environmental management programme wwtw ba caitlin... · 2017. 10. 13. · port st johns wwtw empr...

EOH Coastal & Environmental Services PSJ Waste Water Treatment Works i

ENVIRONMENTAL MANAGEMENT PROGRAMME

PORT ST JOHNS WASTE WATER TREATMENT WORKS

Prepared for:

OR Tambo District

Municipality

Element Consulting Engineers

52 Stewart Drive Baysville

East London, 5241 South Africa

Prepared by:

EOH Coastal & Environmental Services EAST LONDON

25 Tecoma Street, Berea East London, 5214

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

and Maputo www.cesnet.co.za

October 2017

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

Port St Johns WWTW EMPr – October 2017

EOH Coastal & Environmental Services ii PSJ Waste Water Treatment Works

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

1.1 Objectives of an EMPr ...................................................................................................................... 1 1.2 Structure and Function of an EMPr .................................................................................................. 2 1.3 Legal requirements .......................................................................................................................... 3

2 DETAILS OF THE ENVIRONMENTAL ASSESSMENT TEAM .................................................................. 4 3 PROPOSED ACTIVITY ...................................................................................................................... 6

3.1 Description of proposed activity ...................................................................................................... 6 3.1.1 Project background ......................................................................................................................... 6 3.1.2 Project description ......................................................................................................................... 6

4 SCOPE OF THE EMPR ...................................................................................................................... 8 4.1 Layout of the EMPr .......................................................................................................................... 8

4.1.1 Planning and design phase ............................................................................................................ 8 4.1.2 Construction Phase ........................................................................................................................ 8 4.1.3 Operational and Maintenance Phase ............................................................................................ 8

5 MITIGATION AND/OR MANAGEMENT MEASURES .......................................................................... 9 6 ENVIRONMENTAL MONITORING .................................................................................................. 27 7 ROLES AND RESPONSIBILITIES ...................................................................................................... 28

7.1 Project Coordinator ....................................................................................................................... 28 7.2 Contractor ...................................................................................................................................... 28 7.3 Environmental Control Officer ....................................................................................................... 28

8 COMPLIANCE WITH THE EMPR ..................................................................................................... 30 8.1 Non-compliance ............................................................................................................................. 30 8.2 Emergency preparedness ............................................................................................................... 31 8.3 Incident reporting and remedy ...................................................................................................... 31 8.4 Penalties ......................................................................................................................................... 31

9 REPORTING .................................................................................................................................. 33 9.1 Administration ............................................................................................................................... 33 9.2 Good housekeeping ....................................................................................................................... 33 9.3 Record keeping............................................................................................................................... 33 9.4 Document control .......................................................................................................................... 33

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

11 CLOSURE PLANNING..................................................................................................................... 37 11.1 Post-construction audit .................................................................................................................. 37 11.2 General review of EMPr ................................................................................................................. 37

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


EOH Coastal & Environmental Services PSJ Waste Water Treatment Works 1

1 INTRODUCTION

1.1 Objectives of an EMPr The EMPr has been compiled to provide recommendations and guidelines according to which compliance monitoring can be done during the construction and operation of a new waste water treatment works (WWTW) in Port St Johns (PSJ), Eastern Cape. The objective of the EMPr is also to ensure that all relevant factors are considered to ensure for environmentally responsible development. The purpose of the EMPr is to provide specifications for "good environmental practice" for application during this phase.

Figure 1: Locality of the proposed PSJ WWTW site options. This EMPr informs all relevant parties, which are in this case, the Project Coordinator, the Contractor, the Environmental Control Officer (ECO) and all other staff employed by OR Tambo District Municipality at the site (Figure 1) as to their duties in the fulfilment of the legal requirements for the construction and operation of the WWTW with particular reference to the prevention and mitigation of anticipated potential environmental impacts. The objectives of an EMPr are to:

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

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

Verify environmental performance through information on impacts as they occur;

Respond to unforeseen events;

Provide feedback for continual improvement in environmental performance;

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

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

Identify measures that could optimize beneficial impacts;



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

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

Ensure that safety recommendations are complied with;

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

1.2 Structure and Function of an EMPr An EMPr is focused on sound environmental management practices, which will be undertaken to minimise adverse impacts on the environment through the lifetime of a development. In addition, an EMPr identifies what measures will be in place or will be actioned to manage any incidents and emergencies that may occur during operation of the facility. As such the EMPr provides specifications that must be adhered to, in order to minimise adverse environmental impacts associated with the construction and operation of the WWTW. Although this EMPr is not legally binding in terms of the EIA regulations (2014, amended in 2017), the content of the EMPr is consistent with the requirements as set out in Appendix 4 of the EIA regulations stated below, for the construction and operation phases.

According to APPENDIX 4 of GN R 326 (NEMA as amended in 2017), an environmental management programme must include:

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

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

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

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

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

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

and (v) where relevant, operation activities;

(e) A description and identification of impact management outcomes required for the aspects contemplated in (d).

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

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

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

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



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

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

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

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

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

regulations; (m) An environmental awareness plan describing the manner in which –

(i) The applicant intends to inform his or her employees of any environmental risk which may result from their work; and

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

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

1.3 Legal requirements

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

Constitution Act (No. 108 of 1996)

EIA Regulations (2014, amended in 2017)

National Environment Management Act (No. 107 of 1998)

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

National Water Act (No. 36 of 1998)

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

National Environmental Management: Waste Act (2008): National Norms and Standards for the assessment of waste for landfill disposal.

National Heritage Resources Act (No. 25 of 1999)

Informal Land Rights Act (No. 109 of 1996)

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

National Forestry Act (No. 84 of 1998) Municipal policy

OR Tambo District Municipality Integrated Development Plan

PSJ Local Municipality Strategic Development Framework



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

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

a curriculum vitae;

Environmental Consulting Company: EOH Coastal & Environmental Services 25 Tecoma Street, Berea, East London, 5214 PO Box 8145, Nahoon, East London, 5210 Tel: 043 726 7809/8313 Fax: 043 726 8352 e-mail: [email protected] www.cesnet.co.za Project Team:

Dr Alan Carter

Dr Greer Hawley

Ms Caitlin Smith EOH Coastal and Environmental Services (EOH) has been appointed to conduct an Environmental Impact Assessment (EIA) for the proposed WWTW. EOH was established in 1990 as a specialist environmental consulting company and has considerable experience in terrestrial, marine and freshwater ecology, the Social Impact Assessment process, State of Environment Reporting, Integrated Waste Management Plans, Environmental Management Plans, Spatial Development Frameworks, public participation, as well as the management and co-ordination of all aspects of the EIA and Strategic Environmental Assessment processes. Dr Alan Carter, Pr.Sci.Nat.(Report review) Alan is the executive of the EOH East London Office. He holds a PhD in Marine Biology and is a Certified Public Accountant, with extensive training and experience in both financial accounting and environmental science disciplines with international accounting firms in South Africa and the USA. He has 25 years’ experience in environmental management and has specialist skills in sanitation, coastal environments and industrial waste.



Dr Greer Hawley, Pr.Sci.Nat. Principal Environmental Consultant, has a BSc degree in Botany and Zoology and a BSc Honours in Botany from the University of Cape Town. She completed her PhD thesis (Microbiology) at Rhodes University. Greer has been involved in a number of diverse activities. The core academic focus has been directed in the field of taxonomy both in the plant and fungal kingdom. Greer's research ranges from studying fresh and marine algae, estuarine diatoms, Restio species classification in the fynbos and forest vegetation and fungal species identification and ecology. Greer's study of fungi have also contributed towards an understanding of soil ecology and "below ground" ecology. She is currently working on numerous impact assessments at the East London branch. Ms Caitlin Smith (Project Manager, Report Writer), Pr.Sci.Nat. Senior Environmental Consultant. Caitlin holds a BSc degree with majors in Geology and Geography and a BSc Honours Degree (with distinction) in Geology both obtained from Nelson Mandela Metropolitan University. Caitlin is a qualified geologist and has managed and been involved in various Environmental Impact Assessments. Caitlin has completed various Aquatic and Wetland assessments for road and infrastructure projects. She is currently studying her MSc degree in Hydrology at Rhodes University focusing on the groundwater and surface water interactions of the Krom River wetlands.



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

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

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

3.1 Description of proposed activity 3.1.1 Project background OR Tambo District Municipality is proposing the development of a new waste water treatment works (WWTW) with a capacity of 3.5 Ml/day to serve the town of Port St Johns (PSJ). PSJ is currently serviced by a combination of septic tanks, conservancy tanks and pit latrines. Raw sewage is currently entering the Mzimvubu Estuary and possibly other watercourses in PSJ. Conservancy tanks in town are also overflowing into the streets. Sewage from conservancy tanks is collected by honeysuckers and discharged into existing non-functioning oxidation ponds about 360 m upslope of the Town’s dam and Water Treatment Works. Various site options (up to 9 sites) have been discussed and site visits have been undertaken with stakeholders (DEDEAT, DWS, DAFF, etc.) and the PSJ Local Municipality (LM) over a number of years in order to identify available sites. A number of site alternatives were eliminated for environmental and technical reasons and only 3 sites are being assessed further (site 3, site 4B and site 8). 3.1.2 Project description The proposed WWTW sites that will be considered in this Basic Assessment Report (BAR) are indicated in Figure 2 below.



Figure 2: Map indicating the location of the proposed WWTW site options.

The proposed treatment option is an extended aeration activated sludge system. In the extended aeration system raw sewage is digested in a sealed, aerated biodigestor. The efficiency of treatment of an extended aeration system results in a higher quality effluent than a normal activated sludge processes. Scope of works: • Construction of an inlet works (manual screening & de-grit channels); (effluent is screened for large

solids at inlet works which are placed in skips, disposed of with dried sludge) • Installation of flow measuring equipment; • Construction of a biological reactor (extended aeration); • Construction of 2 x clarifiers (sedimentation for sludge or suspended solids removal); • Construction of mechanical sludge dryer with skips for disposal (this is to keep the site footprint as small

as possible. Sludge drying beds require large areas, which means a larger footprint for the site. Dried sludge to be disposed at the local landfill site, but can be used as fertiliser, should there be interest in using it);

• Construction and lining of 2 x maturation ponds / reed beds; (this is for tertiary treatment of effluent) • Construction of a chlorination channel or UV disinfection (which is an alternative disinfection method,

although more expensive); and • Final effluent discharge (Effluent discharged to DWS – General Standards).



4 SCOPE OF THE EMPr In order to ensure a holistic approach to the management of environmental impacts during the construction and operation of the proposed treatment facility this EMPr sets out the methods by which proper environmental controls are to be implemented by the Contractor and all other parties involved. The EMPr is a dynamic document subject to influences and changes as are wrought by variations to the provisions of the project specification.

4.1 Layout of the EMPr The EMPr is divided into three phases of development. Each phase has specific issues unique to that period of the development of the WWTW and associated infrastructure. The impacts are identified and given a brief description. The two phases of the development are then identified as below: 4.1.1 Planning and design phase This section of the EMPr provides management principles for the planning and design of the project. Environmental actions, procedures and responsibilities as required during the planning and design phase are specified. 4.1.2 Construction Phase This section of the EMPr provides management principles for the construction phase of the project. Environmental actions, procedures and responsibilities as required during the construction phase are specified. These specifications will form part of the contract documentation and therefore the Contractor will be required to comply with these specifications to the satisfaction of the Project Coordinator and ECO. 4.1.3 Operational and Maintenance Phase This section of the EMPr provides management principles for the operation and maintenance phase of the project. Environmental actions, procedures and responsibilities as required from OR Tambo District Municipality during the operation and maintenance phase are specified.



5 MITIGATION AND/OR MANAGEMENT MEASURES According to APPENDIX 4 of GN R 326, an environmental management programme must include:

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

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

and (v) where relevant, operation activities;

(e) A description and identification of impact management outcomes required for the aspects contemplated in paragraph (d).

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

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

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

where applicable;

Issues and Mitigation Measures associated with the PSJ WWTW (General Mitigation Measures from the BAR).

Planning and design phase

Issue Mitigation measure

Legal and policy compliance

• During the planning and design phase all relevant legislation and policies must be consulted and the proponent must ensure that the project is compliant with such legislation and policy.

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

• No construction activity may commence prior to issuing of the Environmental Authorisation by DEDEAT.

• All necessary Water Use Licences must be in order prior to commencement of construction activity.

• All necessary permits (permits for forest removal or any protected plant or animal species) must be in order prior to construction activity.

• A suitably qualified Environmental Control Officer (ECO) must be appointed for the duration of the construction phase.

Risks associated with infrastructure

• During the planning and design phase a planning and maintenance schedule must be developed for periodic inspections of the sewer system and must identify who and how often inspections are done.



• Back-up generators to power the core elements of the WWTW must be installed.

• ORTDM must ensure that the WWTW and associated infrastructure is operated and maintained for the system to run effectively.

• It is recommended that an external (appropriately skilled) contractor be appointed to run the WWTW for a period of 5-10 years

• It is recommended that all staff who work at the facility be retained for a full 5 years.

• During this period of time operational training can also be provided to local employees.

• During the planning and design phase technically sound and SABS approved sewer material must be selected and used.

• The sewage pipes MUST be tested for defects and leaks before the trenches, in which the pipelines will be laid, are closed.

• In the case of the pipeline crossing the Mzimbvubu River to site 4B (should this site be authorised) it is recommended that materials such as a glass reinforced pipe or ductile iron pipe be considered for this pipeline.

• Appropriate pipe material must be selected for the pipeline running alongside the Mzimvubu River.

Design of infrastructure • During the planning and design phase the sewage infrastructure should, as far as possible, be placed outside the 1:100 floodline.

• Pump stations should not be placed within 50 m of watercourses (wherever this is possible)

• A generator must be in place at the WWTW and pump stations (if necessary) in case of electricity outages.

• An appropriate holding facility (24-48 hrs) must be designed for the WWTW and pump stations in case of system failures.

• It is recommended that the additional final polishing technology proposed and offered by Dr Anthony Turton (final polishing using vertical up flow modular engineered wetland system) be considered in the final design of the WWTW as an extra final effluent polishing step.

• The sewage pipeline running along the road adjacent to the Mzimvubu River should be placed on the western edge of the road (away from the river side) above the stormwater canal.

Water quality • During the planning and design phase an effective water quality monitoring programme must be developed to ensure that the quality of treated waste water during operation is suitable.

Poor design of holding capacity of the new WWTW system and maturation ponds

• During the planning and design phase the new WWTW and maturation ponds must have a suitable holding capacity for projected sewage inflows.

• Stormwater must be diverted away from the new WWTW. • The maturation pond must be completely sealed.

Stormwater management

• During the planning and design phase stormwater management plans must be developed prior to commencement of construction.



• These plans must be submitted and approved by the ECO before construction activity begins.

Air quality • During the planning and design phase appropriate odour mitigating infrastructure must be incorporated into the design of the inlet works (inlet works must be covered, equipped with scrubbers, etc.).

Construction phase


Site establishment and site clearing

• During the construction phase the contractor must establish his construction camp, offices and other infrastructure in previously impacted areas (when possible) and in a manner that does not adversely impact the environment.

• The contractor must submit a method statement for site clearance for approval by the Project Coordinator and ECO.

• The necessary ablution facilities must be provided and should not be located within 50 m of a watercourse.

• No fires must be allowed at the construction camp and the necessary fire fighting equipment must be available on site.

• The contractor must supply waste collection bins and all solid waste must be disposed of at a registered municipal landfill site. No solid waste may be burnt on site.

• The area to be cleared must be clearly demarcated and the footprint strictly maintained.

• Erosion control measures must be employed. • Appropriate signage and demarcation must be placed to

indicate the construction footprint and any “no-go” areas.

Noise pollution • During the construction phase construction activity should be limited to normal daylight working hours (7am- 5pm).

• Construction site yards, workshops and other noisy fixed facilities should be located well away from noise sensitive areas (houses, tourism facilities, etc.)

• Heavy vehicle traffic should be routed away from noise sensitive areas, wherever possible.

• Blasting operations (if required) are to be strictly controlled with regard to the size of explosive charge in order to minimise noise. The number of blasts per day should be limited, blasting should be undertaken at the same times each day and no blasting may be allowed at night.

• The contractor must take measures to discourage labourers from loitering in the surrounding area and causing noise disturbance.

• Any noise complaints must be attended to immediately by the contractor.

Air quality • During the construction phase damping down of un-surfaced and un-vegetated areas during dusty periods may be required.

• Retention of vegetation where possible will reduce dust travel.



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

• A speed limit of 30 km/hr must not be exceeded within the construction areas. This includes local public gravel roads used to access the site.

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

Fire risk • During the construction phase fires must be prohibited on site. • The construction and operation personnel must be educated

about fire management. • Fire fighting equipment (fire extinguishers) must be available

onsite at all times. • All fire fighting equipment must be clearly marked.

Socio-economic • During the construction phase access to the site must be controlled to ensure that no unauthorised people enter the premises.

• As far as possible local labour should be employed during construction.

• A complaints register must be kept on site and be made available to the ECO during audits.

• As far as possible local labour should be employed during the construction phase.

Water quality • During the construction phase all hazardous substances must be stored in bunded containment areas with sealed surfaces.

• Hazardous substances should not be stored within 50 m of a watercourse.

• Adequate ablution facilities must be provided for construction workers and regularly serviced.

• The site must be managed in a manner that prevents pollution of drains, downstream watercourses or groundwater.

• Temporary cut-off drains and berms may be required to capture stormwater and promote infiltration.

• No concrete mixing must take place within 50 m water of a watercourse.

• All concrete mixing must take place on a non-permeable surface.

• Drip trays must be provided under machinery to prevent soil contamination.

Increased traffic • During the construction phase local residents should be made aware of the presence of construction vehicles by making use of high-visibility signage.

• Whenever possible construction vehicles should be limited to low-volume periods.

• Road conditions should be recorded prior to construction vehicles making use of the roads and any damage caused by construction vehicles should be repaired.

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



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

• Good housekeeping measures must be implemented throughout the construction phase.

Operation phase


Water quality • During the operational phase the WWTW and associated infrastructure must be sufficiently maintained.

• A complaints register must be kept on site and provided to ORTDM.

• Back-up generators must be installed at the WWTW and pump stations.

• Effluent quality must be analysed monthly for the first two years and thereafter monitored bi-monthly.

• Appropriate corrective actions must be taken immediately if contamination is detected or effluent quality does not meet discharge standards.

• Appropriate monitoring boreholes must be installed to detect possible groundwater contamination.

• Sewage pipelines must be regularly monitored for leaks. If these are identified or reported by the public immediate action must be taken to remedy the situation.

Release of non-compliant effluent

• During the operation phase the WWTW and associated infrastructure must be regularly inspected for leaks or problems.

• Effluent quality must be monitored by an accredited laboratory. • Green Drop status standards and guidelines must be achieved. • Water quality at monitoring boreholes must be regularly

checked. • It is recommended that an external suitably trained contactor

be appointed to run the facility for at least the first 5 years of operation.

Health risk to employees • During operation the employees must undergo sufficient training in Health and Safety as well operation of the WWTW.

Operation skills capacity • During the operational phase ORTDM must roll out extensive training for all employees and staff on the operation and maintenance of the treatment facility.

• An annual audit on the training expertise of the staff needs to be undertaken in order to assess whether further training is necessary.

• It is recommended that an external (appropriately skilled) contractor be appointed to run the WWTW for a period of 5-10 years. During this period of time operational training can also be provided to local employees.

Air quality • During the operational phase the WWTW must be correctly operated and monitored to mitigate this impact.

• This impact can be mitigated in the planning and design phase



of the project by incorporating the correct odour mitigating infrastructure into the design of the inlet works (inlet works must be covered, equipped with scrubbers, etc.).

• Sulphurous odours are normally the first indication that the WWTW is not functioning optimally. The source of the odour must be investigated immediately and appropriate corrective measures taken.

• Ensure that screenings are correctly and securely dried and stored prior to disposal. The application of lime to the screenings may be required.

Operational budget • During operation an adequate operational and maintenance budget must be provided by ORTDM.

Sludge disposal • The disposal of sludge must be undertaken in accordance with the guidelines and recommendations in the “Permissible utilisation and disposal of sewage sludge” obtainable from the Department of Water and Sanitation (DWS), “The National Norms and Standards for assessment of waste for landfill disposal” and Category C of the Waste Act (1998).

• Agricultural applications and disposal of sludge to a landfill site are potential options.

• The sludge will need to be tested to determine the appropriate final disposal method (excluding sludge that will be disposed of at a landfill site).

• Sludge may not be disposed of onsite.

Screen disposal • Screened material must be dried on drying racks and stored in bunded areas until removal and disposal at the nearest landfill site.

• Disposal of screened material should take place regularly (weekly).

Specialist mitigation measures: Aquatic Impact Assessment Planning and design • All legal matters pertaining to permitting must be completed prior to any construction

activity. • In particular, all necessary Water Use Licences must be in order for any construction

activity within watercourses (or within the 1:100 floodline, if determined). • During the planning and design phase a Rehabilitation and Alien Vegetation Management

Plan must be developed to reduce the establishment and spread of undesirable alien plant species.

• During the planning and design phase an effective water quality (surface and groundwater, if necessary) monitoring programme must be developed to ensure that the quality of treated waste water during operation is suitable.

• During the planning and design phase it is recommended that the top portion of the sewage pipeline to site 3 (if this site is authorised) be moved out of the drainage system.



• It is recommended that where the sewage pipeline crosses watercourses below site 4B (if this site is authorised) it should be concrete encased, constructed using suitable technology (resistant to flood or other damage) or be directionally drilled.

• It is recommended that the footprint of site 3 (if authorised) be adjusted to avoid the drainage systems north-west and west of the footprint.

• It is recommended that the northern portion of the footprint of site 8 (should it be authorised) be adjusted slightly to avoid the drainage system.

Construction phase: • During the construction phase rivers and drainage systems must be avoided as far as

possible. • The construction footprint and route for construction vehicles must be clearly demarcated. • No vehicles and machinery should be parked overnight within 50 m of a watercourse. • An Environmental Control Officer (ECO) must be appointed for the duration of construction

activity. • During the construction phase no concrete mixing must take place within 50 m of any river

bank or drainage line. • No vehicles or machinery must be parked overnight within 50 m of watercourses. • All hazardous substances must be kept on bunded surfaces more than 50 m from

watercourses. • All concrete mixing must occur on impermeable surfaces. • A serviced fire extinguisher (to neutralise pH levels if a spill occurs in watercourses) must

be available on site in the event that wet concrete is accidentally spilled into a river. • The mitigation measures in Appendix A must be used in conjunction with this report. • A Rehabilitation and Alien Vegetation Management Plan must be implemented during the

construction phase to reduce the establishment and spread of undesirable alien plant species.

• Contractors must adhere to the conditions in the EA and WULA. Operation phase: • During the operation phase the quality of treated final waste water must be continuously

monitored. • Any operational issues resulting in poorly treated effluent must be repaired immediately. • The use of treated waste water for irrigation/ discharge must conform to guidelines

provided in the Department of Health’s publication – Guide: Permissible Utilisation and Disposal of Treated Sewage Effluent.

• During the operational phase sewage infrastructure must be maintained and pipelines checked for leaks on a regular basis.

• If leaks or other system failures are identified or reported by the public, immediate actions must be taken to repair the infrastructure.

• Back-up generators to power the core elements of the WWTW must be installed prior to operation.

• All personnel operating and maintaining the WWTW infrastructure must be appropriately trained.

• A rehabilitation plan must be implemented post-construction. • Alien plants must be removed from aquatic environments through appropriate methods

such as hand pulling, cutting etc. This must be done under the supervision of the ECO.



Wetland Impact Assessment Planning and design phase • All legal matters pertaining to permitting must be completed prior to any construction

activity. • In particular, all necessary Water Use Licences must be in order for any construction

activity within 500 m of a wetland. • It is recommended that once a final site has been approved that a wetland specialist be

appointed to complete a detailed wetland delineation prior to commencement of construction.

• An Environmental Control Officer (ECO) must be appointed for the duration of construction activity.

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

• During the planning and design phase an effective water quality (surface and groundwater, if necessary) monitoring programme must be developed to ensure that the quality of treated waste water (discharged to land/watercourses) is suitable

• If the pipeline (to site 4B from the Mzimvubu Bridge) is placed above ground or trenched it is recommended that as far as possible the route follows the existing road and avoids sensitive wetland vegetation.

• If the pipeline (to site 4B from the Mzimvubu Bridge) is placed above ground or trenched it is recommended that it be encased in concrete or constructed using appropriate technology to prevent leaks or damage due to floods.

Construction phase: • During the construction phase a rehabilitation and alien vegetation management plan must

be implemented (and monitored post-construction). • Alien plants within wetland ecosystems must be removed from the site through

appropriate methods such as hand pulling, cutting etc. This must be done under the supervision of the ECO.

• During the construction phase the wetlands at site 4B must as far as possible be avoided. • The construction footprint and route for construction vehicles must be clearly demarcated. • No vehicles and machinery should be parked in the wetland area (at site 4B). • An ECO must be appointed for the duration of construction activity. • During the construction phase all wetland vegetation removal (if necessary) must take

place under supervision of the Environmental Control Officer (ECO). • Concrete mixing and stockpiling of construction materials should not take place within 50

m of the wetland (site 4B). • Removal of wetland vegetation must be avoided, as far as possible. • Rehabilitation and Alien Vegetation Management Plan must be developed and

implemented. • Removal of the alien invasive vegetation should be prioritised. • Vehicles and machinery should not encroach into areas outside/surrounding the project

footprint. • A designated pipeline route must be marked out and surrounding areas avoided (pipeline

through wetland to site 4B). This route should as far as possible follow the existing road.



Operation phase: • During the operation phase the quality of treated final waste water must be continuously

monitored. • The use of treated waste water for irrigation/ discharge must conform to guidelines

provided in the Department of Health’s publication – Guide: Permissible Utilisation and Disposal of Treated Sewage Effluent.

• It is recommended that a portion of the treated effluent water produced is irrigated, discharged to land or re-used elsewhere to minimise the potential impact on the hydrology and geomorphology of downstream wetlands.

• If any leaks are identified these must be repaired immediately. If the pipeline is placed above ground (to site 4B) it should be concrete encased (or constructed using suitable technology to eliminate risk of leakage).

• If any pipeline leaks are identified these must be repaired immediately. • A trenched or directionally drilled pipeline (through the wetlands to site 4B) must be

constructed using suitable material that prevents any risk of damage or leakage. • During the operational phase sewage infrastructure must be maintained and pipelines

checked for leaks on a regular basis. • If leaks or other system failures are identified or reported by the public, immediate actions

must be taken to repair the infrastructure. • Back-up generators to power the core elements of the WWTW must be installed prior to

operation. • All personnel operating and maintaining the WWTW infrastructure must be appropriately

trained. Ecological Impact Assessment Planning and design phase • All legal matters pertaining to permitting must be completed prior to any construction

activity. • In particular, all necessary permits must be in place to removed protected indigenous

forest. • The relevant permits must be obtained from the competent authority in order to remove

any protected plant and animal species. • A Rehabilitation and Alien Vegetation Management Plan must be designed to reduce the

establishment and spread of undesirable alien plant species. • The layout of the access road must have as minimal impact on the indigenous forest as

possible. • Offsets by DAFF may be required. • All plant and faunal SCC must be relocated to outside the construction footprint prior to

construction commencing. • The relevant permits must be obtained from the competent authority in order to remove

or destroy any SCC. For Site Location (Site 3): • The layout of the WWTW must be designed to avoid forest vegetation as far as practicable.



• All plant and faunal SCC must be relocated to outside the construction footprint prior to construction commencing.

• The relevant permits must be obtained from the competent authority in order to remove or destroy any SCC.

• The layout of the sewage reticulation pipeline must have as minimal impact on the indigenous forest as possible.

• The sewage reticulation pipeline must follow the road or be located south of the proposed route outside of the forest vegetation within the drainage line.

• All plant and faunal SCC must be relocated to outside the construction footprint prior to construction commencing.

• The relevant permits must be obtained from the competent authority in order to remove or destroy any SCC.

• The access road must be designed to avoid forest as far as practicable. For Site Location (Site 4B): • The layout of the WWTW must be designed to avoid forest vegetation as far as practicable. • Offsets by DAFF may be required. • All plant and faunal SCC must be relocated to outside the construction footprint prior to


or destroy any SCC. • The layout of the sewage reticulation and discharge pipeline must have as minimal impact

on the indigenous forest as possible. • All plant and faunal SCC must be relocated to outside the construction footprint prior to


or destroy any SCC. For Site Location (Site 8): • The layout of the WWTW must be designed to avoid forest vegetation as far as practicable. • All plant and faunal SCC must be relocated to outside the construction footprint prior to


or destroy any SCC. • The layout of the sewage reticulation and discharge pipeline must have as minimal impact

on the indigenous forest as possible. • All plant and faunal SCC must be relocated to outside the construction footprint prior to


or destroy any SCC. Construction phase • All legal matters pertaining to permitting must be completed prior to any construction

activity. • In particular, all necessary permits must be in place to removed protected indigenous

forest.



• The relevant permits must be obtained from the competent authority in order to remove any protected plant and animal species.

• All areas that will be impacted must be surveyed by a suitably qualified botanist/ecologist prior to topsoil removal in order to locate and rescue and SCC within the area and relocate them.

• No SCC must be removed from site. All SCC must be relocated immediately outside the construction and operation footprint.

• Search and rescue must be undertaken by a professional and qualified botanist. • The construction footprint must be surveyed and demarcated prior to construction

commencing by an approved Environmental Control Officer (ECO). • Daily site visits must be conducted by the ECO until all clearing is complete. • The contractor’s staff must not approach or trap wild animals. • The contractor’s staff must not harvest any natural vegetation. • Wood storage must be done in accordance with the recommendations of DAFF. • Vehicles and machinery must not encroach into areas outside of the approved

development footprint. • The Rehabilitation and Alien Vegetation Management Plan must be developed and

implemented during construction. • Where vegetation has been cleared, site rehabilitation in terms of soil stabilisation and re-

vegetation must be undertaken. • All areas that will be impacted must be surveyed by a suitably qualified botanist/ecologist

prior to topsoil removal in order to locate and rescue and SCC within the area and relocate them.

• No SCC must be removed from site. All SCC must be relocated immediately outside the construction and operation footprint.

• Search and rescue must be undertaken by a professional and qualified botanist. • The construction footprint must be surveyed and demarcated prior to construction

commencing by an approved Environmental Control Officer (ECO). • Daily site visits must be conducted by the ECO until all clearing is complete. • Labour intensive clearing and trenching must be implemented for all pipelines, to ensure

minimal damage on the environment. • The contractor’s staff must not approach or trap wild animals. • The contractor’s staff must not harvest any natural vegetation. • Wood storage must be done in accordance with the recommendations of DAFF. • Vehicles and machinery must not encroach into areas outside of the approved

development footprint. • The Rehabilitation and Alien Vegetation Management Plan must be developed and

implemented during construction. • Where vegetation has been cleared, site rehabilitation in terms of soil stabilisation and

revegetation must be undertaken. • An Alien Vegetation Management Plan must be implemented during the construction

phase to reduce the establishment and spread of undesirable alien plant species. • Alien plants must be removed from site through appropriate methods such as hand pulling,

application of chemicals, cutting, etc. as in accordance with the NEMBA: Alien Invasive Species Regulation.

• All impacted areas must be rehabilitated with indigenous vegetation. • Only topsoil from the immediate area must be used for rehabilitation. • All impacted areas must be restored as per the Rehabilitation Management Plan.



Operation phase • All cleared areas must be continuously rehabilitated with indigenous vegetation for 6

months after the Operational phase of the project has commenced, or until such time that the ECO is satisfied that all affected areas have been rehabilitated.

Estuary Impact Assessment: Planning and design phase • A water quality monitoring programme must be developed, which must include monitoring

points within the estuary. • The monitoring programme must include both biotic and abiotic parameters. • A practical and efficient reporting and implementation system must be developed through

which water quality issues can be quickly identified and resolved. • A percentage of the total daily discharge must be redirected to other discharge methods

such as irrigation to land. • A water quality monitoring programme must be developed, which must include a

monitoring point within the estuary. • A detailed maintenance programme must be developed that includes regular visual

inspections of the sewage pipeline. • The maintenance programme must also include a clear reporting and action system when

damage to the pipeline is identified in order to ensure that repairs are made quickly. • An emergency response plan must be developed that allows for the pumping systems to be

shut down in the event of the sewage pipeline being damaged during a flood. • The sewage pipeline must also have valves installed at either end of the bridge that will

allow the flow of sewerage to be temporarily stopped until repairs to the pipeline can be made.

• The sewage pipeline suspension bridge must be placed as closed to the existing bridge as possible.

• The sewage pipeline suspension bridge must be located up stream of the existing bridge to prevent damage to the pipeline suspension bridge by the existing bridge in the event of flooding.

• The support structures of the bridge must be constructed outside of the 1:100 year flood line and the height of the pipeline must be above previously recorded flood levels.

• An emergency response plan must be developed that allows for the pumping systems to be shut down in the event of the sewage pipeline being damaged during a flood.

• The sewage pipeline must also have valves installed at either end of the bridge that will allow the flow of sewerage to be temporarily stopped until repairs to the pipeline can be made.

• The support structures of the bridge must be constructed in such a way that the footprint of the support structures does not significantly alter the structure of the banks of the estuary.

• A geotechnical survey must be conducted to determine the structure of the bed of the Mzimvubu estuary.

• A site indicating suitable geology and soil type must be selected before drilling commences. • A maintenance plan must be developed for the sewage pipeline. • Proper planning of the drilling route, including, entry and exit points and angle of entry

must be conducted prior to drilling activities occurring.



• The sewage pipeline crossing Bulolo Estuary must be placed in such a way that it is not directly exposed to damage or vandalism.

• The sewage pipeline crossing Bulolo Estuary must be encased in concrete to ensure that the pipeline is protected from damage and vandalism

• The sewage pipeline must also have valves installed at either end of the bridge that will allow the flow of sewerage to be temporarily stopped until repairs to the pipeline can be made.

• A geotechnical survey (if directionally drilled pipeline) must be conducted to determine the structure of the bed of the Bulolo estuary.

• A site indicating suitable geology and soil type must be selected before drilling commences. • A maintenance plan must be developed for the sewage pipeline. • Proper planning of the drilling route, including, entry and exit points and angle of entry

must be conducted prior to drilling activities occurring. • The sewage pipeline (along road adjacent to Mtambane Estuary) must be located along the

side of the road that is furthest from the estuary. • The sewage pipeline must be placed in such a way that it is not directly exposed to damage

or vandalism. • The sewage pipeline must be encased in concrete to ensure that the pipeline is protected

from damage and vandalism • A detailed maintenance programme must be developed that includes regular visual

inspections of the sewage pipeline. • The maintenance programme must also include a clear reporting and action system when

damage to the pipeline is identified in order to ensure that repairs are made quickly. • An emergency response plan must be developed that allows for the pumping systems to be

shut down in the event of the sewage pipeline being damaged during a flood. • The pipeline (outside of road further from Mtambane Estuary) route though patched of

indigenous vegetation must be clearly demarcated. • No removal of vegetation must occur outside of the demarcated route. • A Vegetation Management Plan must be developed that allows for the re-vegetation of

cleared areas as quickly as possible to minimise the risk of erosion and subsequent sedimentation of the estuary.

• A detailed maintenance programme must be developed that includes regular visual inspections of the sewage pipeline.

• The maintenance programme must also include a clear reporting and action system when damage to the pipeline is identified in order to ensure that repairs are made quickly.

Construction phase • The construction area within the estuarine zone must be clearly demarcated. • No construction activities must take place outside of the demarcated construction zone. • No estuarine biota may be unnecessarily damaged or destroyed by construction workers. • Hazardous Chemical Substances Regulations promulgated in terms of the Occupational

Health and Safety Act 85 of 1993 and the SABS Code of Practice must be adhered to. This applies to solvents and other chemicals possibly used in the construction process.

• Oil trays must be placed under parked machinery to avoid runoff into the estuary. CONCRETE BATCHING • Concrete should not be mixed directly on the ground, or during rainfall events when the

potential for contamination of the estuary is high (as per the EMPr).



• No concrete must be mixed within 32 meters of the estuary and can only be mixed in the area demarcated for this purpose and on an impermeable substratum.

• A serviced fire extinguisher should be available on site in the event that wet concrete is accidentally spilled into the estuary.

HAZARDOUS CHEMICAL SPILLS • If a spill occurs on an impermeable surface such as cement or concrete, the surface spill

must be contained using oil absorbent materials. • Contaminated remediation materials must be carefully removed from the area of the spill

so as to prevent further release of petrochemicals to the environment, and stored in adequate containers until appropriate disposal.

• No construction activities must take place outside of the demarcated construction zone. • No estuarine biota may be unnecessarily damaged or destroyed by construction workers. • The siting of the support structures must be clearly demarcated. • The drilling route must be completely understood by the drilling contractors. • No deviation from the drilling route must occur unnecessarily. • The pipeline route must be clearly demarcated on the side of the road that is furthest from

the Mtambane estuary. Operation phase Discharge from site 3 – • Regular maintenance of the WWTW infrastructure must be conducted as per the

maintenance programme. • The water quality monitoring programme must be implemented in order to quickly identify

the presence of poorly treated effluent in the estuary. • The volume of treated effluent that is directed into the estuary must be reduced in order

to lessen the impact of decreasing salinity on the estuary. • A percentage of the total daily discharge must be redirected to other discharge methods

such as irrigation to land • Sediment quality must be monitored to assess levels of heavy metals, toxins, organo-

chlorides or microbes that are accumulating in the sediment. Discharge into upper reaches of Mthumbane River – • Regular maintenance of the WWTW infrastructure must be conducted as per the


the presence of poorly treated effluent in the estuary. • The volume of treated effluent that is directed into the estuary must be reduced in order



chlorides or microbes that are accumulating in the sediment. • Regular maintenance of the WWTW infrastructure must be conducted as per the

maintenance programme.



Discharge from site 4B - • Regular maintenance of the WWTW infrastructure must be conducted as per the


the presence of poorly treated effluent in the estuary. • The volume of treated effluent that is directed into the tributary must be reduced in order



chlorides or microbes that are accumulating in the sediment. Irrigation of crop fields approximately 3.5 km away from site 4B – • Regular maintenance of the WWTW infrastructure must be conducted as per the


the presence of poorly treated effluent in the estuary. Discharge from site 8 into Second Beach stormwater system (new system planned for PSJ) which

runs into Mzimvubu Estuary Mouth – • Regular maintenance of the WWTW infrastructure must be conducted as per the


the presence of poorly treated effluent in the estuary. • The volume of treated effluent that is directed into the tributary must be reduced in order



chlorides or microbes that are accumulating in the sediment. • Regular maintenance of the WWTW infrastructure must be conducted as per the


the presence of poorly treated effluent in the estuary. • A percentage of the total daily discharge must be redirected to other discharge methods

such as irrigation to land. Sewage pipeline crossing Mzimvubu Estuary (strapped to existing bridge) – • An infrastructure maintenance plan must be implemented that includes regular visual

inspection of infrastructure. • Any damage to infrastructure must be immediately reported and repair work must be

undertaken as soon as possible. • The emergency response plan must be implemented in order to prevent or limit the

amount of contamination that will occur if the pipeline is washed away.



• Regular maintenance of the WWTW infrastructure must be conducted as per the maintenance programme.

• Any evidence of poorly treated effluent must be reported immediately and relevant repairs must be done as soon as possible.

Sewage pipe bridge across Mzimvubu Estuary (new pipe bridge) - • An infrastructure maintenance plan must be implemented that includes regular visual



amount of contamination that will occur if the pipeline is washed away. • Regular maintenance of the WWTW infrastructure must be conducted as per the

maintenance programme. • Any evidence of poorly treated effluent must be reported immediately and relevant repairs

must be done as soon as possible. Directional drilled pipeline below Mzimvubu Estuary – • An infrastructure maintenance plan must be implemented. • Any damage to infrastructure must be immediately reported and repair work must be

undertaken as soon as possible. • Regular maintenance of the WWTW infrastructure must be conducted as per the


must be done as soon as possible. Sewage pipeline crossing Bulolo Estuary - • An infrastructure maintenance plan must be implemented that includes regular visual



amount of contamination that Will occur if the pipeline is washed away. • Regular maintenance of the WWTW infrastructure must be conducted as per the


must be done as soon as possible. Directional drilled pipeline below Bulolo Estuary - • An infrastructure maintenance plan must be implemented. • Any damage to infrastructure must be immediately reported and repair work must be


maintenance programme.



• Any evidence of poorly treated effluent must be reported immediately and relevant repairs must be done as soon as possible.

Sewage pipeline within the EFZ of Mthumbane Estuary • An infrastructure maintenance plan must be implemented. • Any damage to infrastructure must be immediately reported and repair work must be


amount of contamination that Will occur if the pipeline is washed away. • Regular maintenance of the WWTW infrastructure must be conducted as per the


must be done as soon as possible. Sewage pump stations in close proximity to the coast and estuaries • An infrastructure maintenance plan must be implemented. • Any damage to infrastructure must be immediately reported and repair work must be



must be done as soon as possible. Heritage Study Construction phase: • If human graves are uncovered during construction then all activity must stop immediately,

the police and ECPHRA must to be notified immediately. • If any other archaeological artefacts are uncovered during construction then construction

must stop and these should be reported to the ECO, Heritage Specialist and SAHRA/ECPHRA immediately.

Paleontological Study Planning and design phase • If geotechnical reports indicate a certainty that significant exposure of bedrock will result

during excavations at site 4B and 8 then a phase 1 Paleontological Impact Assessment (by a suitably qualified paleontologist) and formulation of a “Chance Find Protocol” is required.

Construction phase • The ECO must be on the lookout for possible fossils, particularly during excavations that

exceed 2 m in depth. • The ECO must familiarise themselves with the geotechnical report and desktop

paleontological study.



Tourism Impact Assessment: Construction phase • During the construction phase damping down of un-surfaced and un-vegetated areas

during dusty periods may be required. • Retention of vegetation where possible will reduce dust travel. • Excavations and other clearing activities must only be done during agreed working times

and permitting weather conditions to avoid drifting of sand and dust into neighbouring areas.

• A speed limit of 30 km/hr must not be exceeded within the construction areas. This includes local public gravel roads used to access the site. Any complaints or claims emanating from the lack of dust control must be attended to immediately by the Contractor.

• During the construction phase construction activity should be limited to normal daylight working hours (7am- 5pm).

• Construction site yards, workshops and other noisy fixed facilities should be located well away from noise sensitive areas (houses, tourism facilities, etc.)

• Heavy vehicle traffic should be routed away from noise sensitive areas, wherever possible. • Blasting operations (if required) are to be strictly controlled with regard to the size of

explosive charge in order to minimise noise. The number of blasts per day should be limited, blasting should be undertaken at the same times each day and no blasting may be allowed at night.

• The contractor must take measures to discourage labourers from loitering in the surrounding area and causing noise disturbance.

• Any noise complaints must be attended to immediately by the contractor. • During the construction phase local residents and tourists should be made aware of the

presence of construction vehicles by making use of high-visibility signage. • Whenever possible construction vehicles should be limited to low-volume periods. Operation phase • The WWTW must be properly maintained at all times, so as to reduce negative impacts

such as foul odours and system failures. • Emphasis must be placed on the proper maintenance of the WWTW.



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

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

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

A monitoring programme should be implemented for the duration of the construction and operation of the PSJ WWTW. This programme will include:

Establishing a baseline of pre-construction site conditions validated with photographic evidence.

Bi-weekly (fortnightly) monitoring during the first month of construction, where after monthly audits will be conducted by an independent ECO for the remainder of the construction phase to ensure compliance with the EMPr conditions, and where necessary make recommendations for corrective action. These audits can be conducted randomly and do not require prior arrangement with the Project Coordinator.

Compilation of an audit report with a rating of compliance with the EMPr. The ECO shall keep a photographic record of the demarcated site and construction area. Reports must be available on site, and made readily available for any authority or member of public to review. The Contractor shall be held liable for all unnecessary damage to the environment. A register shall be kept of all complaints from the community. All complaints / claims shall be handled immediately to ensure timeous rectification / payment by the responsible party.



7 ROLES AND RESPONSIBILITIES According to APPENDIX 4 of GN R 982, an environmental management programme must include:

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

7.1 Project Coordinator The Project Coordinator is responsible for overall management of project and EMPr implementation. The following tasks will fall within his / her responsibilities:

Be familiar with the recommendations and mitigation measures of this EMPr, and implement these measures.

Monitor site activities on a daily basis for compliance.

Conduct internal audits of the construction site against the EMPr.

Confine the construction site to the demarcated area.

Rectify transgressions through the implementation of corrective action.

7.2 Contractor The contractor is responsible for the overall execution of the activities envisioned in the construction phase including the implementation and compliance with recommendations and conditions of the EMPr. The Contractor must therefore ensure compliance with the EMPr at all times during construction activities and maintain an environmental register which keeps a record of all environmental incidents which occur on the site during construction of the waste water treatment facility. These incidents may include:

Public involvement / complaints

Health and safety incidents

Incidents involving Hazardous materials stored on site

Non-compliance incidents The Contractor is also responsible for the implementation of corrective actions issued by the ECO and Project Coordinator within a reasonable or agreed period of time.

7.3 Environmental Control Officer For the purposes of implementing the conditions contained herein, ORTDM must appoint an ECO for the contract. The ECO will be the responsible person for ensuring that the provisions of the EMPr are complied with during the construction period. The ECO’s duties in this regard will include, inter alia, the following:

Conduct regular site visits to be able to report on and respond to any environmental issues;

Report compliance and non-compliance issues to the municipal representative and authorities as applicable;

Advise the Contractor on environmental issues within the defined work areas;

Review access and incident records that may pertain to the environment and reconcile the entries with the observations made during site inspection, monitoring and auditing;

Recommend corrective action when required for aspects of non-compliance with the EMPr;

Take immediate action on site where clearly defined and agreed “no-go” areas are violated or in danger of being violated and inform an OR Tambo District Municipality representative of the occurrence immediately and to take action;



Be contactable by the public regarding matters of environmental concern as they relate to the operation of the works; and

Take immediate action on site when prescriptive conditions are violated, or in danger of being violated and to inform the OR Tambo District Municipality (ORTDM) representative of the occurrence and action taken.



8 COMPLIANCE WITH THE EMPr

According to APPENDIX 4 of GN R 982, an environmental management programme must include: (j) The time periods within which the impact management actions contemplated in paragraph (f) must

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

paragraph (f);

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

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

There is evidence of contravention of the EMPr specifications within the boundaries of the construction site, site extensions and roads;

There is contravention of the EMPr specifications which relate to activities outside the boundaries of the construction site;

Environmental damage ensues due to negligence;

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

The Contractor fails to comply with corrective or other instructions issued by the Engineer within a specific time period.

It is recommended that the engineers/contractors institute penalties for the following less serious violations and any others determined during the course of work, as detailed below:

Littering on site.

Lighting of illegal fires on site.

Persistent or unrepaired fuel and oil leaks.

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

Excess dust or excess noise emanating from site.

Possession or use of intoxicating substances on site.

Any vehicles being driven in excess of designated speed limits.

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

Urination and defecation anywhere except at designated facilities.



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

Accidental waste water discharges to water and land.

Accidental exposure of employees to hazardous substances.

Accidental fires.

Accidental spillage of hazardous substances.

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

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

A list of key personnel and contact details.

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

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

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

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

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

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

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

the location;

the nature of the load;

the extent of the impact; and

the status at the site of the accident itself (i.e. whether further leakage is still taking place, whether the vehicle or the load is on fire).

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

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

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

Damage to sensitive environments.

Damage to cultural and historical sites.

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



Uncontrolled/unmanaged erosion.

Unauthorised blasting activities (if applicable).

Pollution of watercourses.



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

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

9.1 Administration Before the construction activities begin, the Contractor shall give to the ECO and Project Coordinator a written method statement setting out the following:

Details of the construction activities.

Locality where the activity will take place.

Identification of impacts that might result from the activity.

Identification of activities that may cause an impact.

Methodology and/or specifications for impact prevention for each activity or aspect.

Methodology and/or specifications for impact containment for each activity or aspect.

Emergency/disaster incident and reaction procedures.

Treatment and continued maintenance of impacted environment. The Contractor may provide such information in advance of any or all activities provided that new submissions shall be given to the ECO and/or engineer whenever there is a change or variation to the original. The ECO and/or engineer may provide comment on the methodology and procedures proposed by the Contractor but he shall not be responsible for the Contractor’s chosen measures of impact mitigation and emergency/disaster management systems.

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

9.3 Record keeping The Project coordinator (Element Consulting, the appointed engineer) and the ECO will continuously monitor the Contractor’s adherence to the approved impact prevention procedures and the ECO shall issue to the Contractor a notice of non-compliance whenever transgressions are observed. The ECO should document the nature and magnitude of the non-compliance in a designated register, the action taken to discontinue the non-compliance, the action taken to mitigate its effects and the results of the actions. The non-compliance shall be documented and reported to the engineer in the monthly report.

9.4 Document control The Contractor and Engineer shall be responsible for establishing a procedure for electronic document control. The document control procedure should comply with the following requirements:

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



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

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

The Contractor shall ensure that documents are periodically reviewed and revised, where necessary, and that current versions are available at all locations where operations essential to the functioning of the EMPr are performed. All documents shall be made available to the ECO and other independent external auditors.



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

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

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

Contractors shall ensure that its employees and any third party who carries out all or part of the Contractor’s obligations are adequately trained with regard to the implementation of the EMPr, as well as regarding environmental legal requirements and obligations. Training shall be conducted by the ECO where necessary. Environment and health awareness training programmes should be targeted at three distinct levels of employment, i.e. the executive, middle management and labour. Environmental awareness training programmes shall contain the following information:

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

The framework for appropriate training plans.

The summarised content of each training course.

A schedule for the presentation of the training courses. The ECO shall ensure that records of all training interventions are kept in accordance with the record keeping and documentation control requirements as set out in this EMPr. The training records shall verify each of the targeted personnel’s training experience. OR Tambo District Municipality shall ensure that adequate environmental training takes place. All employees shall be given an induction presentation on environmental awareness and the content of the EMPr. The presentation needs to be conducted in the language of the employees to ensure it is understood. The environmental training shall, as a minimum, include the following:

The importance of conformance with all environmental policies.

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

The environmental benefits of improved personal performance.

Their roles and responsibilities in achieving conformance with the environmental policy and procedures and with the requirement of the Agency’s environmental management systems, including emergency preparedness and response requirements.

The potential consequences of departure from specified operating procedures;

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

Environmental legal requirements and obligations.

The importance of not littering.

The importance of using supplied toilet facilities.

The need to use water sparingly.

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

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



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



11 CLOSURE PLANNING Final site cleaning - the contractor shall clear and clean the site and ensure that all equipment and residual materials not forming part of the permanent works is removed from site before issuing the completion certificate or as otherwise agreed. Rehabilitation - the contractor (landscape architect/horticulturist) shall be responsible for rehabilitating and re-vegetation of all areas disturbed/areas earmarked for conservation during construction to the satisfaction of the engineer and ECO.

11.1 Post-construction audit A post-construction audit must be carried out and submitted to DEDEAT at the expense of ORTDM. Objectives should be to audit compliances with the key components of the EMPr, to identify main areas requiring attention and recommend priority actions. The audit should be undertaken annually and should cover a cross section of issues, including implementation of environmental controls, environmental management and environmental monitoring. Results of the audits should inform changes required to the specifications of the EMPr or additional specifications to deal with any environmental issues which arise on site and have not been dealt with in the current document.

11.2 General review of EMPr The EMPr will be reviewed by the ECO on an on-going basis. Based on observations during site inspections and issues raised at site meetings, the ECO will determine whether any procedures require modification to improve the efficiency and applicability of the EMPr on site. Any such changes or updates will be registered in the ECO’s record, as well as being included as an annexure to this document.



12 CONCLUSIONS Although all foreseeable actions and potential mitigations or management actions are contained in this document, the EMPr should be seen as a day-to-day management document. The EMPr thus sets out the environmental and social standards, which would be required to minimise the negative impacts and maximise the positive benefits of the construction activities. The EMPr could thus change daily, and if managed correctly lead to successful construction and operational phases. All attempts should be made to have this EMPr available, as part of any tender documentation, so that the Engineer and Contractor are made aware of the potential cost and timing implications needed to fulfil the implementation of the EMPr, thus adequately costing for these. It is the responsibility of ORTDM to ensure the Operational Phase mitigation measures are followed and the WWTW is audited at least on an annual basis by an independent auditor.

Port St Johns WWTW EMPr – August 2017
