7.10 Three-year project to fast track environmental management plans in South Africa
The environmental management department attached to the South African operations has been tasked with fast tracking some of the major environmental remediation initiatives identified by the group over the next three years. Says project manager, Tony Da Cruz, "When pressures mount to reduce the funding requirements, particularly during periods in which the margins are being squeezed, inevitably the environmental components of the operational budget are cut because they are deemed non-essential to production. The role of the Environmental Management Department is to ensure that the appropriate levels of resources are applied to meet the environmental commitments of the South Africa region in a timely manner and to ensure legal compliance at all times."
Historically, the South African operations were required to compile detailed Environmental Management Programme Reports (EMPR) as prescribed by the Minerals Act, Act No 50 of 1991 and to file these for approval by the Department of Minerals and Energy (DME). Based on this, and other factors, the operation would then receive - or have renewed - its mining authorisation. The South Africa region has 26 DME-approved EMPRs to which it is committed, not only until the cessation of operations but until a closure certificate is issued by the DME. This authorisation effectively gives it the right to operate. The Environmental Management Plan (EMP) that forms part of the EMPR is legally binding and regular reviews must be undertaken to monitor compliance with the EMP.
The status and role of the EMPR were reinforced when the Mineral and Petroleum Resources Development Act, No 28 of 2002 (MPRDA), was enacted on 1 May 2004. This legislation requires the application for conversion of 'old order' to 'new order' mining rights. The company's performance and plans in terms of a range of socio-economic and development issues, including environmental compliance according to the approved EMPRs, will determine whether this conversion is achieved.
An important part of the current conversion process has been the submission of 'compliance reports' for each EMPR. While the commitments made in terms of the EMPRs have always been important, they have now become even more significant. In accordance with Regulation 55 of the MPRDA, every two years a company must submit performance assessments indicating progress in implementing the EMPR. Whilst this is no different from past requirements, it is evident that this will now be increasingly stringently monitored.
To meet these requirements, the environmental management department is now working far more closely with the business units than in the past to ensure delivery in line with the EMPRs. Says Tony, "While funding for the various projects is applied for and obtained on behalf of the business unit, the responsibility lies with the business unit to project manage the work to completion and a project manager is usually assigned to all major projects. The environmental management department provides a governance role in respect of the allocation of funds. The department needs to sign off on all orders and invoices associated with the projects, provide specialist environmental input and perspectives where needed and guarantee the funds are spent on bona fide environmental requirements (as opposed to spending them on other priorities)."
The South Africa region environmental management department, which employs 31 permanent and contract staff members, including environmental specialists and support staff, provides the skills and resources base to prioritise, plan and monitor these projects.
Environmental remediation projects in South Africa include:
- monitoring boreholes at TauTona;
- construction of oil and grease separation systems at the TauTona workshops;
- construction of a decontamination bay at Savuka;
- lining the pollution control dam at the Mponeng plant;
- concreting the area next to the CIP tanks at the Kopanang plant;
- stripping and stockpiling topsoil ahead of rockdump advance at Moab Khotsong;
- remediation of hydrocarbon spillages at Tau Lekoa;
- new repair and salvage bay at Great Noligwa; and
- construction of oil and chemical storage area at Great Noligwa.