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1-1 ENVIRONMENTAL AUDIT REPORT 6 CONSTRUCTION OF THE NEW LEEUFONTEIN SUB-STATION IN LEEUFONTEIN, MPUMALANGA PROVINCE DEA Ref. No.: 14/12/16/3//3/1/1435 Green Gold Ref. No.: GGG18/10 PREPARED FOR: PREPARED BY: Transnet SOC Ltd Carlton Centre Commissioner Street Johannesburg Green Gold Group (Pty) Ltd P.O. Box 65384 Erasmusrand 0165, Pretoria

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Page 1: ENVIRONMENTAL AUDIT REPORT 6 - Transnet Home · Environmental and Safety Induction of construction team was conducted on 16 April 2018 during site establishment. The construction

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ENVIRONMENTAL AUDIT REPORT 6

CONSTRUCTION OF THE NEW LEEUFONTEIN SUB-STATION IN LEEUFONTEIN,

MPUMALANGA PROVINCE

DEA Ref. No.: 14/12/16/3//3/1/1435

Green Gold Ref. No.: GGG18/10

PREPARED FOR: PREPARED BY:

Transnet SOC Ltd

Carlton Centre

Commissioner Street

Johannesburg

Green Gold Group (Pty) Ltd

P.O. Box 65384

Erasmusrand

0165, Pretoria

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DOCUMENT CONTROL

DEVELOPER ENVIRONMENTAL AUDITOR

Transnet SOC Ltd Green Gold Group (Pty) Ltd

Contact Edzisani Siphungu Ms Lebohang Moiloa

Contact

Details

Tel: 011 308 1705

Email: [email protected]

Tel: 012 000 2562/ 073 232 4312

Email: [email protected]

Date Signature

Signature

NAME/INFO QUALIFICATIONS

Field Work & Report Lebohang Moiloa MSc (Geography), Pr.Sci.Nat, IAIAsa

Report Review Ntseketsi Lerotholi MSc (Biotechnology), Pr.Sci.Nat, IAIAsa

Audit Date 18 September 2018

Report Ref No./

Date

GGG18/10 2018 10 17

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1 INTRODUCTION

Green Gold Group (PTY) Ltd, thereafter referred to as Green Gold, was appointed by Transnet

SOC Ltd to conduct monthly environmental audits during the construction and rehabilitation

phases of Leeufontein Substation in Mpumalanga. This was done in order to fulfill the

requirements and conditions of an environmental authorisation (EA) issued by the Department of

Environmental Affairs (DEA) on 05 November 2015. The EA reference number is

14/12/16/3/3/1/1435.

Construction commenced in April 2016 but the works were suspended in March 2017 due to

contractual glitches between the Developer and the Contractor. The construction commenced

again on 16 April 2018. This report presents the findings of the sixth environmental compliance

audit since commencement of construction works on 16 April 2018. The site inspection for this

report was done on 18 September 2018.

2 ENVIRONMENTAL MONITORING

The purpose of environmental monitoring programme is to ensure that the conditions of the EA

as well as mitigation measures outlined in the Environmental Management Programme (EMPR)

are adhered to. Construction activities are monitored and recorded by the Contractor

Environmental Officer (CEO) on a weekly basis. Furthermore, the construction activities are

monitored monthly by the CEO and Employer Environmental Officer (EEO). Findings of audits

form part of site progress meetings agenda.

The Contractor is deemed NOT to have complied with specifications if:

1) Within the boundaries of the site and access roads there is evidence of contravention of the

conditions of the EA and the EMPR;

2) Environmental or social damage arises due to negligence;

3) The Contractor fails to comply with required corrective actions or other instructions issued

by delegated authority or ECO;

4) The Contractor fails to address reported complaints by the public or delegated authority;

and

5) Legal action is instituted against the proponent in terms of environmental laws.

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Although the site is under the control of the Contractor during construction and rehabilitation

phases, the ultimate responsibility for compliance with the conditions set out in the EA and the

mitigation measures proposed in the EMPR lies with the Developer (Transnet).

Below is the detailed outline of the external audit methodology.

3 AUDI METHODOLOGY

Environmental compliance audit covers all the conditions of the EA as well as the performance

targets stipulated in the approved EMPR. Training of the Construction Team is essential to ensure

that all parties understand their roles and responsibilities. The Environmental Monitoring

Programme commenced with training, which is followed by monthly audits.

3.1 Training and induction

Environmental and Safety Induction of construction team was conducted on 16 April 2018 during

site establishment. The construction team comprised, among others; Project Manager, Site

Manager, Safety Officer, Drivers, Operators and General Workers. Environmental topics were

presented by both the ECO (Green Gold Group) and EEO (Transnet). During the environmental

induction, the attendants were familiarised with the conditions of the EA and the contents of the

EMPR. The induction was conducted in English after the presenters were assured that all

attendants are conversant with the language. Refresher awareness topics are presented to

Construction Workers every month by the CEO.

3.2 Site clearing and establishment of campsite

During the environmental authorisation process, it was established that there were no sensitive

areas or protected species on-site, neither were there any, adjacent to the site. The Contractor

developed a temporary campsite layout plan that was approved by both the ECO and EEO. The

campsite was established on the already disturbed part of the site, taking consideration of factors

such as wind-direction, access roads, as well as permanent structures already located on-site.

3.3 External audits

Monthly site visits are conducted by Green Gold ECO and monthly reports are compiled in-line

with EIA Regulations guideline. The reports are submitted to DEA within 30 days from the day of

the audit. In order to monitor environmental compliance of site activities, the following procedure

is followed:

The EMPR approved by DEA was used to compile audit checklist (Appendix I).

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Interviews are conducted with Developer Agents and Contractor Agents on the day of the

site visit, the aim of these interviews is to collect all relevant information and documents

referred to in the EMPR.

Site inspections are done on foot inside the construction site and the immediate

surroundings.

Evidence is collected in a form of site photographs and checklist.

On conclusion of the site inspections, representatives from Transnet, Contractor (Mpande),

and Green Gold sign the site inspection checklist cover page.

Reports are compiled monthly and submitted to DEA.

In the report, the compliance status of each condition and performance targets are assessed and

allocated a symbol depending on level of compliance. The following symbols are used in the

report to illustrate compliance status:

2: Full Compliance- the EA Holder and Contractor have complied fully;

1: Partial Compliance- the EA Holder and Contractor have complied but not fully;

0: Non-compliance- the EA Holder and Contractor have NOT complied; and

N/A: Not applicable- the condition/performance target is not/ not yet applicable.

4 REPORTING AND RECORD-KEEPING

Monthly audit reports are produced within 30 days from the date of the audit and submitted to

DEA. Copies of audit reports are distributed to the Developer and the Contractor for safekeeping

on-site during construction phase. The last audit report will be an integration of all preceding

reports, highlighting areas of non-compliance and corrective measures taken to address such.

A list of all audit reports produced to date is provided in Table 1 below:

TABLE 1: A LIST OF AUDIT REPORTS PRODUCED FOR THE PROJECT

REPORT NUMBER SITE VISIT DATE REPORT REF. NO. REPORT DATE

1 26 April 2018 GGG18/01 18 May 2018

2 16 May 2018 GGG18/02 12 June 2018

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REPORT NUMBER SITE VISIT DATE REPORT REF. NO. REPORT DATE

3 19 June 2018 GGG18/03 16 July 2018

4 16 July 2018 GGG18/05 01 August 2018

5 20 August 2018 GGG18/08 10 September 2018

6 18 September 2018 GGG18/10 17 October 2018

4.1 Record keeping

The CEO is responsible for maintaining an environmental file and all records in relation to the EA

and EMPR on-site during the construction phase. The Contractor keeps electronic paper filing

system identifying all documentation related to the EMPR. These reports are readily available on

request by DEA. On completion of rehabilitation phase, the ECO will conduct the final site closure

inspection. All the documents described below will be handed over to Transnet and a site closure

certificate granted to the Contractor. The ECO shall keep all copies of external audit reports

produced on Green Gold filing system for five years. The documents are listed below:

Environmental Management Programme

Environmental Authorisation

Final design documents and diagrams issued to and by the Contractor

All communications with DEA

Training material

Training attendance registers

Vehicle access and visitors log book

Daily, weekly and monthly site monitoring reports

Complaints register

Environmental incident reports

Emergency preparedness and response plans

Permits and legal documents, including letters authorising specific personnel of their duties

as part of emergency preparedness teams e.g. fire teams, etc.

Disciplinary procedures

Minutes of site meeting

Contractor Method Statements

Personal Protective Equipment (PPE) register for workers

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5 FINDINGS

5.1 Findings from previous audit

The current score is 99%, the Developer and Contractor has maintained a good compliance score

99% for three executive months. The partial compliance noted relate to the Developer notifying

I&APs about the EA later than the stipulated timeframe. The Contractor is doing a great job, so

far no incidents have been observed and/or recorded.

5.2 Compliance with EA Conditions

There are 49 conditions set out in the EA, the Contractor and Developer complies fully with 37

of these conditions, complies partially with three (3) whereas nine (9) of the conditions are not

applicable for the current phase of the project.

Figure 1: Compliance with conditions of Environmental Authorisation

5.3 Implementation of mitigation measures as set out in the EMPR

The EMPR was divided into two sections; pre-construction section and construction section. In

analyzing the compliance status, the sections were analyzed separately as stipulated in Figures

2 and 3 below.

5.3.1 Pre-construction mitigation measures

The Contractor complies fully with all 42 mitigations that are applicable to the current phase of

the project, 12 of the mitigation measures are not applicable.

37

3

0 9

Compliance with EA Conditions

Full compliance Partial compliance Non-compliance Non-applicable

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Figure 2: Pre-construction compliance with EMPR

Figure 3: Construction compliance with EMPR

5.3.2 Construction mitigation measures

The Contractor and Developer comply fully with 181 applicable mitigations. Thirty-two of the

mitigation measures are not applicable.

5.4 Overall compliance status

In order to determine the overall compliance status of the project, the different sections discussed

above were combined together and weighted according to the following score:

Full compliance is given a score of 2

42

0

0

12

Full compliance Partial compliance Non-compliance Non-applicable

181

0 032

Construction Mitigationa

Full compliance Partial compliance Non-compliance Non-applicable

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Partial compliance is given a score of 1

Non-compliance is given a score of 0

Non-applicable are excluded from the rating.

SCORE WEIGHTED SCORE

Full-compliance 260 520

Partial-compliance 3 3

Non-compliance 0 0

Total 263 523 0ut of 526

Figure 4: Combined compliance score (excluding Non-applicable)

Out of maximum weighted score of 526, the Developer and Contractor scored 523, which is 99%.

Both the Contractor and the Developer continue to show commitment to protecting the

environmental while implementing the project. The partial-compliance records pertain to Public

Participation where the adjacent landowners were consulted after the construction works had

commenced. In Appendix 1, partial-compliances are highlighted in yellow for ease of reference.

5.5 Recommendations

The Contractor should keep doing the great job that they have started. The EEO should ensure

that the workers get refresher awareness training monthly so that they do not forget what they

learned during Induction Training, attendance register should be kept in the file.

260

3

0

Full compliance Partial compliance Non-compliance

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6 CONCLUSIONS

Construction works have commenced and to date no environmental incidents have been

observed by, or reported to the ECO. The compliance status of 99% is an excellent performance.

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7 APPENDIX 1: AUDIT CHECKLIST

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8 CONDITIONS OF THE ENVIRONMENTAL AUTHORISATION

CONDITION COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

SCOPE OF AUTHORISATION

1. The preferred Site Alternative 1 and Alternative 1 are approved. 2 Construction is on the approved site.

2. Authorisation of the activity is subject to the conditions contained in this environmental authorisation, which form part of the environmental authorisation and are binding on the holder of the authorisation.

2 Conditions are being observed.

3. The holder of the authorisation is responsible for ensuring compliance with the conditions contained in this environmental authorisation. This includes any person acting on the holder’s behalf, including but not limited to, an agent, servant, contractor, sub-contractor, employee, consultant or person rendering a service to the holder of the authorisation.

2

The Holder is taking full responsibility for ensuring compliance.

4. The activities authorised must only be carried out at the property as described above.

2 Authorised activity is being carried out on the approved site.

5. Any changes to, or deviations from, the project description set out in this authorisation must be approved, in writing, by the Department before such changes or deviations may be affected. In assessing whether to grant such approval or not, the Department may request such information as it deems necessary to evaluate the significance and impacts of such changes or deviations and it may be necessary to the holder of the authorisation to apply for further authorisation in terms of the regulations.

2

No changes have been made to date.

6. The holder of an environmental authorisation must apply for an amendmend of the environmental authorisation with the competent authority for any alienation, transfer or change of ownership rights in the property on which the activity is to take place.

2

DEA was informed when the construction works were suspended in 2017.

7. This activity must commence within a period of five (5) years from the date of issue of this environmental authorisation. If commencement of the activity does not ossur within that period, the authorisation lapses

2 The activity commenced within five years.

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CONDITION COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

and a new application for environmental authorisation must be made in order for the activity to be undertaken.

8. Construction must be completed within 5 years of the commencement of the activity on site.

2 The construction phase is still within the five-year period.

9. Commencement with one activity listed in terms of this environmental authorisation constitutes commencement of all authorised activities.

2 Condition observed.

10. In terms of Section 43(7). An appeal under Section 43 of the National Environmental Management Act, 1998 will suspend the environmental authorisation or nay provision or condition attached thereto. In the instance where an appeal is lodged you may not commence with the activity until such time that the appeal has been finalized.

2

Condition observed.

NOTIFICATION OF AUTHORISATION AND RIGHT TO APPEAL

11. The holder of the authorisation must notify every registered interested and affected party, in writing and within 14 (fourteen) calendar days of the date of this environmental authorisation, of the decision to authorise the activity.

2

Registered Interested and Affected Parties (I&APs) were notified accordingly.

12. The notification referred to must; The notification-

12.1 -specify the date on which the authorisation was issued; 2 -specified date of authorisation;

12.2- inform the interested and affected party of the appeal procedure provided for in the national Regulations, 2014;

2 -informed I&APs of the appeal procedure;

12.3 -advise the interested and affected party that a copy of the authorisation will be furnished on request; and 1

-The I&APs were advised after the construction works have commenced.

12.4 -give the reasons of the competent authority for the decision. 1

- The I&APs were advised and given reasons after the construction works have commenced.

13. The holder of the authorisation must publish a notice- 2

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CONDITION COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

13.1 -informing interested and affected parties of the decision; 2 The EA has been published on the Developer’s website.

13.2 -informing interested and affected parties where the decision can be accessed; and

2

13.3 -drawing the attention of interested and affected parties to the fact that an appeal may be lodged against this decision in terms of the National Appeal Regulations, 2014

1 The condition was met but only after the construction works had commenced.

COMMENCEMENT OF THE ACTIVITY

14. The authorised activity must not commence within twenty (20) days of the date of signature of the authorisation.

2 The activity commenced well over 20 days.

MANAGEMENT OF THE ACTIVITY

15. The Environmental Management Programme (EMPR) submitted as part of the Application for EA is hereby approved. This EMPR must be implemented and adhered to.

2 The EMPR is being adhered to.

FREQUENCY AND PROCESS OF UPDATING OF THE EMPR

16. The EMPR must be updated where the findings of the environmental audit reports, contemplated in Condition 23 below, indicate insufficient levels of compliance with the environmental authorisation or EMPR.

2

Sufficient levels of non-compliance have been addressed.

17. The updated EMPR must contain recommendations to rectify the shortcomings identified in the environmental audit report.

N/A EMPR has not been updated yet.

18. The updated EMPR must be submitted to the Department for approval together with the environmental audit report, as per Regulation 34 of GN R.982. The updated EMPR must have been subjected to a public participation process, which process has been agreed to by the Department, prior to submission of the updated EMPR to the Department for approval.

N/A

EMPR has not been updated yet.

19. In assessing whether to grant approval of an EMPR which has been updated as a result in an audit, the Department may request such

N/A EMPR has not been updated yet.

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CONDITION COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

amendments to the EMPR as it deems appropriate to ensure that the EMPR sufficiently provides for avoidance, management and mitigation of environmental impacts associated with the undertaking of the activity.

20. The holder of the authorisation may apply for an amendment of an EMPR, if such amendment is required before an audit is required. The holder must notify the Department of its intention to amend the EMPR as least 60 days prior to submitting such amendments to the EMPR to the Department for approval. In assessing whether to grant such approval or not, the Department will consider the processes and requirements prescribed in Regulation 37 of GN R.982.

N/A

EMPR has not been updated yet.

MONITORING

21. The holder of the authorisation must appoint an experienced independent Environmental Control Officer (ECO) for the construction phase of the development that will have the responsibility to ensure that the mitigation/rehabilitation measures and recommendation referred to in this environmental authorisation are implemented and to ensure compliance with the provision of the approved EMPR.

2

An experienced independent ECO has been appointed.

21.1 The ECO must be appointed before commencement of any authorised activities.

2 ECO was appointed before commencement of the activity.

21.2 Once appointed, the name and contact details of the ECO must be submitted to the Director: Compliance Monitoring of the Department.

2 The name and contact details of the ECO were submitted to DEA.

21.3 The ECO must keep record of all activities on site, problems identified, transgressions noted and a task schedule of tasks undertaken by the ECO.

2 The ECO is keeping the records.

21.4 The ECO must remain employed until all rehabilitation measures, as required for implementation due to construction damage, are completed and the site is ready for operation.

2 The ECO will remain employed until the site is fully rehabilitated.

RECORDING AND REPORTING TO THE DEPARTMENT

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CONDITION COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

22. All documentation e.g. audit /monitoring/compliance reports and notifications, required to be submitted to the Department in terms of this environmental authorisation, must be submitted to the Director: Compliance Monitoring of the Department.

2

Documents are submitted to the Director: Compliance Monitoring of DEA.

23. The holder of the environmental authorisation must, for the period during which the environmental authorisation and EMPR remain valid, ensure the project compliance with the conditions of the environmental authorisation and the EMPR are audited, and that the audit reports are submitted to the Director: Compliance Monitoring of the Department.

2

The project is being audited and reports are submitted to the Director: Compliance Monitoring of DEA.

24. The frequency of auditing and submission of the environmental audit reports must be as per the frequency indicated in the EMPR, taking into account the processes for such auditing as prescribed in Regulation 34 of GN R.982

2

Auditing is being done monthly as prescribed.

25. The holder of the authorisation must, in addition, submit an environmental audit reports to the Department within 30 days of completion of the construction phase (i.e. within 30 days of site handover) and a final environmental audit report within 30 days of completion of rehabilitation activities.

N/A

Construction is still underway.

26. The environment audit reports must be compiled in accordance with Appendix 7 of the EIA Regulations, 2014 and must indicate the date of the of the audit, the name of the auditor and the outcome of the audit in terms of compliance with the environmental authorisation conditions as well as the requirements of the approved EMPR.

2

Audit reports comply with EIA Regs.

27. Records relating to monitoring and auditing must be kept on site and made available for inspection to any relevant and competent authority in respect of this development.

2 Records are kept on-site.

NOTIFICATION TO AUTHORITIES

28. A written notification of commencement must be given to the Department no later than fourteen (14) days prior to the commencement of the activity. Commencement for the purpose of this condition includes site preparation. The notice must include a date on

2

DEA was informed about the commencement of the activity accordingly.

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CONDITION COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

which it is anticipated that the activity will commence, as well as reference number.

OPERATION OF THE ACTIVITY

29. A written notification of operation must be given to the Department no later than fourteen (14) days prior to the commencement of the activity operational phase.

N/A The project is still in construction phase.

SITE CLOSURE AND DECOMMISSIONING

30. Should the activity ever cease or become redundant, the holder of the authorisation must undertake the required actions as prescribed by legislation and the time and comply with all relevant legal requirements administered by any relevant and competent authority at that time.

N/A

The activity is still active.

SPECIFIC CONDITIONS

31. A storm water management plan must be implemented to prevent pollution and runoff.

2

Stormwater method statement has been developed for construction phase.

Stormwater management plan has been developed for operational phase.

No pollution and runoff observed during audit.

32. Should an archaeological artefact be found during excavations; an archaeologist must be called for further investigation.

N/A No archaeological artefacts have been discovered.

33. An integrated waste management approach must be implemented that is based on waste minimization and must incorporate reduction, recycling, re-use and disposal.

2 Waste management plan has been developed, it addresses reduction, recycling, re-use and legal disposal.

34. Any solid waste must be disposed of at a landfill licensed in terms of section 20(b) of the National Environmental Management Waste Act, 2008 (Act 59 of 2008)

2 Waste is disposed of at the Middleburg landfill site.

GENERAL

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CONDITION COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

35. A copy of this environmental authorisation, the audit and compliance monitoring reports, and the approved EMPR, must be made available for inspection and copying-

2 Copies are kept on-site and made available on request.

35.1 -at the site of the authorised activity; 2

35.2 -to anyone on request; and 2

35.3 -where the holder of the environmental authorization has a website, on such publicly accessible website.

2 The EA has been published on Transnet website.

36. National government, provincial government, local authorities or committees appointed in terms of the conditions of this authorisation or any other public authority will not be held responsible for any damages or losses suffered by the holder of the authorization or his/her successor in title in any instance where construction or operation subsequent to the construction be temporarily or permanently stopped for reasons of non-compliance by the holder of the authorisation with the conditions of authorisation as set out in this document or any other subsequent document emanating from these conditions of authorisation.

N/A

Noted, no action is required.

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9 PRE-CONSTRUCTION PROGRAMME

MITIGATION MEASURES (OBJECTIVE AND TARGET) COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

NEGOTIATIONS WITH AFFECTED LANDOWNERS

Transnet will ensure that all affected landowners are negotiated with prior to construction.

2 The Holder is the owner.

COMMISSIONING OF TENDER

The successful tendering Contractors will be made aware of the contents of this EMPR and penalties arising from non-compliance prior to the commencement of work.

2 The Contractor and workers were inducted and refresher courses are held monthly.

All tendering Contractors will be made aware of the audit and monitoring requirements as stipulated in this EMPR.

2 The Contractor was made aware of the requirements.

Appoint an ECO who will be responsible to monitor compliance to the EMPR. 2 ECO has been appointed.

SITE ESTABLISHMENT

Construction camps on the site will be required to be established in appropriate locations prior to the commencement of construction, preferably within already disturbed area. After completion of the contract, these areas have to be rehabilitated.

2

A camp location has been approved by ECO.

Site Plan

Documentation for each proposed campsite should be prepared by the contractor prior to the commencement of construction activities, and should be submitted to Transnet for approval. This documentation should include the following:

2

Campsite plan has been approved by Transnet.

Site access (including entry and exit points). 2

All material and equipment storage areas (including storage areas for hazardous substance such as fuel and chemicals).

2

Construction offices and other structures. 2

Security requirements (including temporary and permanent fencing, and lights).

2

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MITIGATION MEASURES (OBJECTIVE AND TARGET) COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

Solid waste collection facilities and waste treatment facilities for litter, kitchen refuse, sewage and workshop-derived effluents.

2

Storm water control measures. 2 Stormwater control measures are in place.

Provision of potable water and temporary ablution facilities. 2

Potable water and ablution facilities are provided.

Only designated areas may be used for the storage of materials, machinery, equipment and site offices.

2 Materials are stored in designated areas.

The site offices should not be in close proximity of steep areas, as this will increase soil erosion.

2 Site office is located on flat surface area.

Offices (and in particular, the ablution facilities, spoil areas and hazardous material stockpiles) must be located as far away as possible from any watercourse.

2

Offices are located away from water courses.

Throughout the period of construction, the Contractor shall restrict all activities to within the designated areas as per the construction layout plan. Any relaxation or modification of the construction layout plan is to be approved by the ECO.

2

Construction activities are confined within designated areas.

Site Camps

The following restrictions or constraints shall be placed on the site camp, and construction staff in general:

The use of rivers and streams for washing of clothes. 2 No washing of clothes on-site.

The use of welding equipment, oxy-acetylene torches and other bare flames where veld fires constitute a hazard.

2 No flame-producing activities on-site.

Indiscriminate disposal of rubbish or construction waste or rubble littering of the site

2 No indiscriminate disposal of waste.

Spillage of potential pollutants, such as petroleum products. 2 No spillages observed.

Collection of firewood. 2 No collection of firewood.

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MITIGATION MEASURES (OBJECTIVE AND TARGET) COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

Poaching of any form. 2 There is no poaching.

Use of surrounding veld as toilets 2 Chemical toilets are used.

Burning of waste and cleared vegetation. 2 No burning of any material on-site.

Vegetation clearing:

The natural vegetation encountered on the site is to be conserved and left intact as much as possible.

N/A There are no indigenous plants on-site.

Only trees and shrubs directly affected by the works, and such others as may be approved by the ECO in writing, may be felled or cleared.

N/A No trees will be affected by the works.

Water for human consumption:

Water for human consumption should be available at the site offices and at other convenient locations on site. The water must be obtained from an approved source as per SES.

2

Potable water is available, it is being sourced from nearby garage.

Sewage Treatment:

Should there be no other ablution facilities available, chemical toilets must be supplied (1 per 10 persons) and must be regularly cleaned and maintained by the contractor. The positioning of the chemical toilets is to be done in consultation with the ECO.

2

Chemical toilets have been provided for both male and female at 1:10 ratio.

Chemical toilets are serviced twice a week and service certificates kept on-site.

Applicant should make sure that no sanitary system is located within a horizontal distance of 100m from any water course.

2 No sanitary systems located within 100m of a water course.

The Contractor should arrange for regular emptying of toilets and will further be entirely responsible for enforcing their use.

2 Chemical toilets are serviced twice a week and service certificates kept on-site.

The Contractor will ensure that the latrines are well maintained and clean. 2 Toilets are kept clean.

If necessary, the ablution facilities should be screened from the public view. In remote areas where chemical toilets may not be a viable option, agreement must be reached on the alternatives before construction starts.

N/A There is no public in the immediate vicinity of the site.

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MITIGATION MEASURES (OBJECTIVE AND TARGET) COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

The ablution facilities must be located 100m or more from the wetland and its buffers.

N/A There are no wetlands on/ adjacent the site.

9.1 SENSITIVE ECOLOGY

Relocate, demarcate or recommend conservation/ preservation measures for any identified ecologically sensitive and/or protected species and areas

N/A There are no ecologically sensitive and/or protected species on-site.

Point out and/or demarcate all ecologically sensitive areas to the Contractor (e.g. red data habitats & species, rivers, streams, wetlands, sensitive soils, steep slopes and areas susceptible to erosion).

N/A There are no ecologically sensitive and/or protected species on-site.

Ensure that “No-Go” areas are clearly demarcated and/or fenced before construction starts. Barriers are to be maintained in good order throughout the course of the construction.

2 The site is fenced off.

9.2 ROADS

An access route to the site already exists and therefore there may be no need for new road construction. The client must point out the access road to be used. The Contractor must make use of the existing routes as far as practically possible.

2

Existing access roads are used.

Access roads will be maintained by the Contractor. The Contractor will erect and maintain marker pegs along the boundaries of the working areas, access roads, haul roads or paths, to the satisfaction of the Construction Manager, before commencing any other work. If proved insufficient for control, these will be replaced by fencing, with the additional cost being borne by the Contractor.

2

Access roads are in good condition.

Signs have been placed.

Ensure that access roads to the site are of suitable quality to eliminate soil erosion, and channel storm water into grass buffer area.

N/A Construction workers use existing pubic gravel road to the site, gravel roads.

All existing farm roads (private roads) damaged during the construction phase, should at the end of construction be repaired to the satisfaction of the landowner, as per the conditions of the written contractual agreement between the landowner and Transnet.

N/A

Applicable during rehabilitation phase.

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MITIGATION MEASURES (OBJECTIVE AND TARGET) COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

Transnet must communicate the conditions of the agreement with the Contractor to ensure compliance during construction activities.

N/A

Damage to the existing access roads as a result of construction activities (during construction), will be repaired to the satisfaction of the Project Manager. The cost of the repairs will be borne by the Contractor.

N/A

9.3 MATERIAL HANDLING, USE AND STORAGE

The Contractor’s management and maintenance of the plant and machinery will be strictly monitored according to the criteria given below.

2 A checklist is used to ensure plant and machinery are in good condition.

Safety:

All the necessary handling and safety equipment required for safe use of petrochemicals and oils shall be provided by the Contractor to be used and/or worn by the staff.

2

PPE is provided to workers.

Contractor must comply with the Occupational Health and Safety Act, 1993 (Act 85 of 1993) and Construction Regulations, 2003 as this governs what the contractor has to do/provide for his staff

2

Contractor complies with OHS Act.

Hazardous Material Storage:

Petrochemicals, oils and identified hazardous substances shall only be stored under controlled conditions.

2

Covered storage has been provided for hazardous materials.

All hazardous materials will be stored in a secured, designated area that is fenced and has restricted entry. Storage of hazardous products shall only take place using suitable containers approved by the ECO. In addition, hazard signs indicating the nature of the stored materials shall be displayed on the storage facility or containment structure.

2

Suitable covered storage has been provided for hazardous materials

Fuels and gas storage

Fuel should be stored in a secure area in a steel tank supplied and maintained by the Contractor according to safety procedures.

N/A No fuel is stored on-site.

Gas welding cylinders and LPG cylinders should be stored in a secure, well-ventilated area.

N/A No welding gas on-site.

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MITIGATION MEASURES (OBJECTIVE AND TARGET) COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

The Contractor must supply sufficient firefighting equipment in event of an accident and strictly no smoking will be allowed where fuel is stored and used. 2

Sufficient fire extinguishers have been provided.

Designated smoking area is located far from storage containers.

9.4 EMPR TRAINING

The CEO shall arrange for Environmental Awareness Training programs for the personnel on site and the construction team with the contents of this EMPR, either in written format or verbally.

2 The ECO and EEO provided induction and awareness to construction workers using verbal and written communication.

9.5 WATER SUPPLY

The source of water will be the current supply to the existing substation. 2

Water sourced from nearby garage or local municipality.

The Contractor shall only make use of approved sources to obtain water and this will be inspected by the ECO on a quarterly basis. 2

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10 CONSTRUCTION MANAGEMENT PLAN

MITIGATION MEASURE (OBJECTIVE AND TARGET) COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

10.1 VEHICULAR ACCESS AND MOVEMENT OF CONSTRUCTION VEHICLES

All access roads will be marked. 2 Access roads are marked.

Agree on access to be used throughout the construction phase. 2 Access roads have been identified.

No illegal use of private roads during construction due to damage anticipated as a result of heavy vehicles and equipment.

2 Use of farm roads has been agreed upon with affected farm-owners.

All existing private access roads used for construction purposes, shall be maintained at all times to ensure that the local people have free access to and from their properties.

2 Roads are accessible to other users.

Speed limits shall be enforced in such areas and all drivers shall be sensitised to this effect.

2 Drivers have been sensitised about importance of keeping to speed limits.

Upon completion of the project all roads shall be repaired to their original state.

N/A Not applicable at this stage.

No roads shall be cut through river-and streams banks as this may lead to erosion causing siltation of streams and downstream dams.

2 Existing roads are used.

No equipment shall be used which may cause irreparable damage to wet area.

2 There are no damages due to works on-site.

The Contractor shall use alternative methods of construction in such areas. 2

During the construction, use should be made of existing access routes to construction areas where possible.

2 Existing roads are used.

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MITIGATION MEASURE (OBJECTIVE AND TARGET) COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

Construct approved vehicle turning areas, avoiding selected ecological sensitive areas or species, and have turning area routes approved by the ECO.

2 Existing roads are used.

Temporary access roads must be rehabilitated after use. N/A Not applicable for this phase.

Soil stabilisation measures to be implemented on steep slopes. N/A Established existing roads are used.

Rehabilitation of disturbed areas immediately following road construction. N/A No roads have been constructed.

10.2 MOVEMENT OF CONSTRUCTION PERSONNEL AND EQUIPMENT

All the construction personnel, labourers and equipment remain within the demarcated construction site at all times.

2 Workers remain on construction site during working hours.

Ensure the access to the site, including related infrastructure and machinery is restricted to authorised personnel only.

2 Only authorised personnel are allowed to operate machinery.

Where construction personnel and/or equipment wish to move outside the boundaries of the site, the Contractor/labourers must obtain permission from the CEO.

N/A Workers and equipment are stationed within the site boundary.

All equipment moved onto site or off site during a project is subject to compliance with the legal requirements.

2 Equipment complies with requirements. A daily checklist is administered.

Oil-filled equipment such as transformer, CT’s, VT’s and capacitor cans have specific safety requirements regarding their handling, transport and storage. The Contractor shall meet these safety requirements under all circumstances.

N/A Oil-filled equipment such as transformers has not been brought to the site as yet.

All equipment transported shall be clearly labelled as to their potential hazards according to specifications.

2 All construction vehicles are labelled.

All the required safety labelling on the containers and trucks used shall be in place.

2 Construction vehicles are labelled.

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MITIGATION MEASURE (OBJECTIVE AND TARGET) COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

Ensure that all the necessary precautions against damage to the environment and injury to persons are taken in the event of an accident and shall supply a method statement to that effect.

2 Clean-up spill kits are available on-site.

Method statement has been developed.

No machinery, personnel, material, or equipment enters “No-Go” areas at all times during the course of the project.

2 Equipment and personnel remain on site boundary during working hours.

10.3 VEGETATION

Although no protected species were identified on site during the site assessment, any protected species which cannot be avoided should be trans-located to safe sites nearby.

N/A No protected species have been found on-site.

Existing tracks should be used access wherever possible. 2 Existing tracks are used.

Demarcate the construction footprint. 2 Construction footprint demarcated.

A temporary fence or a demarcation must be erected around the construction area (include the servitude, construction camps, areas where material is stored and the actual footprint of the development) to prevent access to sensitive environs.

2 Temporary fence has been erected.

No open fires are permitted within naturally vegetated areas. 2 No evidence of fire on-site.

Formalise access roads and make use of existing roads and tracks where feasible, rather than creating new routes through naturally vegetated areas.

2 Existing roads are used.

Construction workers may not remove flora and neither may anyone collect seed from the plants without permission from the local authority.

2 Construction workers do not remove plants and seeds except for site clearing.

Retain soil and vegetation in position for as long as possible, removing it immediately ahead of construction/earthworks in that area.

2 Vegetation is cleared where necessary only.

Remove only vegetation where essential for construction and do not allow any disturbance to the adjoining natural vegetation cover.

2

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MITIGATION MEASURE (OBJECTIVE AND TARGET) COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

Implement an alien invasive plant monitoring and management plan whereby the spread of alien and invasive plant species into the areas disturbed by the construction are regularly removed and re-infestation monitored.

2 Alien invasive plant monitoring and management plan is in place.

No alien invasive plants observed on-site.

10.4 PROTECTION OF FAUNA AND AVIFAUNA

Any active faunal burrows within the development footprint should be located and marked before construction and avoided until the occupant animals can be excluded or have moved away due to the nearby construction activities.

2 The site was inspected, no barrows were found.

Any fauna threatened by construction activities should be removed to safety.

N/A No fauna has been spotted on-site.

During construction, all vehicles should adhere to demarcated tracks or roads and the speed limit should not exceed 30km/h.

2 Vehicles stay on tracks and keep speed limit.

Where necessary, dust suppression should be done to reduce dust impacts on surrounding areas.

2 Water-spraying used to suppress dust.

All construction staff should undergo environmental induction before construction commences in order to raise awareness and reduce potential faunal impacts.

2 Induction was conducted. On-going awareness raising is done regularly.

All spills of hazardous material should be cleared in an appropriate manner according to the nature and identity of the spill and all contaminated soil removed from the site.

2 Drip trays used to collect dripping oil, to disposed of at the hazardous landfill site.

Under no circumstances shall any animals (stock or game) be handled, removed, killed or be interfered with by the Contractors, his employees, his subcontractors or his subcontractor’s employees.

2 No animals have been handled on-site.

No hunting of fauna and avifauna shall be tolerated on the site or elsewhere.

2 Hunting is not allowed on-site.

No domesticated animals are allowed on site. 2 Domestic animals are not allowed on-site.

The site must be kept clean and tidy from rubbish that can attract animals. 2 The site is kept clean.

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MITIGATION MEASURE (OBJECTIVE AND TARGET) COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

Vegetation clearing must be restricted to the construction footprint only. 2 Vegetation clearing is restricted to construction footprint.

Fauna rescue and relocation programme must be implemented. 2 Fauna rescue method statement is in place. The ECO is content that the approach will suffice since there is little faunal activity on-site.

Any open excavations must be inspected early in the morning prior to the daily construction activities. Any amphibians and small mammals or any other fauna species found should be removed and released in suitable habitats away from construction activities.

2 Excavations are inspected.

The open excavations should be filled as soon as possible. 2 Excavations are filled as soon as work is complete.

Records of any injured or deaths of sensitive species within the construction site must be kept by the ECO.

2 Incident register is available on-site. No incidents have been recorded to date.

Areas identified with high ecological sensitivity should be avoided during construction activities.

N/A There are no areas with high ecological sensitivity on-site and immediate surroundings.

As much of the natural vegetation as possible should be left intact in order to maintain ecological corridors for the movement of fauna species.

2 Removal of vegetation is limited to construction footprint.

Disturbed areas should be re-vegetated as soon as possible using an appropriate plan which incorporates indigenous plant species.

2 Disturbed areas are rehabilitated progressively. Indigenous grass will be used for rehabilitation upon completion of construction works.

Roads should be planned to encourage faunal dispersal and minimise fragmentation of ecologically sensitive areas.

N/A Existing roads are used.

Roads should preferably be maintained as gravel tracks. 2 Access roads are kept as dirt roads.

Construction should be restricted to daylight hours to prevent any disturbance such as floodlights.

2 Construction works restricted to daytime.

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MITIGATION MEASURE (OBJECTIVE AND TARGET) COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

Personnel should be informed of the Animal Protection Act No. 71 of 1962 and encouraged not to harm any wildlife.

2 Animal protection topic was included during induction.

Refresher awareness conducted regularly.

Pesticides that are environmentally friendly should be used if necessary. 2 No pesticides are used on-site.

Vehicles must be regularly checked for oil or hydraulic leaks during the construction phase to prevent pollutants from entering surface and groundwater.

2 Drip trays are placed under vehicles that could potentially have fuel leaks.

10.5 HERITAGE AND/OR ARCHAEOLOGICAL SITES

No obvious cultural or historical material were identified on site, however, should any graves or heritage artefacts be discovered during construction phase, all works must stop at the affected area and the Eco must be contacted. The ECO will contact SAHRA and all necessary procedures will be followed

N/A Workers were made aware of this requirement. No archaeological objects have been discovered yet.

All identified archaeological material shall be barricaded and marked as no go for the duration of the construction phase.

N/A No archaeological material has been identified.

Labour-intensive workers should be notified about these graveyards and the developer should avoid conveying duty during the time when the graveyards are active (that’s mostly Saturday mornings).

N/A

If any archaeological material (e.g. fossils, bones, artefacts, etc) is found during excavation, the Contractor shall stop work immediately and inform the ECO and Transnet.

N/A

The ECO shall inform SAHRA and arrange for a registered heritage specialist to inspect, and if necessary excavate the material, subject to acquiring the necessary approval from SAHRA.

N/A

The Contractor shall not commence working in that area until written permission has been received from the SAHRA.

N/A

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MITIGATION MEASURE (OBJECTIVE AND TARGET) COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

Under no circumstance may any heritage material be destroyed or removed from the site until the necessary approval has been obtained from SAHRA.

N/A

Should any remains be found on site (potential human remains) the South African Police Services should be contacted.

N/A

An information section on cultural resources must be included in the environmental training given the Contractors involved in earthmoving and trenching activities. This section must include basic information on:

Heritage;

Graves;

Palaeontology;

Archaeological findings; and

Historical Structures.

2 During induction, workers were made aware of this requirement.

10.6 ACCESS ROADS

Access road to site already exists. The primary access to the site will then be National Route N4 and direct access will be through the Transnet Railway line service road which is a gravel track.

2 Existing access roads are used as stipulated.

Construction staff may only use authorised paths and roads. 2 Construction staff use staff transport provided.

The proclaimed speed limit must be strictly adhered to. 2 Speed limit of 30km/hr has been proclaimed along dirt access roads and it is adhered to.

If two-way traffic movement is to take place, passing bays are to be used to prevent access/ detours into the surrounding areas. The drivers delivering construction materials to site are to be made aware of this.

2 No detours to surrounding areas have been established. Traffic is accommodated within existing road network.

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MITIGATION MEASURE (OBJECTIVE AND TARGET) COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

Upon completion of the construction, the Contractor will ensure that the access roads are returned to a state no worse than prior to construction commencement.

N/A Applicable during rehabilitation phase.

10.7 SERVICING AND REFUELLING OF CONSTRUCTION EQUIPMENT

All maintenance and repair work will be carried out within an area designated for this purpose, equipped with necessary pollution containment measures.

2 No maintenance is carried out on-site.

The ground under the servicing and refuelling areas must be protected against pollution caused by spills and/ or tank overfills (bunded/lined).

2

The Contractor may only change oil or lubricant at agreed and designated locations, except during emergency repair, following which any accidental spillages will be cleaned up/ removed immediately.

2

In such instances the Contractor will ensure that drip trays are available to collect any oil or pollutants.

2 Drip trays are used.

Drip trays must be placed under vehicles and machinery that are stationary. 2 Drip trays are placed under trucks and machinery.

Construction vehicles are to be maintained in an acceptable state of repair. No vehicles or equipment with leaks or causing spills will be permitted to operate at any of the construction sites.

2 Vehicles are kept in good condition; a checklist is administered daily.

Fuels required during construction must be stored in central depot at a construction camp.

2 Fuel is not kept on-site.

This storage area should be located on a slab and be contained within a bund capable of containing at least 110% of the total volume in the containers.

2

Temporary fuel storage tanks and transfer areas also need to be located on an adequately bunded surface to contain accidental spillages.

2

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MITIGATION MEASURE (OBJECTIVE AND TARGET) COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

Appropriate run-off containment measures must be put in place. 2

10.8 WASTE MANAGEMENT

Solid waste management

An adequate number of scavenger proof refuse bins must be provided at the construction site.

2 Waste bins with lids have been provided.

The Contractor will ensure that all personnel deposit waste in the waste bins provided.

2 Workers use provided waste bins.

All waste must be transported in an appropriate manner (e.g. plastic rubbish bags) and disposed of at a registered waste disposal site. Proof of safe disposal must be kept on site.

2 Waste is transported in covered drums. Disposal register is kept on-site.

The Contractor may not dispose of any waste and/or construction debris by burning or burying.

2 No burning of waste is allowed on-site.

Waste bins must be emptied regularly (minimum weekly) such that they do not overfill.

2 Bins are emptied as soon as they get full.

Discard all construction waste as a registered waste management facility/ landfill site, particularly waste or products that could impact on surface or groundwater quality by leaching into or coming into contact with water.

2 Waste is disposed of at Middleburg landfill site weekly.

The Contractor will maintain good housekeeping practices and ensure that all work sites and construction camp are kept tidy and litter free.

2 The site is clean and tidy.

Liquid waste management

An adequate number of drums must be provided at the construction site. 2 An adequate number of bins has been provided.

These drums must be provided with lids and an external closing mechanism to prevent their contents from rain.

2 The bins provided have covers.

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MITIGATION MEASURE (OBJECTIVE AND TARGET) COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

The Contractor will ensure that all personnel discharge waste water in the drums provided.

2 Workers use provided bins.

All waste must be transported in an appropriate manner and disposed of at a registered waste disposal site.

2 Waste transported in closed bins to the landfill site.

10.9 SURFACE AND GROUNDWATER MANAGEMENT

Water use related activities must be approved by DWS prior to commencement.

N/A There are no regulated water-use activities on-site. We recommend that this mitigation measure be removed.

No unauthorised activities should occur within 100m or within the 1:100-year floodline.

2 No activities occur within100m or within the 1:100-year floodline.

The Contractor must take reasonable precautions to prevent the pollution of the ground and water resources on and adjacent to the site as a result of this activities.

2 No groundwater pollution has occurred.

All the requirements stipulated in the National Water Act, No. 36 of 1998 must be adhered to.

N/A The National Water Act, No. 36 of 1998 does not apply. We recommend that this mitigation measure be removed.

No surface, ground or storm water may be polluted as a result of any activities on the site.

2 No pollution of water has occurred.

Erosion control measures must be implemented to reduce erosion and sedimentation.

2 No sign of erosion or sedimentation on-site.

No natural watercourse is to be used for the cleaning of tools or any other apparatus. This includes for purposes of bathing, or the washing of clothes etc.

2 No natural watercourse is used for the cleaning of tools.

All washing operations will take place off-site at a location where wastewater can be disposed of in an acceptable manner.

2 Tools are not washed on-site.

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MITIGATION MEASURE (OBJECTIVE AND TARGET) COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

No spills may be hosed down into a storm water drain or sewer, or into the surrounding natural environment.

2 No spills have been reported.

All soil contaminated, for example by leaking machines, refuelling spills etc, is to be excavated to the depth of contaminant penetration, paced in suitable drums/containers and removed to a hazardous waste facility.

2 Soil has not been contaminated.

No extraction of water from any natural resources without the relevant authorisation.

2 There is no extraction of water from natural resources.

Stormwater management measures must be as per the stormwater management plan.

2 Stormwater management plan implemented.

Erosion control on temporary access roads must be undertaken. N/A Existing roads are used as they are. We recommend that this mitigation measure be removed.

Any physical damage to any aspect of a water course must be avoided. 2 There hasn’t been any damage to a water course.

Minimise the extent of any damage to flood plains that is necessary to complete the works, and will not pollute any river as a result of construction.

N/A There are no rivers and flood plains in the vicinity of the site. We recommend that this mitigation measure be removed.

10.10 SENSITIVE AREAS (WETLANDS AND BUFFERS)

Sediment barriers must be properly maintained throughout construction and reinstalled as necessary until replaced by permanent erosion controls or restoration of adjacent upland area is complete.

2 There is no erosion on-site.

A temporary fence or demarcation must be erected around the works area to prevent access to sensitive environments. The works areas generally include the construction camps(s) and areas where material is stored.

2 A fence has been erected around the construction site.

Planning of construction site must include eventual rehabilitation/restoration of indigenous vegetation cover;

2 Rehabilitation plan has been developed.

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MITIGATION MEASURE (OBJECTIVE AND TARGET) COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

Cordon-off areas that are under rehabilitation as no-go areas using appropriate measures. If necessary, these areas should be dropped off to prevent vehicular, pedestrian and livestock access;

2

Remove only the vegetation where essential for construction and do not allow any disturbance to the adjoining natural vegetation cover.

2 Site clearance is done progressively only where necessary.

During the construction phase, measures must be put in place to control the flow of excess water so that it does not impact on the surface vegetation.

2 Stormwater management plan is in place.

Protect all areas susceptible to erosion and ensure that there is no undue soil erosion resultant from activities within and adjacent to the construction camp and work areas.

2 There is no soil erosion on-site.

Runoff from roads must be managed to avoid erosion and pollution problems.

2 There is no pollution from construction works and related activities.

Active rehabilitation and monitoring of erosion where required, and monitor vegetation.

2 There is no erosion on-site.

10.11 HAZARDOUS MATERIALS

Ensure compliance with all national, regional and local legislation with regard to the storage, transport, use and disposal of petroleum, chemical, harmful and hazardous substances and materials.

2 Workers have been inducted on transportation, use and disposal of hazardous substances.

Training also included handling of accidental spillages.

Ensure that proper training and education of all personnel on site who will be handling the material about its proper use, handling the material about its proper use, handling and disposal is undertaken.

2

Establish an emergency procedure for dealing with spills or toxic substances.

2

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MITIGATION MEASURE (OBJECTIVE AND TARGET) COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

Storage of all hazardous materials is to be safe, tamper-proof and under strict control.

2

Petroleum, chemical, harmful and hazardous waste throughout the site must be stored in appropriate, well-maintained containers.

2

Exercise extreme care with the handling of diesel and other toxic solvents to ensure that spillage is minimised.

2

Any accidental chemical/ fuel spills have to be corrected immediately. 2

10.12 OIL SPILL MANAGEMENT

Transformers and voltage transformers as well as other tools and equipment contain oil, care should be taken when installing them.

2 No spillages have been observed nor recorded on-site.

Prevent potential oil spills during the replacement of underrated equipment, installation of current transformers and installation of the transformer.

2

Fuels, oils, hydraulic fluids, cements etc. must be stored in properly contained areas so as to minimise accidental spillage.

2

No hazardous or toxic chemicals or substances should be stored where there could be accidental leakage into subterranean water supplies.

2 Locke-up containers have been provided to storage of hazardous waste.

Accommodation must be made for oil leaks that may occur from vehicle sumps. This can be achieved by providing a sump tray for each vehicle or sand that is later removed from site. The containment sand will have to be disposed of at a licensed hazardous disposal site.

2 Trip trays and oil spill kits have been provided.

All significant spills must be reported to the ECO within 24 hours. N/A No spillages have occurred.

A mobile oil spill kit must be available on site at all times. 2 Spill kits are available on-site.

The oil spill clean-up and rehabilitation standard need to be implemented. 2 Clean-up procedure is in place.

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MITIGATION MEASURE (OBJECTIVE AND TARGET) COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

10.13 STORMWATER MANAGEMENT

Ensure the rainwater containing pollutants does not run-off into natural areas and thus result in a pollution threat.

2 No pollutants have been discharged into the environment.

Stormwater management plan must be implemented. 2 Stormwater management method statement is implemented.

The client must ensure that the drainage diversion system is fully operational to divert runoff from areas of potential pollution, e.g., batching area, vehicle maintenance area, workshops, chemical and fuel stores, etc.

2 There are no batching areas, no vehicle maintenance and no workshops on-site.

Chemical and fuel are stored in a lockup container above ground-level.

Stormwater shall be diverted from the construction works. Where necessary, works must be constructed to attenuate the velocity of the stormwater discharge.

2 Stormwater management method statement is adhered to.

Increased runoff due to vegetation clearance and/or soil compaction must be managed and steps must be taken to ensure that the stormwater does not lead to excessive levels of silt entering the watercourses.

2 No excessive levels of silt from the site enters watercourses.

Necessary erosion mechanisms shall be employed to ensure that stormwater leaving the construction site is not contaminated by any substance, whether solid, liquid or gas.

2 No contamination of stormwater has been observed.

Stormwater management system must be constructed, operated and maintained in a suitable manner throughout the project.

2 Stormwater is being managed effectively.

10.14 FIRE

A fire management plan and Fire Protection Plan should be put in place by the Contractor and Transnet.

2 Fire Protection Plan is available on-site.

Landowners must be consulted in order to incorporate their specific firefighting measures.

2 Adjacent landowners have been consulted.

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MITIGATION MEASURE (OBJECTIVE AND TARGET) COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

All the necessary precautions to ensure that fires are not started as a result of activities on-site must be put in place.

2 Workers have been trained on fire-prevention measures.

Fuels or chemicals must be stored at the designated storage area. 2 No fuels or chemicals are stored on-site through a storage container has been provided.

Gas and liquid fuels may not be stored in the same storage area. 2 Gas and fuel not stored on-site.

All fire control mechanisms (firefighting equipment) will be routinely inspected by a qualified investigator for efficiency and be approved by local fire services. Such mechanisms will be present and accessible at all times.

2 Fire extinguishers are regularly inspected.

The Contractor must ensure that there is adequate firefighting equipment at the fuel stores in case of emergency.

2 Adequate fire extinguishers have been provided.

No open fires for heating or cooking will be permitted on site, unless otherwise agreed and then only on designated areas.

2 Fires are not allowed on-site.

All staff on-site will be made aware of the general fire prevention and control methods and the name of the responsible person to alert of the presence of a fire.

2 Fire prevention was part of the induction.

Designated smoking areas should be provided, with special bins for discarding of cigarette stumps.

2 Designated smoking area provided.

Fire must be reported immediately. 2 Fire emergency numbers are available on-site.

10.15 AIR POLLUTION

The potential air pollutants would be dust emanating from excavation activities and access roads as well as from emissions from vehicle/equipment exhausts.

Appropriate dust suppression measures of temporary stabilising mechanisms will be sued when dust generation is unavoidable (e.g., dampening with water, chemical soil binders, straw, brush packs chipping), particularly during prolonged periods of dry weather.

2 Dust suppression is done by means of water-spraying.

Removal of vegetation will be avoided until such time as soil stripping is required.

2 Stripping of soil is done progressively when necessary.

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MITIGATION MEASURE (OBJECTIVE AND TARGET) COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

No burning of waste material, such as vegetation from any clearing operations is allowed;

2 There is no burning of waste on-site.

Drive at authorised speed on the access road in order to minimise or avoid dust pollution.

2 Vehicles stick to speed limit.

Excavation, handling and transportation of erodible materials will be avoided under high wind conditions or when a visible dust plume is present.

2 High wind conditions are observed when excavating and transporting erodible materials.

If dust-damping measures are deemed inadequate, work will cease until windspeed drops to an acceptable level.

2 Water-spraying is sufficient in suppressing dust.

Soil stockpiles will be located in sheltered areas to limit the erosive effects of the wind.

2 Soil stockpiles are covered with mesh to prevent erosive effects of wind.

Equipment and construction vehicles must be in good working order. 2 Machinery and vehicles are maintained in a good working condition.

10.16 NOISE

Machinery and vehicles are to be maintained in a good working order. 2 Machinery and vehicles are maintained in a good working condition. Malfuntioning staff trasnport was dealt with swiftly.

Offending machinery and vehicles will be banned from use on site until they have been repaired.

2 No offending machinery have been observed on-site.

Noise levels must be kept within acceptable limits and must not be of such nature as to detract adjacent landusers.

2 There is no loud noise coming from the site.

No complaints have been received from adjacent land-users.

Noise-generating activities with output levels of 85dB or more must be scheduled between 07h00- 17h00 Mondays to Fridays and weekends as required and with the permission of the ECO and consent from landowner

2 Noise exceeding 85dB has not been recorded on-site.

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MITIGATION MEASURE (OBJECTIVE AND TARGET) COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

Any complaints pertianing to the noise must be recorded and reported to the ECO and addressed accordingly.

2 No complaints have been received by ECO.

Labourers to be provided with hearing protection as and when required 2 Noise exceeding 85dB has not been recorded on-site.

10.17 VISUAL

Storage facilities, feeder bay, transformers and other temporary structures on site should be located such that they have as little visual impact on local residents as possible.

2 The site is far from residents.

Soil excavated (if any) must not be stockpiled above 2m. 2 Excavated soil is stockpiled below 1m.

All temporary structures erected on-site for the purpose of the project’s construction pahse will be removed from the site upon completion of the project.

N/A Applicable for rehabilitation phase.

Lighting will be sufficient to ensure security but will not constitute light pollution to the surrounding areas.

2 Lighting adequate to security needs.

The site must be clean and tidy at all times. 2 The site is clean and tidy.

10.18 EXCAVATION, BACKFILLING AND TRENCHING

While working at areas prone to erosion, the following must be adhered to:

Excavations must not be left open for longer than 30 days where at all possible.

2 No excavations by the Contractor have been left open for more than 30 days.

Excavations must be barricaded/ fenced off at all times. 2 The entire site is fenced off.

Excavations are barricaded.

10.19 AGRICULTUAL ACTIVITIES

Maintain good relations with landowners. 2 The Developer is the landowner.

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MITIGATION MEASURE (OBJECTIVE AND TARGET) COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

No complaints have been received from adjacent landowners.

Avoid unnecessary destruction of crops by remaining within the servitude at all times.

2 Construction works and workers operate within the construction site.

No form of disturbance of agricultural stock will be permitted for whatever reason, except for all aproved activities.

2 Construction works and workers operate within the construction site without causing any disturbance to livestock.

10.20 EROSION AND CONTROL

To prevent any form of erosion the following must be adhered to:

During constructionm the Contractor will protect areas susceptible to erosion by installing necessary temporary and/ or permanent drainage works as soon as possible by taking suitable measures to prevent surface water concentration into nearby roads.

2 Erosion control measures have been put in place.

Prior to construction, all topsoil (top 300mm as a minimum) must be stripped and stockpiled separately from subsoil and rocky material.

2 An area has been identified for storage of topsoil in line with this requirement.

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

2 Top soil is removed progressively when required.

Stockpiled topsoil should not be compacted and should be replaced as the final soil layer.

2 Stockpile is not compacted.

No vehicles/ equipment may be allowed access onto the stockpiles after they have been placed.

2 Vehicles are not allowed to drive over stockpiles.

Topsoil obtained from sites with different soil types must not be mixed. 2 No topsoil has been brought to the site from offsite.

Topsoil stockpiles must not be contaminated with any foreign matter, which may inhibit later growth of vegetation and microorganism in the soils.

2 Topsoil has not been contaminated.

Soil must not be stockpiled in the drainage lines or near watercourses. 2 Soil is not stockpiled in drainage lines.

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MITIGATION MEASURE (OBJECTIVE AND TARGET) COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

Vehicles must use the existing access route. 2 Vehicles use existing roads.

Where required, cut-off trenches can be installed to divert substantial runoff and prevent erosion as and when necessary.

2 Stormwater management method statement is implemented.

Sensitive areas such as watercourses shold be cordoned off so that vehicles and construction personnel cannot gain access to these areas.

N/A There are no sensitive areas on-site.

Where access cannot be avoided into sensitive areas, the amount of vehice and personnel traffic should be kept to a minimum and shoud make use of only one route.

N/A There are no sensitive areas on-site.

Soil erosion must be prevented at all times along the access road. 2 Construction vehicles used established dirt roads. Speed limit is enforced to avoid wind erosion of soil.

Any runnels or erosion channels will be backfilled and compacted, and the area/s restored to a proper condition.

2 Ponds occurring on-site are filled and compacted using excavated soil.

Limit ponding on the surface and ensure storwater runoff is channelled from the site. The method used will be appropriate to the expected stormwater flows and the topography and geology of the site.

2

The Contractor will be liable for any damage to downstream property caused by the diversion of overland stormwater flows.

2 The Contractor has been made aware of this requirement.

10.21 USE OF CEMENT AND CONCRETE

The Contractor is advised that cement and concrete are regarded as highly hazardous to the natural environment due to their high pH and the chemicals contained therein. To avoid ground pollution the following must be adhere to:

Pre-mix concrete shall be preferred option where possible. 2 Pre-mix concrete is used where large quantities are required. For smaller amounts, concrete is mixed on-site in a wheelbarrow.

The batching / mixing area must be properly designed and indicated on the site plan and it will be neat and clean at all times.

2 Small quantity mixing of cement is done inside a wheelbarrow.

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MITIGATION MEASURE (OBJECTIVE AND TARGET) COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

No batching / mixing activities will occur on a permeable surface. 2 Pre-mix concrete is used where large quantities are required. For smaller amounts, concrete is mixed on-site in a wheelbarrow.

All runoff from such area will be strictly controlled, with contaminated water collected, stored / contained and disposed of at an approved waste disposal site.

2

Unused cement bags will be stored appropriately so as not to be affected by rain/runoff.

2 Cement bags are still sealed and stored in a locked container.

Used cement bags will be stored so as to prevent windblown dust and potential water contamination. Used bags will be disposed of regularly via solid waste management system detailed previously.

2 Covered bins have been provided for empty cement bags.

Concrete transportation will not result in spillage 2 No spillages have been recorded.

To prevent spillage onto roads, ready mix trucks will rinse off the delivery shoot into a suitable sump prior to leaving site

2 No spillages have been recorded.

All contaminated water and fines from exposed aggregate finishes will be collected and stored in sumps for disposal at an approved waste disposal site.

2

The visible remains of the batch plant and concrete, either solid, or from washings shall be physically removed immediately and disposed of appropriately at a registered landfill site.

N/A Applicable for rehabilitation phase.

10.22 SITE CLEAN-UP AND REHABILITATION

The Contractor must ensure that all temporary structures, materials, waste and facilities used for construction activities are removed upon completion of the project.

N/A Applicable during rehabilitation phase.

Fully rehabilitate (eg. Clear and clean area, rake, pack branches etc.) all distured ares and protect them from erosin.

N/A

All replaced equipment and excess gravel, stone, concrete,bricks, temporay fencing and the like shall be removed from the site upon completion of the work.

N/A

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MITIGATION MEASURE (OBJECTIVE AND TARGET) COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

No discarded material of any nature shall be buried on the site or on any other land within the site.

2 No material is buried on-site.

Re-seeding shall be done on distured areas as directed by the CEO. 2 The ECO has recommended sowing of cynodon grass seeds on disturbed areas.

The Contractor shall dispose of all excess material on-site in an appropritae manner and at a designed place.

2 Method statement for disposal available on-site.

All anticpated crop damage shall be noted while access negotiations are underway.

2 Potential damages have been noted and communicated to the Contractor.

All damage to commercial crops shall be recorded immediately. 2 Incident register availabel on-site to record damages,

All claims for compensation emanting from crop damage should be directed to the ECO for appraisal.

N/A No crop damages have occured.

The Contractor shall be held liable for all unnecessary damage to crop and the enviroment.

2 The Contractor has been made aware of his liabilities.

10.23 MONTORING OF EMPR COMPLIANCE

The correct and successful implementation of impact mitigation measures in order to reduce adverse impacts on enviroment conditions needs to be ensured by a proper monitoring program.

2 Environmental auditing by both ECO and CEO ensures that mitigation measures are implemented.

Monitoring of the general implementation of/adherence to the EMPR shall be the respnsibiity of the ECO.

2 ECO has assumed this responsibility.

10.24 DOCUMENT CONTROL

A Copy of the EMPR and the EA will be made avaible on site at all times. 2 Copies are kept on-site.

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MITIGATION MEASURE (OBJECTIVE AND TARGET) COMPLIANCE STATUS COMMENTS

2= Full Compliance 1= Partial Compliance 0= Non-Compliance NA= Not Applicable

The EMPR as well as the EA will be used for referral as the project progresses. The EA will also be presented to the authorities at any random time that they might visit the site.

2