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Commencement with the construction of culvert upgrade works and sewer pipeline crossing through a watercourse - Eskom Holdings (SOC) Ltd Ingula Pump Storage Scheme

(DEAREFERENCE NO.14/12/16/3/3/1/1019)

TECHNICAL DOCUMENT IN SUPPORT OF THE

BASIC ASSESSMENT REPORT

SEPTEMBER 2013

Table of Contents

1.INTRODUCTION

1.1BACKGROUND

1.2PROPOSED ACTIVITY DESCRIPTION

1.2.1INLET STRUCTURE IMPROVEMENT (DEVILS CULVERT)

1.2.2SEWER PIPELINE CROSSING

1.2.3ACCESS ROAD CULVERT

2.LEGISLATION CONSIDERATION

2.1LOCALITY DESCRIPTION AND MAP

2.1.1BIOPHYSICAL ENVIRONMENT DESCRIPTION

3.DETAILS OF PUBLIC PARTICIPATION PROCESS

3.1INTERESTED AND AFFECTED PARTIES COMMENTS

3.2SUMMARY OF ISSUES RAISED

4.NEED AND DESIRABILITY MOTIVATION

5.ASSESSMENT OF ALTERNATIVES

5.1MOTIVATION FOR ALTERNATIVE ASSESSMENT EXEMPTION

6.IMPACT ASSESSMENT

6.1IMPACT SIGNIFICANCE RATING SYSTEM

6.2POTENTIAL IMPACTS DURING THE CONSTRUCTION PHASE

6.3DESCRIPTION OF PROJECT RELATED ACTIVITIES AND ASPECTS

7.ENVIRONMENTAL MANAGEMENT PROGRAM

7.1FRAMEWORK FOR COMPLIANCE AND AUDIT

1.introduction

1.1background

This technical document is in support of Eskoms’ Ingula Pumped Storage Scheme Basic Impact Assessment Application, which was submitted in accordance with the provisions of the National Environmental Management Act, 1998 (Act No. 107 of 1998) Environmental Impact Assessment Regulations, R544 listing notice 1 as corrected, December 2010.

The application for environmental authorization is for the commencement with the following activities:

  • Remedial work and improvement of the inlet structure of an access road culvert, within a water course (Devils culvert);
  • Installation of a new sewer pipeline across a stream to link to the existing bulk sewer main and the Sewage Treatment Works; and
  • The construction of an internal link access road with a stream crossing (culvert) to the existing primary Water Treatment works.

Figure 1: General layout of the project area

1.2PROPOSED ACTIVITY DESCRIPTION

1.2.1Inlet structure improvement (Devils culvert)

The inlet structure of a road culvert to be improved is located on an access road that has already obtained environmental authorization. The Braamhoekspruit River flows through the inlet structure and is bounded by a channeled valley bottom wetland.

A drain through the centre of the wetland modified its hydrology and dried out some parts of it.As a result, an erosion headcuthas formed on the wetland leading to a higher, more erosive water velocity. Rehabilitation intervention was initiated and was aimed at restoring the wetland’s original hydrology. Gabion structures and earth works were used to deactivate the headcuts and prevent their migration upstream, trap sediment to prevent sedimentation of the wetland, and raise the water table in the drained area.This was done so that during peak flows, water will be able to flow more evenly throughout the wetland. However, this area has experienced a migration of the headcut erosion in spite of the establishment of the gabion structure.

In response to this head-cut erosion, the Ingula site now intends to change the design of the inlet structure. The proposed structure consists of a more stable concrete slab, which is engineered in such a way that peak flows will be accommodated and will not result to further erosion of the site.

1.2.2Sewer pipeline crossing

Part of the infrastructure at the Ingula project site includes an administration office, which is still under construction. A waste water treatment plant that will service this administration office is located on the southern side. An unnamed stream runs in between these two facilities. The treatment plant and its infrastructure already have an environmental authorization. The current application is for the proposed sewer pipeline crossing which extends from the administration office tolink to the existing sewer pipeline.

The stream crossing method with the least and short term environmental impacts will be used in the construction process. In addition, measures will be implemented that will be aimed at reducing siltation and erosion. This includes but limited to vegetative buffer strips, drainage diversion structures and sediment barriers. After construction, the impacted area will be restored and re-vegetated to reduce the potential for erosion of the stream bank.

1.2.3Access road culvert

An internal link access road with a stream crossing (culvert) to the existing primary Water Treatment works was constructed on site. The road is shorter than 1000m in length and is less than 8m in width, therefore, it does not require an environmental authorisation. The culvert construction however, requires authorisation as it entails removal of some material from the streambed during the construction phase.

2.LEGISLATION CONSIDERATION

The approach to the application for authorization and motivation for exemption has been guided by the applicable legislation and by the requirements of the NEMA EIA Regulations (2010) which stipulate the procedural aspects of the various levels of an EIA (i.e. Basic Assessments and Full Scoping and EIA processes). Given that the proposed development is listed in R544 of the listed activities promulgated in terms of the NEMA, Act 59 of 2008; a Basic Assessment process will be undertaken.

The R544 Notice listing 1 activities associated with this application include the following:

  • Activity 11 (iii) – The constriction of bridges where such construction occurs within a watercourse or within 32m of a watercourse, measured from the edge of the watercourse, excluding where such construction will occur behind the development setback line.
  • Activity 18 (i) – The deposition or infilling of any material of more than 5 cubic meters into, or the dredging, excavation, removal, or moving of soil, sand, shells grit, pebbles, or rock from a watercourse, but excluding where such infilling, depositing, dredging, excavation, removal or moving (i) is for maintenance purposes undertaken in accordance with a management plan agreed to by the relevant environmental authority; or (ii) occurs behind the development setback line.
  • Activity 39 (iii) – The expansion of bridges within a watercourse or within 32 meters of a watercourse, measured from the edge of the watercourse where such expansion will result in an increase in development footprint but excluding where such expansion occur behind the development setback line.

3.PUBLIC PARTICIPATION PROCESS EXEMPTION

The Minimum requirements for undertaking the public participation process in terms of Regulation R543 include the following:—

a)Conduct at least a public participation process as set out in regulation 54;

b)Open and maintain a register of all interested and affected parties in respect of the application in accordance with regulation 55;

c)Consider all comments and representations received from interested and affected parties following the public participation process conducted in terms of paragraph (a), and subject the proposed application to basic assessment;

d)Prepare a basic assessment report in accordance with regulation 22; and

e)Give all registered interested and affected parties an opportunity to comment on the basic assessment report in accordance with regulation 56.

3.1EXEMPTION MOTIVATION

Application for exemption from undertaking the full public participation process is based on the following facts about the site:

  • Although these are new, the proposed activities applied for will be taking place within the existing construction footprint of the Ingula Pumped Storage Scheme under construction, for which various existing EA’s are in place.
  • The last two EIA/BAR applications submitted to the DEA was for the construction of the lower Braamhoek bridge and the expansion of the Sewerage Treatment Plant, where full Public Participation processes were conducted (in accordance to section 27 (a) to (d) and 54 of GNR 543). No comments were received as a result (records are available).
  • The proposed construction activities will take place within the applicant’s property acquired for construction of the Ingula Pumped Storage Scheme, by Eskom.
  • One of the proposed activities (remediation of the inlet structure on an existing culvert) is initiated to address a complaint from the adjacent landowner.
  • All I&AP are known to the applicant and can be easily contacted via existing I & AP database.
  • The construction activity will take place in the tributary of the Kilp River that has existing ecological monitoring system in place to monitor impacts.

3.2PROPOSED SECTIONS OF PUBLIC PARTICIPATION PROCESS TO BE UNDERTAKEN

  • Exemption from compiling a new Interested and affected parties database

Ingula has an existing stakeholder database which includes the adjacent landowners, the Municipalities, and the representative Councillors. It is proposed that an existing register is used in support of the current application.

  • Exemption from Advertisement in local and national newspaper

A notification containing the Background Information Document (BID) and stakeholder notification letter will be emailed to all the relevant I&APs on the existing Ingula stakeholder databases and/or hand-delivered to landowners who do not have access to email.

  • Exemption from full Public comment timeframe

Relevant I & AP’s will be given 10 calendar days to comment on the draft Basic Assessment Report. It is motivated that 10 days is a reasonable period for I&APs to comment on the draft Basic Assessment Report. All interested and affected parties who are on the current database will be notified of the draft report’s availability and given opportunity to comment.

4.assessment of alternatives EXEMPTION

Motivation for exemption from assessing alternatives was submitted to the DEA in accordance to section 24(4)(b)(i) of the Act and motivation provided, as contemplated in subregulation 22(2)(h).

Due to the nature of this project there is no possibility for any alternative site to be assessed because: -

  • The main purpose for the construction of an internal link road and culvert is to service a permanent potable water treatment plant located across the watercourse.
  • Devils culvert is not a new activity but rather an upgrade of an existing culvert. The remedial work on the inlet is based on a complaint received from the adjacent landowner, which Eskom intends to address through the proposed activity.
  • The sewer pipeline from the Visitors Centre and Administration Building needs to link to the existing bulk sewer main and SWT located across the ephemeral stream. Any alternative alignment of the bulk sewer main will therefore cross the stream, although the proposed alignment allows for gravity feeding.

4.1No-Go alternative

The connection of the Sewer pipeline from the administration and visitors centre is critical for the operation of this facility. Without this link there is risk of contaminating the surrounding water resources by releasing untreated effluent into the environment. Thus it is critical that this infrastructure be put in place so that effluent will be channelled towards the effluent treatment plant that is on site.

The main purpose for the construction of an internal link road and culvert is to service a permanent potable water treatment plant located across the watercourse. The road is already in existence and it has been identified that the current culvert is impeding the flow of water during wet season when the flow is high and is gradually being washed away. The link road is important to the operation of the facility because it provides access to the portable water treatment plant. Without this culvert it will be difficult to provide treatment chemicals and the general maintenance of the treatment plant. This will affect the water supply for personnel working on the scheme.

The inlet structure of a road culvert is an upgrade of an existing culvert. The existing culvert is failing and this leading to a higher, more erosive water velocity and head cutting of the Braamhoekspruit River. Rehabilitation intervention was initiated and is aimed at restoring the wetland’s original hydrology. If this upgrade is not done there will be further head cutting and erosion.

Thus the no go option cannot be supported.

5.Impact assessment

This section identifies potential environmental and socio-economic impacts of the proposed culvert upgrade works and sewer pipeline construction across a water resource. This section has been compiled based on a site visit, information provided by Eskom i.e. correspondence with the various Departments, the original Environmental Impact Report, Record of Decision and the EMS policies.

5.1Impact Significance Rating System

The potential significance of every environmental impact identified has been determined using the significance rating system described below. The terminology has been taken from the Guideline Documentation on EIA Regulations, of the Department of Environmental Affairs and Tourism (DEAT), April1998 guidelines.

Determining environmental significance:

Significance of environmental impact = Consequence X Probability

The consequence of an impact can be derived from the following factors:

  • Severity / magnitude
  • Reversibility
  • Duration of impact
  • Spatial extent

The severity of an impact relates to how severe the impact will be. The reversibility of the impact refers to the ability of the site to recover after an impact has occurred. Duration is defined by how long the impact may be prevalent and spatial extent is the physical area, which could be affected by an impact.

Table 1: Consequences and probability rating

SEVERITY / MAGNITUDE / REVERSIBILITY / DURATION / SPATIAL EXTENT / PROBABILITY
5 – Very high / don’t know / 1 – Reversible (regenerates naturally) / 5 – Permanent / 5 – International / 5 – Definite / don’t know
4 – High / 4 – Long term (impact ceases after operational life) / 4 – National
3 – Moderate / 3 – Recoverable (needs human input) / 3 – Medium term
(5 – 15 years) / 3 – Regional / 3 – Likely
2 – Low / 2 – Short term
(2 – 5 years) / 2 – Local / 2 – Possible but unlikely
1 – Minor / 5 – Irreversible / 1 – Immediate (several months) / 1 – Site only / 1 – Negligible

The maximum value which can be obtained is 100 significance points. Environmental impacts have been rated as High, Moderate or Low significance by combining the consequence of the impact and the probability of occurrence:

Significance = Consequence (severity + reversibility + duration + spatial scale) X Probability

The significance has been characterised as follows:

  • More than 60 significance points indicate High environmental significance
  • Between 30 and 60 significance points indicate Moderate environmental significance
  • Less than 30 significance points indicate Low environmental significance

5.2Potential impacts during the construction phase

Potential impacts that may occur during the construction phase are listed in the table below.

Impacts evaluated during the construction phase will have an impact of LOW significance with the exception of the loss of soil due to erosion which will have an impact with a MODERATE significance. A conservative approach was adopted to evaluate the impacts. A high severity was allocated to those impacts that when it occurs it will have a high severity. The impacts will be of a short duration because the construction phase will be only two weeks. Eskom has also implemented a certified ISO 14001 Environmental Management System (EMS), which means that when an incident occurs it would be addressed immediately according to the necessary policies and procedures.

Furthermore the impacts will be confined to site should it occur because of the site layout. The probability that these impacts would occur was possible but unlikely or likely due to the location where the construction would take place. Impacts such as aesthetic impacts or on archaeological were taken into consideration for completeness. The probability of the impact occurring were low because these are already existing sites and therefore the impacts would have been addressed in the original EIA.

Table 2: Potential impacts that may occur during construction phase
Potential impact / Severity / Reversibility / Duration / Extent / Probability / Significance
Contamination of surface water due to polluted runoff / High / Reversible / Immediate / Site only / Likely / LOW
Contamination of soils due to hydrocarbon spillages / High / Reversible / Immediate / Site only / Likely / LOW
Loss of soil due to soil erosion / High / Recoverable / Short term / Site only / Likely / MODERATE
Loss in and/or disturbance of vegetation when activities move outside the existing footprint / Moderate / Reversible / Immediate / Site only / Possible but unlikely / LOW
Disturbance of fauna i.e. habitat / Moderate / Reversible / Immediate / Site only / Possible but unlikely / LOW
Aesthetic impact / Low / Recoverable / Medium / Site only / Possible but unlikely / LOW
Damages to archeologically sites / High / Irreversible / Permanent / Site only / Negligible / LOW
Increase in ambient noise levels / Moderate / Reversible / Immediate / Site only / Likely / LOW
Increase in dust emissions or nuisance dust during construction / Moderate / Reversible / Immediate / Site only / Likely / LOW
Increase in nuisance conditions i.e. smells, noise, / Moderate / Reversible / Short term / Site only / Possible but unlikely / LOW
Increase in usage of resource e.g. water / Moderate / Reversible / Short term / Site only / Possible but unlikely / LOW
Conservation of a resource due to recycling / Moderate / Short term / Local / Likely / LOW

6.ENVIRONMENTAL MANAGEMENT PROGRAM

6.1PURPOSE OF THE EMP

This EMP is based on the principles of the National Environmental Management Act (Act no. 107 of 1998) (NEMA). These principles include:

  • To avoid, minimise, or correct pollution and degradation of the environment;
  • To avoid or minimise waste and to re-use or re-cycle waste where possible;
  • To apply a risk averse and cautious approach;
  • To anticipate and prevent negative impacts on the environment (physical, biological, social, economic, and cultural). Where these impacts cannot be prevented, such impacts must be minimized or remedied;
  • That negative impacts on the environment and on people’s environmental rights be anticipated and prevented, and where they cannot be altogether prevented, are minimized and remedied;
  • Environmental management must be integrated, acknowledging that all elements of the environment are linked and interrelated, and it must take into account the effects of decisions on all aspects of the environment and all people in the environment by pursuing the selection of the best practicable environmental option; and
  • The social, economic and environmental impacts of activities, including disadvantages and benefits, must be considered, assessed and evaluated, and decisions must be appropriate in the light of such consideration and assessment.

The NEMA stipulates that anyone who causes pollution or degradation of the environment is responsible for preventing impacts occurring, continuing or recurring and for the costs of repair of the environment. Other legislation that contain requirements which were taken into consideration in drafting the EMP, include: