was observed that no significant

alien invasive species occurred. It is noted that

as the mine is an underground mine, minimal

rehabilitation activities are undertaken at the

facility.








NA

The infrastructure will be demolished

and removed in consultation with the

authorities.

NA













unnecessary environmental impact. Additionally a

re-vegetation programme will be implemented to

ensure indigenous vegetation is utilised during

rehabilitation. Additionally alien invasive species

monitoring will be undertaken on the newly

rehabilitated areas so as to prevent the spread of

invasive species.




No communications have been received from

the authorities in relation to the demolision of

infrastructure.

NA

The lighting of the plant and shaft

areas will be designed in such a way

as to reduce illumination at night.

C


lighting is utilised to illuminate the operation.

These lights are pointed towards the ground to

ensure light is direct on the mine and not into the

surrounding properties.


Lights are pointed towards the ground to

ensure light is direct on the mine and not into

the surrounding properties.

C

High mast lights will be designed in

such a way that they shine on the

plant and mine infrastructure only.

C


high mast lights are utilised to illuminate the

operation. These lights are pointed towards the

ground to ensure light is direct on the mine and

not into the surrounding properties.


Lights are pointed towards the ground to

ensure light is direct on the mine and not into

the surrounding properties.

C

Rehabilitate all disturbed areas as

soon as is practicably possibleNA






undertaken. No visual complaints have been

received (Complaints register, 2018). Berms have

been constructed around the incline shaft and

PCD to reduce the visual impact associated with

the mine.



Mooikraal's end of LoM. NA

10 Noise



noise.

11 Aesthetics

To minimise the visual impact of

mining operations as much as

possible.

Introduce flora to soften and screen

buildings and structuresC

It was communicated that limited flora is found

onsite as it is currently a fully operational mine.

Indigenous trees have been planted around the

mine. Limited visual receptors are located in

close proximity to the mine therefore the visual

impact of the mine to the adjacent land owners is

considered to be minimal.


Limited flora is found onsite as it is currently

a fully operational mine. Indigenous trees have

been planted around the mine. Limited visual

receptors are located in close proximity to the

mine therefore the visual impact of the mine to

the adjacent land owners is considered to be

minimal.

C

Planting of indigenous trees around

structures, buildings, etc; and

maintaining of the area around

infrastructure and keep it neat

C

During the site assessment it was communicated

that only indigenous trees were planted and it was

found that the mine was will kept.


Limited flora is found onsite as it is currently

a fully operational mine. Indigenous trees have

been planted around the mine

C

12Interested and

Affected Parties

To minimise the negative impacts of

the closing down of the underground

operations and resulted loss of

employment.

Sasol Mining Rights and Property

Department (SMRD) gives feedback

to all I &APs on complaints received

and the implementation of corrective

actions taken as committed in the

ISO14001 EMS

C

A complaints registered was provided which

records all complaints that have been made with

the Mooikraal Mine. The register is maintained by

the SMRD (Mooikraal Complaints Register Dated

April 2018). It was noted that complaints have

been received to date such as dust compliments,

spillages, dumping of waste and veld fires. These

complaints have been investigated to determine

whether Mooikraal is responsible for the

complaint. Should the compliant be found to be

valid, measures are undertaken in accordance

with SMRD PROC 004 to resolve the issue and

close out the complaint. It was noted that only

one compliant was found to be unresolved to date

which was raised in June 2018 with regards to

damage of grazing land from cement being

deposited on it. Sasol must undertake an

investigation to determine whether Sasol were

responsible for the incident and implement

measure if found to be responsible. All incidents

and non-conformances are thoroughly

investigated as part of ISO 14001: 2015 element

4.5.3, procedure Sn of dust arou


The Sasol Mines Complaints register was

provided which had 25 complaints logged from

February 2019 to November 2019.

Only 1 of the 25 complaints has been resoled

as per the compliants register. It is

recommended that complaints be addressed

at a more expediant manner to avoid

complaints running over the next year.

C

The main structures requiring

maintenance are:

■ Stormwater diversion

channels/berms

■ Stormwater conveyance

channels

■ Sumps

■ Trenches

■ Pollution control dams

■ Surface dams

All of the above facilities will be

maintained according to general

accepted engineering practices and

in accordance with the requirements

of the National Water Act, 1998 (Act

36 of 1998) and will be inspected

visually at least once a week.

Estimations of the costs of measures

to comply with statutory obligations

will be determined by suitably

qualified persons within ninety days

before the end of each financial year.


No further action required13

Maintenance of

water pollution

structures

C

Weekly inspections are undertaken at the mine by

the Environmental Practitioner. It was noted that

the sump is regularly cleaned out by EnviroServe

to remove the sludge that is generated form the

operation which was noted through inspection list

completed by the responsible person for that

area. Additionally inspections of the stormwater

management specifically the trenches and berms

are undertaken in September prior to the first

heavy rainfall event. Should an issue be identified

maintenance will be undertaken to ensure the

structures are able to contain a 1:50 year flood

event. Additionally Inspections are typically

conducted after each major rainfall event, to

determine whether any damage has occurred to

the stormwater management infrastructure.

Stormwater management infrastructure are

inspected in summer months on a monthly and in

winter months every 2 months.

14Financial

ProvisionC

11 Aesthetics

To minimise the visual impact of

mining operations as much as

possible.

Sasol Mining calculated the financial provision

for the various Sasol mines in 2019 which

was completed by Jones and Wagener (Ref

No. JW047/15/E473 - Rev 4). The FP for the

Mooikraal Opertaions is at a total of R 120

293 927.19 as of March 2019.

C

As found in the 2019 WUL Audit, berms are

used to prevent clean water from entering the

incline shaft and divert the water around the

shaft area. All contaminated stormwater from

the wash bay, parking areas and bulk storage

areas at the Mooikraal Shaft is contained to

the dirty water system which comprises a

network of sumps and silt traps which

overflows into the PCD. From the North PCD

this water is pumped to the 3 Shaft for dust

suppression or the SO as part of their water

system.

C

Contribution towards the estimated

costs of measures shall be made by

Sasol Mining before the end of the

financial year.

The shortfall between the estimated

costs of measures and the credit of a

beneficiaries account shall be made

good by Sasol Mining.

The above shortfall could arise at

termination of mining operations

and/or liquidation before the required

financial provision in terms of the

above formula has been made

No further action required14Financial

ProvisionC

Sasol Mining calculated the financial provision

for the various Sasol mines in 2019 which

was completed by Jones and Wagener (Ref

No. JW047/15/E473 - Rev 4). The FP for the

Mooikraal Opertaions is at a total of R 120

293 927.19 as of March 2019.

C

Documents

Sigma Colliery: Mooikraal and 3 Shaft Environmental Audit...2020/01/29 · Digby Wells Environmental (hereafter “Digby Wells”) was appointed by Sasol Mining (Pty) Ltd to undertake